OSHA Fall Protection, Fall Protection Systems, Fall Arrest System, Fall Protection Equipment

Fall Protection and OSHA

We are often asked “What are the OSHA rules for fall protection when operators are on top of trucks or rail cars while loading or unloading the vehicles?”

There are three answers. The first answer is OSHA regulations pertaining to the “general duty clause”. This broad statement says a plant site must maintain a “safe” work environment. If a worker is injured due to a fall from the top of a truck or rail car, obviously the work environment is not safe. There is no escape from this general clause. If a worker gets hurt, the environment is not safe and the plant site is going to be held responsible.

Good Faith Effort

The second answer is there are no specific OSHA regulations that pertain directly to operators working on top of trucks or rail cars. One interpretation of the rules says the top of a truck or rail car is the same as any other work platform. There are specific regulations concerning handrails on platforms. The problem with this interpretation is the complexity of trucks and rail cars in a loading or unloading station. Trucks and rail cars vary greatly with no way to predict just what vehicle configuration is going to show up at any time. Another variation is the exact spot of the vehicle. These variables make it virtually impossible to meet exact toe board, mid rail and top rail specifications. In every case known to us, the spirit of the rules allow for these variables. If the plant site has taken reasonable measures to provide adequate fall protection, there is no issue.

Industry Standards

Nearly every loading or unloading station has been provided with fall protection. This has established an industry standard that fall protection is required. If a plant site decides not to install fall protection for workers on top of trucks or rail cars, that decision comes with a risk. It is not if a fall will occur, the question is when and how seriously the worker will be injured. Deaths from these falls do occur.

The hazard is compounded by the nature of the work on top of trucks and rail cars. Often the worker must handle equipment and hazardous chemicals. The walk surface on top of these vehicles is also full of trip hazards that can cause a fall. Since industry has established the need for fall protection, any location that does not provide for safety is subject to serious trouble.

Solution

The only real solution is to take advantage of the experience of Safe Rack field representatives. These problems have been solved by Safe Rack people who have actually stood on top of these vehicles.

Safe Rack equipment complies with all OSHA guidelines as we understand them.