Comment from Kramer, Thomas; LJB Engineering
LJB EngineeringSupportBusiness
Summary: LJB Engineering, an engineering firm specializing in worker safety, supports the proposed regulations but advocates for specific technical refinements. They argue for stricter oversight by "Qualified Persons," suggest a 30-foot height threshold for consistency, and emphasize that implementation should be based on risk assessments rather than just a mandated timeline.
Thank you for the opportunity to provide these comments on such an important issue. LJB Engineering has dedicated over 35 years to protecting workers at height and has incorporated many best practices and lessons learned from a variety of public and private clients in the preparation of this document. We also want to thank the administration for allowing OSHA staff to participate in the discourse of this industry. We have met many and they serve the industry well.
As requested, we have provided comments, data and information as summarized below per your numbered items. Please let us know what we can clarify.
Attachments
- Comments from Thomas Kramer, LJB Engineering (PDF)
- Attachment 1 - 2021 NATE SEMC Wire Rope Safety Sleeve Testing Report II (PDF)
- Attachment 2 - UK HSE Research Report 258: Preliminary Investigation into the Fall-Arresting Effectiveness of Ladder Safety Hoops
- Attachment 3 - UK HSE Research Report 657: Investigation into the Fall-Arresting Effectiveness of Ladder Safety Hoops, When Used in Conjunction with Various Fall-Arrest Systems
- Attachment 4 - Heightec Report on Hooped Ladders: Hooped Ladders (aka 'caged' ladders) Briefing Note to Assist Those Undertaking Risk Assessment (PDF)