b'Garys CornerContinued from page 17your responsibilities for the actions for the employeesto consider any possible alternative and never got to of the sub as well as the method by which you willthe question of whether its anchorage point was in enforce those responsibilities. compliance with 1926.502(d)(15)(i) and (ii). I raise this PFAS anchor points issue because I find that frequently, employees in the field will use expedient measures to accomplish a task Howdoyouanchoryourpersonalfallarrestwithout following the rules. In a situation such as the systems? Many employers/employees take short cutsone I have outlined, employees are likely to tie off to when anchoring their personal fall arrest systems.anything that appears to be solid without ever taking Rather than finding an anchor point that complies withany steps to confirm their belief. I believe the subparts the requirements of 1926.502(d)(15) and is capable ofI have discussed above can give the employer an supporting a load of at least 5,000 pounds per employeealternative to installing a 5,000 pound per employee or is designed in compliance with the requirementsrated anchorage point, but they will only come into play of 1926.502(d)(15)(i) and (ii), they tie off to anythingif a qualified person (under the definition in 1926(32)at hand. These alternatives state that the anchorage(m) has made a determination of the safety factor of the must be part of a complete fall arrest system whichproposed anchor point. I must recommend complying maintains a safety factor of at least 2 and which is underwith the requirement for an anchorage point with a 5,000 the supervision of a qualified person. I raise this issuepound load factor per employee. If you choose to rely on because recently I have become aware of citationsthe provisions of (i) and (ii), be sure you have involved being issued for violations of 1926.502(d)(15) becausea qualified person in establishing your anchor point.the employer was not using and could not demonstrate State Plan States that their anchorage point met the 5,000 pounds per employee requirement.I have discussed the requirements of state plan state programs in the past. But some of the differences have become more apparent since COVID-19. If you are Inonecase,thegoing to perform work in a state plan state, remember employer had itsthe rules that govern the work you are going to perform, even though you are based in a state where safety employeesloopis governed by federal OSHA or you are based in a theirsafetylinethroughdifferent state plan state. For example, Virginia has adopted a very detailed Emergency Temporary Standard the sheet metal base of anfor employee exposures to COVID-19. Other state plan HVAC unit using an aluminumstates have either adopted emergency guidance or carabiner that had no weightare in the process of adopting emergency temporary standards. Be aware that guidance in a state plan state, rating.Tomakemattersif more strict than the guidance relied on by federal worse, the set-up had notOSHA to protect employees inlight of the COVID-19 pandemic, will govern all employers working in that been approved or installedstate no matter what the guidance or rules are in the by a qualified person.state in which that employer is based. Also, if you are going to be working in a state plan state, familiarize In one case, the employer had its employees loopyourself with that states safety standards that will govern their safety line through the sheet metal base of anthe work you will be doing as well as the procedures HVAC unit using an aluminum carabiner that had noestablished in that state for challenging any citations weight rating. To make matters worse, the set-up hadyou may receive in that state.not been approved or installed by a qualified person. No effort had been made to determine the load bearing limits of the sheet metal base or the load limits on the carabiner, so OSHA concluded that the employer was in violation of 1926.592(d)(15). The employer failed 18 www.mrca.orgMidwest Roofer'