NIOSH Testimony on Safety Standards for Fall Protection in the Construction Industry by R. A. Lemen, February 25, 1987.
This testimony comments on the OSHA proposed revisions to Subpart M, Fall Protection. Specifically the comments concern the definition of leading edges to mean the edge of a floor, roof, or form work which changes location as additional floor, roof or form work sections are placed, formed, or constructed. It is not clear whether this definition applied to both the temporary and permanent components of floor decking during its installation in multi floor buildings. A second comment concerns the requirements to have fall protection, and stresses that required protection only for those operations 16 feet or more above lower levels is inadequate for worker safety. NIOSH suggests that OSHA state that the first worker allowed on the roof or leading edge is designated as the competent person under the requirements of the safety monitoring system, if that is indeed the intent of OSHA. Additional concerns are voiced with regard to wall openings, safety nets, belt and harness systems, securing of positioning devices, and safety monitoring systems.