Hi
I am seeking guidance from someone who is an authority on this issue (not just opinions. I have those...) Anyway, what is the applicability of OSHA to existing buildings that aren't marine or factory occupancies? The OSHA text for buildings outside of these two is sufficiently vague to imply inclusion of all buildings, but was that the intent?
I work for Northwestern University, and we are evaluating ALL our existing buildings for OSHA compliance. This has been triggered by an OSHA fine that we received. The Facilities Management group is unclear as to its applicability to, say, a classroom building, an office building, a research lab or a performance hall. Our Risk Management group is advising that the OSHA requirements apply
anywhere that there is an employee. In some cases, this is contrary to IBC. And there are historic building implications,i.e a beautiful wood stair railing may be short by several inches for current OSHA compliance, but was within code at that time of construction. Coming up with safe installations and maintaining architectural integrity is sometimes a challenge. For buildings with no OSHA compliant roof parapet, fall protection must be installed to access anything within 15 feet of the perimeter. This means retrofitting guard rails or a fall arrest system with anchors to structure. Guardrails may be aesthetically undesirable. Anchor systems require ongoing visual inspections and testing, which burdens our Operations teams.
Further, most design teams ( A or E) don't even know that there are OSHA requirements that an Owner needs to address. It needs to be included in a design just like compliance with any other code or ordinance. There are real consequences for non-compliance that range from fines to death. I recommend that all design personnel take an 8 hour OSHA class to learn about conditions that require physical permanent solutions (a self-closing gate at the top of an access ladder, for example) in a building for the life safety of the employees.
To compound things, just like the AHJ, compliance may be at the discretion of the OSHA inspector that day...
Is there an initiative to get OSHA and IBC to look at the places where they intersect and resolve differences or support the life safety of workers?
If you are able to address either of these two questions from an authoritative position (working on a committee already addressing this?) please share your expertise.
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Deborah Burkhart AIA
Project Manager
Northwestern University
Chicago IL
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