I always train employees that they need to be tied off at least 18-1/2 feet from the next level to use a 6-foot shock absorbing lanyard.

Lanyard: 6 Foot
Deceleration Space (stretching of the lanyard): 3.5 Feet
Employee: 6 Foot
Safety Factor 3 Foot

Total: 18-1/2 Feet

Because of this most employees use a retractable lanyard which is like a seat belt and will lock up and arrest a fall in a shorter amount of space.

With all safety equipment it's important for it to be properly designed and PROPERLY inspected before EACH use. At work we use 50-foot retractable lanyards and I always get some eye rolling when I pull out all 50-feet of cable to demonstrate how to perform an inspection properly.

All fall arrest equipment I've come across has been a once and done type of deal. If an employee experiences a fall and shocks the equipment, the equipment is to be taken out of service and destroyed. All of the harnesses and lanyards we provide have an indicator that is exposed when the equipment has arrested a fall.

The anchoring points are either structural steel trusses or engineered anchoring points certified by a professional engineer.

It is also important to consider how a person will be retrieved if they experience a fall and are hanging in their harness. Will a ladder or a boom/scissors lift be able to retrieve an employee or will some other plan (outside help) need to be arranged?

As for the heights of which a fall arrest system is needed:

General Industry (29 CFR 1910.23): Over 4 Feet
Construction (29 CFR 1926.500): Over 6 Feet

And Railroads are under "General Industry" ?

That means pretty much any railroad shop would need a fall arrest system right?

Thought I would bump this up... are tourist railroads somehow exempt from this? Or are they just ignoring the laws?

For clarification, see the Applicability Section, 49 CFR Part 243.3:

https://www.ecfr.gov/cgi-bin/text-idx?S ... 9.4.243_13

So tourists railroads are exempt from OSHA? That doesn’t seem right.

Sorry, I misunderstood and thought you were referring to the FRA Part 243 requirements.

Yes, it is my understanding that tourist railroads (as applicable based on OSHA) would fall under the applicable OSHA standards for their employees. Fall protection would be included.

Sorry for the confusion....

Mike Ramsey

It's the law here in Ontario, Canada. If you are so many feet off the ground you have to wear a harness. Granted, this isn't always the case until they get caught.

I remember talking to a paramedic about falls, and he said a fall of just 20 feet is fatal half the time. Those that fall on their head and survive will likely end their working career, and have serious lifelong medical problems.

About 3 years ago I was a mechanic on the Alaska cruise trains. I was changing out some cracked windows on the roof of the dome cars which are 18 feet tall. Obviously there is no where to attach a cable to a harness to prevent a fall. But am I willing to risk injury or death for these windows? No way. I found the harness, inspected it, and then found someone to drive a cherry picker lift to where I was working. He placed the mast right over where we were working, shut off the engine, and we all attached our ropes.

It only took maybe 5 minutes to do all that. I have worked many dangerous jobs. I have been told by dozens of employer's "we can replace equipment, we can replace materials, we can not replace you". I once saw a guy get half his hand cut off not 3 feet from me from a large sheet metal sheer. He was making 12 dollars a hour and second day on the job. Ended up costing the company a fortune in hospital bills.

Your life is valuable, and your body is fragile. Be safe and come home the same condition you left. If a company is asking you to do unsafe work then I would refuse. If they fire you then call the department of labor and tell them the story. Had that happen to me once and the labor department gave me 9 months of unemployment benefits. I milked those benefits to the very end to stick it to that company.

Glad this got bumped back up, as it is a good reminder for all of us.

We do our best to follow OSHA regulations in our facility, although we have never actually had an onsite visit by an OSHA representative. We do have an internal Risk Auditor that visits once a year.

It's a legal/ insurance thing. Yes, I don't expect anyone from OSHA to come to our facility and write us a fine, the way FRA can do. But if we have an incident and it develops into an insurance claim or a lawsuit, and there is an investigation, and we weren't following guidelines.....

As for fall protection specifically, it doesn't make sense to strap on a harness and find a tie off just to take off a stack cover or open a turret valve. It takes longer and is probably more dangerous trying to find a tie off than it takes to do the job. Especially if the job is done outside where there is no easily available overhead cable to use. But if we are going to be in the air for a while, like setting safeties, inspecting a dynamo, filling the sand dome, we use harnesses and tie off to whatever is easily available on the equipment, such as lifting eyes or handrails. One of our previous risk managers wanted to attach 4 foot railings above the outside of the running boards to avoid using tie offs and still be covered. Might be OK for long periods of shop work, but I'd be embarrassed to run up and down the track that way.

We also have a confined space program, and boiler inspections and repairs walk a thin line of OSHA regulations between what is a permit and non-permit required confined space. I've had certain individuals tell me that we can't enter our own boiler, or the tender water tank, because it is a confined space and we don't have proper training or equipment for emergency rescue. So far I've been able to convince them otherwise by identifying the precautions that we DO take, such as constant air quality monitoring, safety harnesses for easy extraction, and hole watchers. I'm afraid that one day the wrong person with the right authority will tell us no more, and basically shut down the steam program.

Eric

If you're looking for some of the best fall protection training you can get, check out Gravitec near Seattle, WA

https://gravitec.com/



Inside the warehouse style building you'll find classrooms as well as a bunch of hands on climbing structures, sections of wind turbines, high tension towers, girders, oil rigs, containers and more.

Nobody's going to be sending all their volunteers to this, as it costs thousands. But if your facility requires somebody who's certified to implement the system and train the workers, their "train the trainer" programs are the best I've ever seen!

I have no affiliation with them, other than having been trained there myself.

Railroad employees are also exempt from Social Security. Does that seem right? (they have an alternate/predecessor system called Railroad Retirement).

The answer is that "Exempt" isn't quite exempt. FRA still regulates and inspects; but they only want to see that you have a practice, and the practice is reasonable for you, and non-insane.

What's that about? Remember when the Gettysburg engine blew up, 611 derailed in the Great Dismal Swamp, etc.? This caused heritage railways to get Congressional scrutiny. FRA was already giving a lot of slack to smaller heritage railways, on the logic that this was good public policy, because these small organizations' actual practices were mostly reasonable, and the statutory burden of full 49 CFR compliance would ruin them. Meanwhile, uncertainty about regulation was confusing everyone, and scaring the daylights out of tourist railways. Congress listened and agreed, and codified (made law) what FRA was already doing, in 49 USC 20103. As is typical, Congress didn't micro-manage this; it deferred the implementation to FRA.

FRA did public feedback, then stated their rationale inside 49 CFR 209 Appendix A. FRA exempts tourist railways from many picayune chapter-and-verse requirements, and allows them to use their own standard of practice that is reasonable for them.

How do they enforce "reasonable for you" if they've exempted the tourist railway from the regulations? FRA uses its Emergency Order authority, which encompasses and overrides all regulations, exempt or not. It goes like this. " You can't run the car with broken shards of glass all over. You are exempt from 49 CFR 223. You do not need to use 223 safety glazing. But this car will not be safe unless you replace all plain glass with some sort of safety glass like tempered or laminated. Sideline it now, or we will issue an Emergency Order."

And you bet your bippy you either fix the windows or sideline the car!

This "force of threat" is 100% effective. FRA issues less than one EO a year, and all of them involve outrageous misconduct and refusal to comply with warnings. I can't recall any being against a tourist railway.

So no, heritage operations are NOT truly untouched by FRA fall protection regs. It must have a practice in place, and that practice must be not unreasonable. It does not need to comply with the picayune letter of the regs.

This is good, because FRA's jurisdiction pre-empts OSHA. Enjoy FRA-Lite, and not having to put safety railings on heritage equipment.

If there was an accident, and the employee chose to involve osha, things would get messy would they not?

I’m personally at conflict, I love seeing the fireman climb up on the tender and refill the water from the water tower. But it’s a dangerous practice and doesn’t comply with OSHA which is why we see the operational water tower no longer used at Disneyland. Instead the firemen use a hose which they insert from a safety ladder on the outside of the locomotives.

At Disney world, they now open the tank with a hook and lower the water tower from the ground.

Would I prefer the historic way? Yes. But I also think safety is important and shouldn’t be ignored just because we can get away with it.

Amusement parks with or without railroads have to comply with OSHA regs. Even if the “railroad” fell under FRA lite, it’s not likely the park will roll the dice and exempt the railroad from OSHA. Better safe than sorry.

I’m just pointing out osha happy procedures... I think it’s best to be proactive about safety... but I suppose why this is why osha exists. Lots of people saying “we don’t have to worry about that, this is how it’s always been done.”

My understanding is that on railroads regulated by the FRA, OHSA has no jurisdiction over rolling stock and track, FRA does. Shops, structures and off-rail equipment, yes, but not equipment that runs on rails, or the rails themselves.

I recall hearing about an incident probably twenty five plus years ago where an over eager OSHA inspector stopped in at a Class 1 yard to do a surprise inspection, sited them for every rail in the yard being a tripping hazard, and demanded that the yard be closed until enough ballast could be brought in to fill in the entire yard to railhead level. Seemed like there was quite a bruhaha between the railroad's, OSHA's and FRA's lawyers as to who had jurisdiction where.

We were recently turned in to OSHA by a disgruntled ex-employee as retaliation for his being let go (OSHA gets a lot of those). One of the items on his list was confined space entry of boilers and tender tanks. When I replied that the equipment in question was on rails, and our employees follow the same procedures that the FRA inspectors do when they are visiting for an inspection, OSHA was satisfied with that answer.

The reality of the situation is that OSHA only has about 2,000 agents stretched across the entire country, and doesn't have the time to deal with much less than fairly major accidents. I suspect that they are quite happy to hand over jurisdiction to other agencies when they can.