1. Fall Protection: there were many questions on this topic due to the recent changes by OSHA. One contractor asked what am I required to do to comply with fall protection? Others asked do I really have to wear harnesses on low sloped roofs? What is the height requirement? Leona explained that the old fall protection standard is rescinded and has been replaced with a the new one in June of 2011 effective as of 9/16/2011. She stated that the top cited violations are from fall protection, ladders, scaffolding and lack of fall protection training. He said contractors have a duty to provide fall protection training and equipment for their workers. She also said the general contractor must make sure their subs are compliant as well.

Ms. May went on to explain that there are many injuries and deaths from falls. She showed us several examples where men were killed from falls as little as 8 feet! Ms. May explained to contractors that they are required to comply with the new fall protection standards on residential jobs where workers work 6' above lower levels. She explained contractors must have a written fall protection plan and use fall arrest systems, guard rails and/or safety nets. Contractors are required by OSHA to train their workers on the fall protection standards and then document that they were trained. She showed several examples of inspections conducted and enforced.

2. Safety Manuals: There were several questions about the requirement for a residential contractor have to have a safety manual? Does the manual have to be on site or in the truck or can it be at the office? What needs to be in the manual?

Ms. May explained that all contractors are required to have a safety program and manual. She said it should be on site for workers to reference. She also said one of the most frequent violations is the failure to have a safety training program backed up with documentation that you trained your workers on OSHA Standards. She also cautioned contractors that they must be careful when using a template. The manual must be relevant to the hazards presented by the contractor's type of work and hazards. There are several standards that must be in the safety manual; fall protection written plan, hazardous communication written plan, for RRP work medical monitoring and respiratory written plans and more.

3. Enforcement Initiatives for Region 1: The following questions were asked. How many enforcement officers are there in our area? Why is OSHA focusing on residential contractors? Why are the fines so big? What kind of cars do OSHA officers drive? How often do they make their rounds? What are they looking for when they come on site?

Ms. May said there are approximately 80 officers in New England. They make there rounds randomly and without warning. They drive cars like the Ford Focus or other basic vehicles. When a compliance officer drives by a site he, or she, is looking for an obvious violation. If they see something they are instructed to stop and investigate. Ms. May said if there is nothing obviously wrong he cannot stop by. He said OSHA officers need a reason (probable cause) to come on the job. She said if it looks like you are following the rules the compliance officer will keep on driving. If guys are up on a roof without fall protection he or she is instructed to go onto the job site.

OSHA Local Emphasis Programs: Ms. May said Region 1 OSHA officers have been instructed to focus on residential construction job sites. There are two local directives in Region 1; Fall Protection and Residential Construction. Essentially in Region 1 the residential construction industry is under a specific enforcement focus until the end of 2012. Our industry is also known as a targeted industry. Due to the high injury and death rate in residential construction in New England OSHA will be focusing on residential contractors until the rates come down.

Ring's End and the Home Builders Association will continue to host these round table discussions through the winter season. We would encourage you to consider attending one of these sessions. The next discussion will take place on December 13th, 2011. If you would like to reserve a seat please sign up here: OSHA Fall Protection Discussion or call the Home Builders Association at 203-335-7008.

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