OSHA requirements for fall protection and U.S. Coast Guard-approved life jackets and buoyant work vests during construction activities over water.
● When working above water, employers must provide fall protection if the distance from the walking/working surface to the water’s surface is 6 feet (1.8 meters) or more.
29 CFR 1926.501(b)(1) states that “each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 meters) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.” The preamble to the standard states the term “lower level surface” includes liquids, so employers must provide fall protection during construction activities when employees are working 6 feet or more above the water.
● When fall protection is provided on walking/working surfaces located above water, and no drowning hazard exists, employees do not need to wear U.S. Coast Guard-approved life jackets or buoyant work vests.
Section 1926.106(a) states that “employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jacket or buoyant work vests.” In general, when continuous fall protection is used—without exception—to prevent employees from falling into the water, the employer has effectively removed the drowning hazard, and life jackets or buoyant work vest are not needed. But read the next item regarding the use of nets!
● When using safety nets as fall protection, U.S. Coast Guard-approved life jacket or buoyant work vests are usually required.
The use of safety nets as fall protection during marine construction activities usually will not eliminate the drowning hazard. In many cases (such as in bridge construction) there is a risk that materials heavy enough to damage the nets may fall. In such cases, using personal flotation devices and the other applicable requirements of §1926.106 apply. Also, the §1926.106 requirements apply during the installation of the nets.
● The use fall protection that eliminates drowning hazards does not relieve employers from having to provide ring buoys and a lifesaving skiff under §1926.106(c) and (d).
The requirements in §1926.106(c) and (d) for ring buoys and a skiff address the hazard of falls that may occur in the event of a failure of the operation of fall protection devices or a lapse in their use. Therefore, ring buoys and a skiff must be provided irrespective of the fall protection provided on the marine construction site.
