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As an employer, you are aware of your obligation to provide a safe work environment for your workers per OSHA guidelines. But owners that operate their businesses in California have their own set of – often more strict – safety regulations known as the California Division of Occupational Safety and Health. Are you aware of the most up to date differences between Cal/OSHA and Federal OSHA standards? If not, you could be inadvertently putting your employees and your business at risk. From OSHA roof fall protection requirements to specifications for guardrail systems, you need to understand what your obligations are in 2022.
All businesses are required to follow the safety regulations set forth by the Federal Occupational Safety and Health Administration (OSHA). However, for employers in 22 states there are state specific, OSHA-approved health and safety guidelines in place that are equal to or even more stringent than federal guidelines.
California is one of these states, and if you operate a business there you’ll need to be extra vigilant when it comes to keeping employees safe work related safety risks. Cal/OSHA not only has stricter rules in place for workplace fall protection, but also additional safety regulations you must follow. For example, Cal/OSHA includes an Illness Prevention Program (IIPP) as well as a Heat Illness Prevention Program, which Federal OSHA does not. There are many other differences, and this article will review some of the most important ones.
To say that Cal/OSHA is stricter than Federal OSHA isn't the end of the story. To keep your California company compliant, you'll want to pay close attention to the differences in the two sets of regulations. Otherwise, you may face stiff fines and penalties. Most notably, you must realize that there are several distinct differences with regards to fall protection requirements.
A metal guardrail is among the most commonly used forms of indoor fall prevention and OSHA roof fall protection. Both OSHA 1910.29 and Cal/OSHA Title 8, 3209 standards set minimum requirements for guardrail systems. The distinct differences between the two include:
According to Federal OSHA standards for general industry, fall protection is required anytime employees are walking or working 4' above a lower level. Therefore, you must protect mezzanines, walkways, and other elevated working/walking surfaces with OSHA-compliant guardrail systems or the equivalent. In addition to indoor fall protection, you are also required to provide fall protection systems for roofs that employees work on.
To comply with Cal/OSHA regulations, you need to provide fall protection whenever employees are working 30" above the level below. When the surface is more than 6' over a space where employees normally work or travel, a toeboard is also required to protect against falling materials.
According to the Federal OSHA regulations in 1910.29, the top rails, or equivalent guardrail system members must be 42" (107 cm), plus or minus 3" (8 cm), above the walking/working surface. Cal/OSHA Title 8, 3209, on the other hand, states that the top rails of a metal guardrail can have a height from 42" to 45" from the surface below, with a permissible tolerance on height dimensions of one inch.
So, to meet OSHA standards, a guardrail can be between 39" and 45" tall, but Cal/OSHA only allows railings to be 41" to 46" tall. Therefore, if your OSHA roof fall protection metal guard rail is between 41" and 45" tall, you'll be compliant with both regulations.
Both Cal/OSHA and Federal OSHA state that a metal guardrail must be able to handle a force of 200 pounds applied in a downward or outward direction without failure. Cal/OSHA also includes a load regulation that states: "All guardrails and other permissible types, including their connections and anchorage, shall be designed for a live load of 20 pounds per linear foot applied either horizontally or vertically downward at the top rail."
It is important to understand that the 200-pound concentrated load is pretty simple to calculate. It literally refers to the force applied in one spot along the top rail. However, determining the live load is a bit more difficult and it requires the assistance of a qualified safety expert. Your qualified individual will be able to do calculations that involve the overall dimensions and layout of the railing to figure the strength required in order to ensure the railing is in compliance with Cal/OSHA standards.
It's imperative that you follow federal and state guidelines for providing a safe workplace. Determining which regulations to follow may seem like a tough choice, but it's actually quite easy. Keep in mind that state programs like Cal/OSHA must, at a minimum, meet Federal OSHA roof fall protection standards regarding fall protection systems for roofs. However, federal guidelines may not be adequate to meet Cal/OSHA standards. So, you should always follow the stricter of the two and you can rest assured that you're compliant for both.
To keep your employees safe and your company out of regulatory hot water, you need to install fall protection systems for roofs as well as indoor fall protection. While you are not required to use a specific type of fall protection equipment, like a metal guardrail or safety harness, lanyard and anchor combination, you do need to make sure that the equipment you use meets the state and federal guidelines. That's no easy task. And, if you get it wrong, someone could get hurt and your company will pay a steep price, both in lost production and regulatory fines.
In 2022 fall protection is even more important than ever, and you're obligated under federal and state law to minimize or eliminate fall hazards in your workplace. Don't leave anything to chance, make sure your facility is equipped with OSHA roof fall protection and Cal/OSHA compliant fall protection equipment. Not sure what kind of fall protection equipment you need? Concerned that your current metal guardrail system isn't up to par? Feel free to contact the fall protection specialists at Bluewater for a consultation with a qualified safety expert to discuss your fall protection needs as well as your compliance obligations.
