Best Practices in Fall Protection
d..This article is posted with permission from Bay Publishing (www.bay-publishing.com).
The highest level of fall protection for both employer and employees
By Kevin Denis
One of the best fall protection practices an employer can do is to develop a formal managed fall protection program. Adhering to minimum OSHA requirements is beneficial, but consistency suffers and OSHA regulations simply cannot address specific fall protection issues that every employer has.
Developing a fall protection program can be a daunting task, since it is most often developed retrospectively when personnel have been working at height for years without the benefit of a formal fall protection program.
Every employer that has fall hazards present at the workplace usually has a policy already in place. Most programs involve issuing personal fall protection equipment to each worker and providing some level of training so workers can solve fall hazards as they are encountered.
Best practices dictate that employers do more than procure personal protective equipment (PPE) and provide training. Simply issuing fall protection PPE for either a fall arrest or fall restraint system may not be the best solution to address a fall hazard. The best solution may be elimination or substitution of the task where fall protection is required.
The use of passive fall protection systems like guardrails or covers, for example, may also provide a more appropriate solution.
The following key elements are described in ANSI/ASSE Z359.2-2007 (Minimum Requirements for a Comprehensive Managed Fall Protection Program). This standard, and the process it prescribes, can be applied to any fall hazard in any industry. It is a methodical and logical approach to identifying fall hazards, creating solutions and developing a program.
Commitment from Management and Policy
Resources are required to develop the fall protection program. Management must be aware of the fall hazards their employees encounter during the course of their workday so management can provide guidance and resources to address said hazards.
Development and Education of Key Personnel
Regardless of the employer’s size, key personnel must be identified to manage the fall protection program. Larger employers often develop a steering committee that is made up of a cross section of workers. Smaller employers may only have one or two key people. Either way, this group is charged with the success of the program, including identifying and categorizing fall hazards, determining solutions, writing procedures and developing training programs.
Fall Hazard Assessment
An assessment of individual fall hazards provides an invaluable amount of information. All too often, the fall hazard assessment considers the height of a fall and/or a legislated duty to provide fall protection. Limiting the assessment to these two factors rarely provides enough information to develop adequate solutions. The frequency of the task, duration of task, similar work areas, area obstructions, environmental conditions and the reason for the exposure should also be investigated. The most feasible solution is easily recognized when good information is gathered.
Hierarchy of Fall Protection
After the assessment, fall protection solutions can be identified and developed based on the employer’s policies and budget. The program administrator or steering committee can use the Hierarchy of Fall Protection to address specific hazards (or groups of hazards).
The Hierarchy of Fall Protection is the preferred order of control to eliminate or reduce fall hazards. This methodology mirrors common safety practices for hazard abatement beginning with elimination and ending with administrative controls. Using the data collected from the fall hazard assessments, each solution in the hierarchy can be applied to each hazard.
The preferred solution to all fall hazards is elimination. The reason for exposure to the fall hazard is challenged and evaluated to determine if a change in the procedure, practice, location or equipment will eliminate exposure to the fall hazard. Specifying that HVAC (Heating, Venting and Air Conditioning) equipment be located on the ground or in an equipment room rather than by the edge of the roof is an example of hazard elimination.
Using passive methods of fall protection is the next best solution. Physical barriers like guardrails around unprotected edges and covers over holes are examples of passive fall protection.
There are many situations where an employer didn’t consider guardrails around the perimeter of a building because of initial higher capital costs. Yet, it’s possible that the cost of the PPE is higher in the long run. PPE requires worker training, inspection and replacement, along with the identification of (or lack of) anchorages.
Rescue planning must also be included. Passive protection is generally considered to provide a higher level of safety since the opportunity for error is less than using PPE to accomplish the work. However, passive protection may not be warranted if the frequency and duration of exposure to the fall hazard is limited.
An exhaustive hazard assessment provides the information needed to make these kinds of decisions to maximize cost-effectiveness.
Fall restraint is the next method of fall protection in the hierarchy of controls. Fall restraint systems are erected in such a manner that a fall cannot occur. Fall restraint systems use personal protective equipment to restrict the workers’ range of movement so they cannot physically travel to the fall hazard.
Fall restraint systems are often underutilized because they are not specifically mentioned in many regulations, but they are preferred over fall arrest systems. Free fall distance is not an issue for fall restraint systems, therefore arresting forces, clearance requirements, secondary injuries, and rescue issues are virtually eliminated.
If fall restraint is infeasible, fall arrest is the next preferred method of fall protection. Fall arrest systems are erected in such a manner that a fall can occur but the fall is arrested within acceptable force and clearance margins.
Fall arrest systems have a higher risk associated with them, since we have to stop the falling worker within an acceptable level of force and prevent him/her from contacting the surrounding structure (or the ground).
Training for both fall restraint and fall arrest systems is key and it’s important for workers to understand the difference and how to assemble the systems.
ANSI Z359.2-2007 includes a significant amount of information about fall protection training for authorized persons, competent persons, qualified persons, rescuers and trainers.
The last control method in the Hierarchy is implementation of administrative controls. Administrative controls are work practices or procedures that increase a worker’s awareness of a fall hazard. It must be noted that administrative controls are the least preferred method of protection because they do not provide a physical or positive means of protection.
Administrative controls are preventive measures taken to reduce the likelihood of a fall. These methods include safety monitors, warning lines, warning horns, designated areas, or control lines. It must also be noted that OSHA regulates the use of many administrative controls and it is incumbent on the fall protection program administrator to understand the jurisdictions and regulations that apply.
Fall Protection Training
The ANSI Z359 Fall Protection Code is one of the best resources for employers. Section 3.3.4 of ANSI/ASSE Z359.2 (Minimum Requirements for a Managed Fall Protection Program) includes guidance for employers on how to conduct training.
There are several other considerations for training that have not been discussed here that are detailed in this document. The requirements included in the ANSI Z359 Fall Protection Code can be applied to your internal training program, or used as a measuring stick for outside training sources. Either way, it will help employers take the steps toward a more effective fall protection program.
Fall protection and rescue training is conducted for two fundamental reasons: protection of the worker and protection of the company. To adequately protect the worker, training must be thorough, include effective materials, allow adequate time, be conducted by qualified staff or a training company, and include observations of performance. To protect the company, fall protection training must include the same elements. This results in training that protects everyone by educating the worker at height and acting as an insurance policy to stand up to the test of litigation.
One of the questions most frequently asked is: “What kind of training do I need in regards to fall protection?” Although it seems like a straightforward question, the answer can be a little tricky. Unfortunately, many people believe that the singular training requirement is completion of a fall protection course, but it’s just not that simple.
Gravitec Systems believes that the key person in a fall protection program is the ‘Competent Person’. A Competent Person is defined as: “One who is capable of identifying existing and predictable conditions in the surroundings and work areas which are unsanitary, hazardous or dangerous, and who has authorization to take prompt corrective action.”
The definition is a little nebulous, but it does provide the two key expectations for a Competent Person: the ability to predict local hazards and the authority to make changes.
To satisfy these criteria, it is imperative that the workers’ skills and knowledge are evaluated to determine the appropriate training they require to complete the scope of work expected by their employer.
Employers must also examine their organizational structure to allow a Competent Person to exercise the authority to make changes. Only after these elements have been considered and Competent People identified, should training be evaluated and selected.
There are dozens of ways to conduct training. Before investing or creating a training program, employers should understand what they are getting so their needs are met. The end result of effective training is workers who can control fall hazards at the local level, resulting in a higher level of safety and compliance. Training should focus on this end goal. Having a certificate is not enough if the training does not accomplish these goals.
Training should include several key elements to get the job done. When selecting training always ask the following question: “Does your fall protection training include observations of performance on each fall protection system and for each skill set that you expect your workers to have?”
Observations of Performance
Fall protection requires several physical skills: putting on a harness, setting anchorages, calculating clearance, installing systems, and maybe descent control or suspended work-positioning systems.
As a result, hands-on training is paramount. The student, legal departments, other agencies or OSHA can challenge training formats that do not include observations of performance, so hands-on demonstrations of skill must be included.
Training formats that do not include observations of performance provide a document with the student’s name on it, but do little to prove student’s ability or to withstand the test of litigation.
There is a general misconception that as long as a topic was discussed, demonstrated and documented with a test or roster, then the training was acceptable and adequate. Observations of performance take it one step further by requiring that the students demonstrate their skills to a qualified instructor.This is key.
The majority of learning takes place when the student physically participates in hands-on exercises. It is one thing to watch a video of someone using a ladder safety system. It is quite another to don a harness, attach yourself to the system and climb.
Inadequate training may instruct students on how to don a harness, but use videos or presentations to illustrate how the rest of the fall protection system works. Or, instructors may demonstrate how to use the fall protection system but they do not have the students physically participate.
It takes time (and money) to provide each student with an opportunity to use each component. Also, a structure where hands-on training can be provided is not always readily available. Observations of performance are often the first thing eliminated from training when time and money considerations are put before the quality of the program.
The International Association of Continuing Education and Training (IACET) and the Criteria for Accepted Practices in Safety, Health, and Environmental
Training (ANSI Z490.1-2009) provide guidance for how observations of performance should be used to gauge and evaluate desired skill sets and training outcomes.
ANSI/ASSE Z359.2 (Minimum Requirements for A Comprehensive Managed Fall Protection Programme) also supports observations of performance by calling for “physical demonstrations by trainees.”
Although training formats that do not include observations of performance may provide excellent information, they fall short. Imagine enrolling your teenager in a drivers’ education program where he/she is issued certification without ever getting behind the steering wheel of a car.
Obviously, training at heights, whether fall protection or rescue, needs to be conducted safely. The level of protection provided for students during training must be more than the minimum required by OSHA.
As much risk as possible must be removed in the training environment. Mistakes happen. Students may be using fall protection systems incorrectly or training exercises may be their first exposure to the equipment. A student may simply slip and fall during training.
Accidents and lost-time incidents are damaging enough – imagine one happening during training. Training should represent the workplace, but without the risk. When vertigo, apprehension, nervousness, fear, uncertainty or a fall occurs during fall protection and rescue training, provisions must be in place to ensure the safety of the student.
This is essential during observation of performance exercises. The instructor should balance the authenticity of the exercises with the risk associated with them. For example, using a Y-lanyard to climb a tower structure is acceptable according to OSHA requirements. But, if a fall accident should occur during training and a student is using a Y-lanyard only, he/she is going to fall several feet and swing into the structure.
During training, the students should be connected to a belay line or a self-retracting lifeline to offer the highest degree of safety while still allowing them to climb.
This principle has been understood for decades by many organizations. SCUBA diving is taught in a pool or shallow water. CPR is conducted on a mannequin. Drivers’ education cars have an extra set of brake pedals.
Fall protection training must also be designed to remove as much risk as possible. Training facilities provide a safer environment because they can provide certified anchorages, reduce swing falls, afford an environment that is conducive to learning and limit heights to facilitate prompt rescue if necessary.
Programme Implementation and Maintenance
Many components of the fall protection program come together after solutions are determined. PPE can be sourced and purchased and training programs can be developed.
ANSI/ASSE Z359.2-2007 provides direction for authorized, competent, qualified and program administrator training (as well as others). In the same manner that an assessment of fall hazards is conducted, a training assessment is conducted to ensure that training includes written objectives and observations of performance.
Other requirements of the fall protection program are also identified after fall hazard solutions are determined. There may be a need for engineering for permanent solutions or it may be necessary to design horizontal lifelines or certify anchorages. The number of unique fall hazards may reveal that written procedures are necessary for each area.
Those procedures should be included in the training program or materials for the worker. After solutions are determined, PPE is in place, workers are trained and engineering controls are in place, the program only needs to be maintained to include investigations and training updates. As new work is encountered or the worksite conditions change, the whole process starts over with a fall hazard survey.
Best practices for fall protection dictate that each area where workers are exposed to fall hazards is addressed. It is also necessary to determine feasible solutions, implement and document the controls, train, and maintain the program. This methodology provides the highest level of protection for both the employer and employee.
There is an unprecedented amount of fall protection information available to employers. The ANSI/ASSE Z359 Fall Protection Code, which includes Z359.2-2007, has more than 400 pages of information that provides guidance for employers who wish to develop an ‘industry best’ fall protection program.
Kevin Denis, Training Manager for Gravitec Systems, Inc, a company specializing in fall protection engineering, consulting, training, testing and technical equipment. Mr. Denis has been involved in the establishment of successful fall protection programs and audits for dozens of companies throughout Canada and the United States. He has managed a training department that averages more than 50,000 student training hours per year and has authored nationally recognized training standards for a number of different industries. Mr. Denis is a SPRAT.
(Society of Professional Rope Access Technicians) certified Level II Rope Access Technician and assists ANSI/ASSE Z359 Fall Protection Committee in developing the Fall Protection Code.
Part of this article was originally published in ASSE’s Practice Specialty newsletter.
Founded in 1911 and celebrating its centennial, the Des Plaines, IL-based American Society of Safety Engineers (ASSE) is the oldest professional safety society and is committed to protecting people, property and the environment. Its more than 32,000 occupational safety, health and environmental professional members lead, manage, supervise, research and consult on safety, health, transportation and environmental issues in all industries, government, labour, health care and education.