Falls are an ongoing workplace safety issue, and violations of general fall protection requirements regularly land at the top of OSHA’s annual Top 10 list of most-frequently cited standards. Though falls can occur nearly anywhere—including on flat surfaces—a subsection of falls requires specific safety rules and special equipment. That subsection is for falls from a leading edge.
When the Occupational Safety and Health Administration’s final rule on fall protection went into effect in 2017, among the updates was a clarification on when fall protection systems are needed around leading edges: If there is 6 feet or less from the leading edge, a conventional fall protection system (such as a guardrail system, a personal fall arrest system or a safety net) must be used, says Leading Edge Safety. If the distance is between 6 and 15 feet from a leading edge, a designated area for temporary work is required, with a warning line that must be placed at 6 feet. But what’s a leading edge?
What’s a Leading Edge?
In the Safety and Health Regulations for Construction, CFR 1926 Subpart R, OSHA defines a leading edge as “the unprotected side and edge of a floor, roof, or formwork for a floor or other walking/working surface (such as deck) which changes location as additional floor, roof, decking or formwork sections are placed, formed or constructed.”
The standard A10.32-2012 by the American National Standards Institute similarly defines a leading edge as “the unprotected side or edge during periods when it is actively or continuously under construction.”
“OSHA has their own definition, but from my experience and what I have seen out in the field, a leading edge application would be anytime there is potential for the connecting device to come in contact with an edge—be it a lifeline, a self-retracting lifeline or a lanyard, it’s ‘leading edge’ to me,” says Leah Shook, product marketing manager at Honeywell Safety Products in an interview with Better MRO. But there are other potentially dangerous nuances between the OSHA definition and what is experienced in the real world.
“It can also be where you are tying off below a D-ring, and you do not have an overhead anchor point, so you have to tie off at foot level,” she says. “I would say 90 percent of the time there is the potential for that lifeline to come in contact with an edge.”
Shook says that it does not happen every single time, but there is a very high probability of issues with the leading edge when not using correctly rated lifelines and connecting devices. Many of the products that are rated for the leading edge in fall protection are made to adhere to ANSI standards, as they are more precise in their safety specifications. OSHA will often look to see if companies are using ANSI’s leading edge standards for PPE, and customers will often request that the products companies use comply with ANSI, says Shook.
Need a better understanding of the different standards? Read “OSHA Vs. ANSI: How to Up Your Safety Compliance Game.”
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I was recently audited by my corporate office and they are telling me I need to guardrail my entire roof. I do not see that standard. Please help. They state that the flag system can’t be used any longer.
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