For construction work over or near waterways, OSHA 1926.106 requires employers to have a boat available on standby to ensure a timely rescue of a fallen worker. In fact, according to one OSHA letter of interpretation (LOI), the retrieval of an employee from the water is required no more than 3 to 4 minutes from the time they entered the water. And, depending on hazards present, it could be required even sooner.
Section 1926.106(d) states:
At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.
The intent of the regulation is to ensure prompt rescue of employees that fall into the water, regardless of other precautions taken. OSHA is clear that regardless of how foolproof your fall protection systems may be, they are not a substitute for the skiff.
An employer is also required to comply with all other applicable standards including, but not limited to, the requirements that an injured employee be treated by medical personnel or an employee certified in first aid within 3 to 4 minutes from the time the injury occurred. This could mean that first aid treatment would have to begin in the lifesaving skiff or boat.
As with other Roco services, our personnel are experienced emergency responders trained to provide lifesaving skills when it matters most. All Roco marine standby personnel are First Responder/ CPR/First Aid trained, and most are EMT’s. Our boats are fully equipped with First Aid kits, AEDs and O2 for prompt emergency care.
Resources: OSHA 1926.106 as well as Letters of Interpretation (LOI’s) dated 8/23/04; 12/5/03; 12/6/91; and 06/13/90.
NOTE: In this article, Roco cites OSHA 1926.106 which applies to construction activities while working over or near water. For other industries such as shipyard (Part 1915), marine terminals (Part 1917), or longshoring (Part 1918), please refer to those standards for specific requirements, particularly for personal flotations devices (PFDs) and rescue skiffs. OSHA does not require rescue skiffs for all industry activities. However, keep in mind, OSHA sets minimum standards. And, remember, there’s a safe way and a safer way!