When Does OSHA's 1910.66(f)(5)(v)(D) Fall Short in Airports?

OSHA's 1910.66(f)(5)(v)(D) regulation specifically addresses the safety requirements for intermittently stabilized platforms, such as building face rollers. However, the unique operational environment of airports can present scenarios where this regulation might not fully apply or may fall short in ensuring safety.

Unique Challenges in Airports

Airports are dynamic environments with high stakes for safety. The regulation 1910.66(f)(5)(v)(D) primarily focuses on construction and maintenance work on building exteriors. At airports, however, the activities often involve working around active aircraft, high-speed vehicles, and sensitive electronic equipment. These factors can complicate the application of this regulation.

Limitations of 1910.66(f)(5)(v)(D)

While 1910.66(f)(5)(v)(D) mandates the use of intermittently stabilized platforms for certain conditions, it may not cover:

• Proximity to Aircraft Operations: The regulation does not account for the additional hazards posed by aircraft movements, such as jet blast or the risk of collision.
• Electromagnetic Interference: Airports have extensive electronic systems that could interfere with the operation of the platforms, a concern not addressed by the regulation.
• High Traffic Areas: The regulation does not specifically address the need for additional safety measures in high-traffic areas, which are common at airports.

Real-World Application and Scenarios

In my experience working with various airport facilities, I've seen firsthand how the regulation's limitations can impact safety protocols. For instance, during a routine maintenance project on an airport terminal, the use of building face rollers near an active runway required additional safety measures beyond what 1910.66(f)(5)(v)(D) prescribes. We had to implement specialized traffic control and communication systems to ensure the safety of both the workers and the aircraft operations.

Supplementing with Additional Safety Measures

To address these gaps, organizations at airports need to go beyond the requirements of 1910.66(f)(5)(v)(D). This can include:

• Implementing a comprehensive risk assessment specific to airport operations.
• Developing tailored safety protocols that consider aircraft movement and electronic interference.
• Using additional safety equipment, such as high-visibility vests and enhanced communication devices.

By understanding the limitations of 1910.66(f)(5)(v)(D) and taking proactive steps, airports can maintain a high level of safety that aligns with their unique operational needs. Based on available research, individual results may vary, but the importance of customized safety measures cannot be overstated.