Is fall protection required during inspection, investigation and assessment activities?
The 1926.500(a)(l) provides an exception to subpart M which does not apply when employees are making an inspection investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed. The exception was set forth before the actual work begins or after the work has been completed for exposure to fall hazards for very short durations, since they most likely would be able to accomplish their work without going near the danger zone. In an ideal situation, inspections would only be visual, but 1926.500(a)(l) does not prohibit inspectors from using tools to perform tasks like opening covers, and making measurements needed to complete inspections.
Inspectors must maintain their balance, only use hand tools to manipulate materials, and perform these tasks cautiously while at or leaning over the unprotected edge. When work activities where tools are used in a potentially distracting manner, in close proximity of the fall hazard, the fall protection exemption would not apply, and would be a requirement during inspection activities.
If you have any questions contact Phil Mercuris, Vice President of Safety Services at Master Builders of Iowa 515-250-7001 or pmercuris@mbionline.com.
