How to Develop an Effective Fall Protection Program
6 min read This month at the National Safety Council 2019 Congress & Expo, OSHA announced that for the ninth consecutive year, Fall Protection – General Requirements, specifically 1926.501, is the most frequently cited standard. OSHA has a long history of focusing on fall protection issues and citing U.S. companies for violations. Employers bear a substantial amount of responsibility for providing and maintaining adequate fall protection for employees. It is also important to ensure trained and competent employees continuously inspect and monitor all fall protection and prevention equipment and systems before use. Effective Fall Protection Programs Fall protection includes a variety of different equipment and systems. For example, many companies employ fall protection measures like personal fall arrest (PFA) systems, guardrail systems, safety nets, positioning device systems, warning line systems and controlled access zones. When looking at the components of an effective fall protection system and program, consider these three factors: Thorough pre-work equipment inspections Detailed work area inspections Appropriate fall arrest/restraint systems Pre-work Equipment Inspections Before performing work involving significant heights, it is critical that trained personnel complete a thorough inspection of all fall protection equipment that will be in use. There are a few different regulations that can be referenced while developing pre-use inspection protocols for personal fall protection arrest equipment: ANSI/ASSE Z359.2* requires, among others, that fall protection equipment be inspected at the beginning of each 8-hour shift. OSHA 29 CFR 1910.140 requires that each inspection of fall protection equipment include inspections for mildew, wear and tear, deterioration and other defects that might affect critical functionality. Failure to inspect fall protection equipment properly can have dire consequences. In 2017, OSHA reported 366 deaths in the construction industry attributed to falls from elevated work areas. Furthermore, the Bureau of Labor Statistics (BLS) reported fatal falls in the private construction industry increased by 45% over the five-year period from 2011 to 2016. For many employees, adequate personal fall arrest systems are the last line of defense in preventing fatal falls. Any defects must be identified and corrected prior to an employee beginning work at elevation. *ANSI will periodically update these guidelines, and updated versions will typically be made available every three years. Work Area Inspections In addition to inspecting the fall prevention equipment itself, a thorough pre-work inspection must include consideration of the environment in which the work is being performed. When inspecting your work area for fall protection issues, some factors to consider include: Where is your anchor point? OSHA 1910.140(c)(4) and 1926.502(d)(15), for general industry and construction respectively, require an anchor point be strong enough to safely hold 5,000 pounds per attached employee. A reliable anchor point is typically at a point embedded into the structure where work is being performed, such as a steel component. Temporary or unstable materials, such as guardrails, scaffolding or light fixtures, should not be used as anchor points. “If you do not feel you can safely hang your work vehicle from the structure without collapse, it shouldn’t be your anchor point,” said Jerrod Temple, an ISN safety professional. What is below the elevated work area? In addition to finding a sturdy anchor point, it is necessary to determine what lies beneath the elevated work area should a fall occur. Care should be taken to identify the structures an employee could hit if swinging during a fall. Consideration should be taken to limit work or traffic under the elevated work area. What is the estimated free fall distance? The estimated free fall distance for an employee working at heights is crucial and needs to be calculated prior to work beginning. Once identified, ensure the anchor point is at a correct height and verify that the properly sized fall protection equipment is used for the affected employee. If the free fall distance of the available fall protection would exceed the fall distance, then a fall restraint system should be used over a fall arrest system. How to Calculate Free Fall DistanceThe factors considered when calculating total free fall distance include the length of the lanyard being used, the height of the anchor point, the distance that the employee would have to travel, the employee’s height, harness flex and incorporation of a safety factor (typically 2 feet). This number generally comes to approximately 18.5 feet, depending on equipment used and the personnel using it. It is best to engage competent fall protection experts when evaluating and prepping the workspace to incorporate fall protection considerations. A fall protection competent individual is defined by OSHA 1926.32(f) as, “…an individual who is capable of identifying existing and predictable hazards in the surrounding work conditions that are unsanitary, hazardous, or dangerous to employees, and who has the authorization to correct and eliminate these hazards.” Although employees at your company can become competent fall protection individuals through a mix of specific fall protection training and workplace experience, it is ultimately up to the employer to determine who is truly competent. Fall Arrest vs. Fall Restraint As previously mentioned, total free fall distance will determine if the individual working at heights may hit the ground if a fall occurs. When there is high risk for a fall, fall arrest equipment should be used. Fall arrest equipment is designed to slow the employee during a fall, limiting the impact incurred on the body. This equipment includes retractable lanyards, ladder safety systems and shock absorbing lanyards. If a fall does occur, the equipment used should be immediately inspected to determine if damage affected its integrity. Some equipment, such as lanyards with shock absorbing packs, will become ineffective after a fall and should be immediately destroyed. Fall harnesses and other equipment may also be designed to show impact; if a previous impact is identified or suspected upon inspection, this equipment should be immediately destroyed and discarded to prevent future use. Fall restraint systems are used to prevent a fall from occurring. Unlike fall arrest equipment, fall restraint is designed to prevent an employee from reaching the edge of a structure through rigid lanyards and work positioning devices. One of the most common examples of where fall restraint devices may be used is roof work where the anchor point is typically in the middle of the structure. Work positioners and rigid lanyards are designed to allow individuals to move freely across the structure while preventing them from reaching the leading edge. Suspension Trauma Even if all equipment functions as it should, when a fall occurs there are still serious dangers associated with suspension from safety equipment. Suspension trauma is a serious, life-threatening issue that must be addressed immediately. 29 CFR 1926.502 (d) (20) requires employers provide a “prompt rescue” for an employee that has experienced a fall and are unable to rescue themselves. Studies have shown victims of a fall can experience suspension trauma within as little as 10 minutes of a fall. Familiarize yourself with how suspension trauma can affect the body and consult medical professionals to help develop rescue procedures and post-rescue protocols. Emergency personnel and medical services should be consulted any time an individual has a fall from heights. A detailed medical consultation and/or investigation is necessary to determine the extent of the individual’s injuries. Be AwareIf you’re a contractor employee, ask your supervisor for a copy of your company’s fall protection written program. Stay up-to-date on the latest information available regarding preventing falls and requirements from your Hiring Clients. How ISN Can Help If you are a Hiring Client, ask your contact at ISN for information on the fall protection written program requirements. Our HSEQ Review and Verification Services (RAVS) team reviews contractors’ policies and training to help ensure they address necessary regulations. RAVS Plus Implementation Assessments take the initiative one step further, analyzing contractors’ policy implementation through interviewing employees and reviewing additional documentation, including evidence of fall protection training and equipment inspections. Are you a Hiring Client and interested to learn how ISN could help you manage your contractors and validate written programs like fall protection policies? Request a demo of our contractor management system, ISNetworld.