The California Framing Contractors Association (CFCA) was first founded in 2001 as Cal/OSHA was issuing citations throughout California for fall protection violations or perceived violations for lack of fall protection for heights above 7½ feet. Framing company owners throughout California banded together to form the Association to understand and work with Cal/OSHA to establish guidelines and regulatory language that met the wants of Cal/OSHA while meeting realistic and practical field applications for protection against falls by workers.
Through the efforts of the CFCA and other trade associations and labor, we were able to form a coalition of employers and employees to arrive at the existing Fall Protection Standard, 1716.2 and establish a collaborative working relationship with the executives of Cal/OSHA.
• We avoided the proposed 7½-feet trigger height for fall protection.
• Single-story vs. two-story—With the 15-foot trigger height, most single-story homes can be built without conventional fall protection.
• Gable end exception—Installing gable ends without the use of conventional fall protection.
• No site specific plan required—Specific site plans were initially proposed, along with limited methods of fall protection Cal/OSHA would accept.
• Methods of fall protection beyond scaffold only.
• Over 50 meetings occurred, with over 15 days of meetings in Sacramento, and at least 1,000 hours of drafting, conference calls, and negotiating was spent by the CFCA Board and Legal Counsel.
• Our picture book on Fall Protection is still used as the #1 training reference for Cal/OSHA Inspectors.
Shortly after the Fall Protection Standard was adopted, Cal/OSHA contacted us to work with them on establishing guidelines and a standard for injuries from Pneumatic Nailers. The CFCA took on the challenge and developed a regulation that reflected the best safe practices from the industry based on its comprehensive, quantitative study on the causes of injury and the severity of injuries from pneumatic nailers.
Over 3 years of time spent to establish the standard:
• Eliminated ALL citations related to “unattended nailers.”
• Avoided brand and model specific training.
• Avoided unorthodox methods that varied from the industry safety standards.
• Avoided a requirement for using different nailers for sequential and non-sequential for specific tasks.
• Developed and lead Cal/OSHA statewide task force.
• CFCA funded comprehensive nail gun study, where we hired an Epidemiologist to analyze the data and found the TRUE cause of most accidents.
Heat Illness Prevention legislation was introduced by large Labor groups requiring onerous requirements for heat illness prevention for all outdoor workplaces. The initial legislation drafted proposed:
• Documenting hourly temperatures at varying locations on the job sites.
• Mandatory rest breaks each hour.
• Enough shade to cover 100% of the employees at any given time.
• Acclimatization period requirements–gradual work time for employees for two weeks.
• Start of work shift, water requirements of one quart per hour for each employee (200 gallons of water at start of work for 100 employees).
At the end of the day, we worked hard with the coalition group and the Governor’s office to develop a Heat Illness Regulation that provided a safe workplace with reasonable compliance standards instead of the onerous requirements outlined in the proposed legislation.
• In 2010, met with Governor’s office six times (total trips to Sacramento/San Diego/Fresno/ Oakland/ Los Angeles exceeded 50 trips).
• In addition, over 1,000 hours of calls, drafting, and negotiating.
• Testified before the Senate Labor Committee – Twice!!!
Additional regulations CFCA participated in included design load, silica dust, definition of serious injury, scaffold plank requirements, forklifts, rope grabs, design load, and Cal Green. In each of these items we avoided extremely cumbersome or arbitrary regulatory language or requirements that would not necessarily lead to better worker safety.
• Would have required engineering specs prior to loading joists, trusses, plywood, or even a box of nails.
• Estimated saving of $450 of additional engineering costs per type of unit.
• Initial proposal included wet cutting of siding or respirators program with annual medical fit test.
• Negotiated complete exemption for framers cutting siding.
Classification of Serious Citations and Serious Harm Definition – AB 2724
• Originally Proposed Definition of Serious Harm: “Could reasonably lead to impairment of a part of the body by substantially reducing its efficiency on or off the job for more than 24 hours.”
• Final Definition of Serious Harm: “Impairment…permanently and significantly reduced efficiency…”
• Eliminated the assumption that the accident occurred.
• Affirmative Defense for employers who take “reasonable and responsible” steps to prevent accidents.
• We were one of three people at the table representing employers in California.
• Not responsible for how planks are manufactured.
• Cumbersome requirements for lifting employees in man basket.
• Avoided arbitrary elimination.
• Developed best practices for use of rope crabs.
• No specific requirement for us to meter moisture content in lumber.
• No requirement to cover lumber stored on site.
• Assisted in drafting framing specific revisions to the Q&A contained in the HCD Guide Book
The CFCA Safety Committee and the CFCA Employment Committee have each worked to populate the CFCA website library with training materials, guidelines, and forms for member compliance on safety and labor/employment specific to our industry. Our members find these resources invaluable for their internal safety and human resource professionals.
Contact Jodi Blom, CFCA Executive Director, at (408) 505-8373 or firstname.lastname@example.org.