A National Emphasis Program (NEP) does not change the regulations or expectations from OSHA when they visit but acknowledges that an increase in enforcement and outreach activities around a particular subject is warranted. 

Ultimately this program is intended to identify and reduce hazards that are causing, or are likely to cause, serious injuries and fatalities from falls while working at heights. In this case, despite OSHA’s outreach, enforcement, and compliance assistance efforts, fatalities caused by falls continue to be a leading cause of death for all workers. And the numbers in the United States outpace those of similar countries by a factor of at least three.

OSHA’s goal will be accomplished by a combination of enforcement, outreach to employers, and compliance assistance. One of the significant differences with the emphasis program is that OSHA compliance safety and health officers can now open inspections whenever they observe someone working at heights—not just when they observe violations. If a compliance officer determines an inspection is not necessary after entering a worksite and observing work activities, they will provide outreach on fall protection and leave the site. 

First, organizations need to recognize that OSHA officers can enter a site if anyone is working at height, so any work at elevation is subject to scrutiny. This could include work on the roof, which is historically where 20% of fall fatalities occur. To evaluate potential risks, now is a prudent time to solicit a third-party evaluation of operations from a skilled provider or fall protection expert. If you have any concern that your personnel training, assessments, documentation or procedures are lacking, strongly consider investing in these processes to ensure compliance.  

One of the keys OSHA looks for in any fall protection system is documentation that the system meets the required regulations- We regularly hear this from our clients and their representatives that are dealing directly with OSHA. Too often when we go visit a site, a system that was installed one, two or even five years ago doesn’t have any tangible documentation showing it meets the pertinent OSHA regulations or ANSI standards. Without this documentation, it is challenging for organizations to demonstrate compliance. 

Each state with a State Plan can choose to respond differently, so it’s important for organizations to confirm the specific impacts they may face. State Plans are required to have enforcement policies and procedures in place that are at least as effective as those in the NEP. State Plans have the option of adopting an identical or different program, but the program must be at least as effective as the NEP.

Absolutely not. While OSHA has different fall protection regulations for construction and general industry (and other industries), this program applies OSHA wide. In addition to construction, non-construction inspections may target roof top maintenance, road-sign maintenance, utility line work, billboards, power washing, window cleaning, and communication towers.

As part of our mission to reduce risk for workers at height, LJB regularly serves as a third-party auditor for risk assessments, continuous improvement programs, and OSHA citations. And, with our knowledge of regulations and standards and relationships throughout the industry, we know what you need to facilitate compliance and improve safety.

Our team of fall protection experts—including many dually certified professional engineers and certified safety professionals—can provide a wide variety of services to help you better understand your fall protection program and potential gaps:
− Training
− Risk Assessments
− Solution Design and Installation
− Certifications, Inspection and Re-Certifications
− Program Evaluations