Apply the Hierarchy of Fall Protection Controls to Save Lives (& Money)

Year after year, falls continue to be a leading cause of death and injury on construction sites. The Occupational Safety & Health Administration (OSHA) releases an annual report with fall protection violations given each year, including violations regarding equipment misuse, lack of proper training, ladder safety, and scaffold safety as well; bringing nearly half of OSHA’s Top Ten citations related to fall protection for nearly the past decade. 

Per OSHA 1926.501, employers must protect construction workers who are in an environment with the potential to fall six feet or more to the next lower level. (Note that general industry companies must adhere to OSHA 1910 and must be protected at four feet or more.) On a typical job site, the next lower level could be an elevator shaft, several floors of unfinished framing, steel beams, rebar, heavy machinery, the hard earth below, or even an excavation pit underneath that. Additionally, once an employer is made aware of a safety hazard, they are obligated to find a solution. OSHA presumes that basic fall protection methods like guardrail or personal fall protection systems are feasible. Note that feasibility does not necessarily equate to cost-effectiveness. This article will discuss how to apply the Hierarchy of Fall Protection Controls to identifying and determining the feasibility of various solutions for fall hazards. 

The Hierarchy of Fall Protection Controls 

The Hierarchy of Fall Protection Controls offers a systematic approach to identifying solutions that can keep workers as safe as possible. The last thing an employer should want is for an employee to get injured or killed while on the job. The next worst thing would be wasting resources on ineffective solutions that still didn’t properly protect a worker from danger. Applying this hierarchy of controls to the decision-making process of evaluating solutions puts the worker’s safety top-of-mind, and then progressively places the worker closer to the hazard but with further personal protective measures. The hierarchy proceeds as follows, in increasing order of increasing potential risk of injury to the worker: 

• Hazard Elimination
• Passive Fall Protection
• Active Travel Restraint
• Active Fall Protection
• Administrative Controls
  

If more organizations sought to change the nature of tasks to eliminate hazards or be more considerate of utilizing temporary guardrail before constructing permanent guardrail to be left behind after construction, then perhaps the culture shift would equate to lives being saved. Aside from saving lives and not risking the quality of life for workers at height, this culture shift could also have fiscal benefits for companies as well. According to a 2022 report from the National Safety Council (NSC), falls have the third leading worker's compensation payouts with an average of $50,000 per incident. That does not include other potential direct costs like OSHA citation penalties and litigation fees. Some sources estimate that further indirect costs, like decreased worker productivity, cost to replace injured or deceased workers, retrain new hires, and lost business due to damaged reputations, can equal up to four times as much as direct costs. 

Let’s further discuss what it looks like to properly apply the hierarchy of fall protection controls when trying to mitigate fall hazards on an active job site: 

Hazard Elimination

Eliminating a fall hazard is easier said than done in many construction environments. However, when one evaluates a hazard by trying to remove the hazard altogether before simply focusing on protecting the worker as-is, they’re able to make the work area safer and eliminate the risk. Instead of simply reducing the risk or severity of injury. For example, general contractors could discuss with building architects & design engineers incorporating parapet walls at least as tall as OSHA-compliant guardrail specifications (+/- 42” tall) that could remove rooftop fall hazards during the construction and future building maintenance. Or an electrical contractor could prepare conduit on the ground level before going up at heights for final installation.  

Passive Fall Protection

In many facilities, and especially on active construction sites, it is often infeasible to eliminate fall hazards since the nature of constructing buildings is dangerous work. However passive fall protection methods are quite effective at protecting workers from falls and require minimal user input. Guardrail is a textbook example of a passive fall protection system. As long as it exists in an environment, workers are made aware of the fall hazard the guardrail is protecting against, and it acts as a physical barricade in case of a slip, trip, or fall that occurs near the guardrail.  

Guardrail is simple to construct, and OSHA helps detail specifications for what classifies as compliant guardrail. A recommended best practice that is gaining popularity is to construct a temporary guardrail as the building’s frame is being constructed. Trade partners, inspectors, vendors, and anyone who will have to navigate unfinished floors could benefit from being protected by guardrail constructed at the start of a project. If it is possible, the best practice would be to install permanent guardrail as the project continues, if the fall hazard will remain once construction is complete. That practice can be extremely beneficial in certain areas, like mezzanines or rooftops. 

Per OSHA 1926.502 permits guardrail to be constructed if there is a top rail at +/- 42” tall (42”-45” only in California), at least one midrail, and toeboards. The top rail must be able to withstand 200lbs of downward force and the midrail is required to withstand 150lbs. Toeboards are also required if there is a chance of material falling onto workers below. Toeboards must be at least 3.5” tall and can sit no more than 0.25in off the ground. If constructing guardrail is not feasible, renting or purchasing prefabricated OSHA-compliant guardrail is always a possibility. 

Active Travel Restraint

If efforts to passively protect workers are deemed infeasible, there’s still one more level of the hierarchy that aims to remove the worker from the fall hazard. Travel restraint is an example of fall prevention equipment as opposed to fall protection equipment. The latter protects workers from the full forces and consequences of a fall, while the former attempts to prevent the fall from occurring altogether. 

Travel restraint systems require an anchor point approved by the site’s Competent Person, a properly donned harness, and an appropriate length fall restraint lanyard connected to the user. The connection device must be or can be adjusted to a length less than a worker can walk to reach their leading edge. Also, note the increase in user input required to make a travel restraint system effective compared to a passive system like guardrail. Suppose a worker neglects to use an appropriate length connection device. In that case, the entire system would be rendered useless, and the worker would be subject to a fall without proper equipment to mitigate the fall hazard or consequences of the fall. 

Travel restraint systems can prove difficult to establish in temporary settings, but that should not discourage one from considering them. When performed correctly, these systems allow workers to move around a work zone with their risk of falling virtually eliminated as long as they are connected into the fall prevention system. 

Active Fall Protection

Active fall protection is the hierarchy level that most people think of first when trying to mitigate fall hazards. There is nothing inherently wrong with fall protection systems, but they are a reactionary method to mitigate a hazard. The former levels in the hierarchy aim to remove hazards, not just mitigate how they affect the worker. A common fall protection system consists of an anchorage, body harness, and a shock-absorbing lanyard or Self-Retracting Lifeline (SRL). When determining which connection device to supply to the worker, refer to the product’s label to help determine the minimum required fall clearance for the device and ensure that clearance exists where the worker will be performing their task(s).

This is where things can get exciting. If the building being constructed is a facility that will have personnel regularly working at heights, like an aircraft or fleet maintenance facility, the fall protection system(s) that will protect future workers in the building could potentially be used to protect the people also involved in the construction of the building. With discussion & coordination between the building’s future occupant, the building design team, and the general contractor, fall protection systems could be specified in the planning phase of design to incorporate fall protection from the very beginning of a project. Examples of these systems could be overhead truss systems, rigid rail trolley systems, or horizontal lifelines. 

Fall protection systems also require a fall rescue plan in case of a fall. In addition to calling emergency personnel, OSHA requires employers to have the ability to self-rescue a fall victim until first responders arrive, if necessary to assist in a rescue. 911 should always be called in the event of a fall so the victim can receive medical attention, but emergency responders cannot be the only method of rescue offered to workers. Again, coordination with the building design team can help incorporate additional anchor points to be installed during construction that can be utilized for the personal fall arrest system and/or the rescue equipment. There is nothing to be said against these anchor points remaining after construction is complete to benefit future workers as well. However, it is common that most fall hazards experienced during the building's construction will no longer exist once it is complete. 

Administrative Controls

The last level of the hierarchy is a scary (and dangerous) place to be. It is when all other levels of the hierarchy are determined infeasible, and no fall protection methods can yet be installed. For clarification, OSHA only accepts infeasibility if it is determined that it poses an even greater hazard to try and install fall protection systems at this point in construction. This can be common for framers and erectors who are building the very infrastructure that future anchorages will be installed.  

For these scenarios, OSHA mandates these areas be designated as controlled access zones and must possess a safety monitor system and document the limited amount of necessary people that will be allowed into controlled access zones. Ideally, these areas would only exist while initial fall protection systems are being constructed, immediately once the required infrastructure is completed. 

Administrative control solutions should be considered a last resort regarding fall protection, as they do not remove the worker from the hazard, do not help to prevent a fall, nor do they mitigate the effects of a fall if it occurs. Some examples of administrative controls are additional signage to warn workers of upcoming hazards or utilizing a safety monitor system. A safety monitor is someone who exclusively supervises the work being performed at heights and verbally communicates to workers as their risk of injury increases while working. These solutions should be used strictly as required to hopefully install fall protection for immediate use. Often, administrative controls are used in conjunction with other systems as part of a comprehensive fall protection plan. 

Conclusion

Most organizations and safety teams aim to keep their workers as safe as possible, and the hierarchy of fall protection controls is a helpful resource to make sure all options are considered. While feasibility might be influenced by factors like available time and budget, the hierarchy helps consider the long-term benefits of always trying to remove the hazard before deploying mitigation methods. Eliminating the hazard is always ideal, but hardly ever the easiest task to accomplish. However, fall hazards are too common & dangerous to continue operating without always applying the hierarchy. 

Companies like Diversified Fall Protection have been involved in helping architects, general contractors, and building owners apply the hierarchy of fall protection controls at every stage of a building’s life. From assisting with building design to incorporate construction & future-use fall protection to retrofitting older buildings with modern technology to protect maintenance workers, they can use their proven process to mitigate the fall hazards on any job site or facility. Sometimes the solutions can be tedious and detail-oriented, but in the pursuit of saving lives there really cannot be any effort spared. 

This article was originally published in Construction Superintendent as "Applying Hierarchy of Fall Protection Controls Saves Lives, Money" on May 21, 2024