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OSHA’s Updated Interim Enforcement Response Plan (IERP): How it Affects Indoor Fall Protection & Warehouse Safety

OSHA's Updated Interim Enforcement Response Plan (IERP): How it Affects Indoor Fall Protection & Warehouse Safety

Workplace safety is the top priority for OSHA, and should be for managers and owners of industrial facilities as well. But sometimes efforts to protect workers need to be ramped up to meet a specific threat or challenge. Such was the case when the COVID-19 pandemic struck, which presented unique challenges to every sector and industry. Coping with the virus required regulators to enact National Emphasis Programs (NEPs) to address the hazards associated with the virus. As the pandemic evolved, so too did OSHA’s response and it issued an Updated Interim Enforcement Response Plan (IERP). But what does that mean for you?

Novel Workplace Hazards and OSHA Regulations

Regardless of what industry you work in, protecting employees from exposure to known hazards is your legal obligation. When something like COVID-19 happens, it can create a great deal of confusion that can lead to harm to employees and potential OSHA violations. That’s why OSHA acts quickly to address new hazards and to set forth standards for mitigation.

On March 12, 2021, OSHA developed and implemented a National Emphasis Program (NEP) for COVID-19, DIR 2021-01 (CPL-03). The intention of this program was to protect healthcare workers from being exposed to COVID-19 in the workplace. On July 7, 2021, OSHA released an Updated Interim Enforcement Response Plan (IERP) to address the pandemic and how it relates to industrial industries, replacing the NEP from March 12. This plan details an employer’s responsibility to provide respiratory equipment and other protections for workers.

OSHA Has Authority to Fine Your Company

Imagine, if you will, that OSHA is informed of a potential violation of the IERP regarding COVID-19 safety precautions. Anytime OSHA is called in for COVID-related issues, it will likely trigger a surprise inspection of your facility. If you’re not providing adequate protection such as posted warehouse safety rules, personal protective equipment (PPE) and social distancing, you may face a fine for being out of compliance, but that may just be the beginning. You may also have to shut down or delay your daily operations until you are in compliance.

How COVID-19 May Expose Other Workplace Hazards

While it’s certainly nerve-wracking to learn and implement all of the new warehouse safety standards with regards to COVID-19, that’s hardly all you need to worry about. The NEP mandates that 5% of each OSHA region’s total inspections must be related to COVID-19, resulting in an estimated 1,600 additional inspections. Remember that if an OSHA inspector shows up at your facility for a COVID-related issue, they may observe and cite any non-COVID compliance issues as well. So, how do you avoid issues with OSHA? By making sure your entire facility is compliant.

OSHA Fall Protection Requirements

While COVID-19 is certainly worrisome, the hazard that puts employees at the most risk is height. Anytime workers are performing their duties 4′ above the level below, you need to provide adequate fall protection. A fall protection system may include any combination of the following:

  • Guardrails
  • Indoor Safety Gates
  • Warning Lines
  • Harnesses
  • Lanyards
  • Lifelines
  • Anchor Points

Choosing OSHA-Compliant Fall Protection for Your Warehouse Facility

According to OSHA 1910.28, it is your duty to provide fall protection and falling object protection for your warehouse employees. What OSHA doesn’t do is tell you what fall protection systems you must use for any specific hazard. That is something you have to figure out yourself. Some things to consider include:

Guardrail Systems & Safety Gates

Guardrails are the most popular form of fall protection for industrial facility settings and warehouse safety. They are versatile, durable, and don’t require active use by employees. A guardrail system and indoor safety gates will provide adequate fall protection on elevated surfaces, walkways, and rooftops while also guarding dangerous machinery.

Personal Fall Protection

In some cases, a guardrail system is not feasible, such as on sloped roofs or on elevated surfaces inside the warehouse with limited space. When this is the case, personal fall protection devices like a safety harness, lanyard, and lifeline must be employed to keep workers from falling.

Machine Protection

If workers must traverse the areas near or above dangerous warehouse machinery and equipment, fall protection is essential. A safety railing with a toe board combined with indoor safety gates helps keep everyone safe. In addition, a guardrail and safety gate around the perimeter of machinery limits access, protecting workers and the machine.

Roof Openings and Roof Holes

On occasion, it’s going to be necessary for someone to get up on your warehouse roof to make repairs, perform maintenance, or to service the equipment up there. Roof openings like skylights, roof hatches, and holes in the roof membrane need to be protected with a guardrail or other fall protection systems to keep workers safe.

Evaluate Your Fall Protection Systems Today

Remember that if OSHA inspectors come into your warehouse and notice violations, you’re going to suffer the consequences. Rather than being caught off guard by a surprise OSHA inspection for COVID-19 that turns into a full-blown warehouse safety inspection, be prepared. Take the time to walk through your facility with a qualified safety expert to evaluate your current fall protection systems. If they do not meet the current OSHA guidelines, you need to act quickly to remedy the situation to avoid OSHA fines and penalties.

OSHA-Compliant Fall Protection Systems You Can Rely On

For the last couple of years, protecting your warehouse employees from exposure to the COVID-19 virus has been a top priority. But you can’t focus solely on the virus. You need to make sure you protect workers from all workplace hazards, especially fall protection.

If you’re worried that OSHA inspectors may find fall protection violations in your warehouse facility, it’s time to act. Contact us at Fabenco to discuss your fall protection needs. Our safety experts will be happy to help you determine whether you need a guardrail system and safety gate, personal fall protection devices, or a combination. All of our fall protection equipment is 100% OSHA-compliant, so you can rest easy knowing your employees are safe and you won’t be fined.