Workplace falls are one of the leading causes of occupational injuries and deaths nationwide. A fall from as little as 4 feet can have devastating or even catastrophic consequences. This post offers 5 “Must Ask” questions to help assess the health of your company’s fall protection program and benchmark compliance with key OSHA regulations, ANSI guidelines, and industry-accepted best practices.
Question 1–Do any of your employees perform work or maintenance tasks at heights?
In general industry, any leading edge over 4 feet is considered a fall hazard requiring a fall protection abatement plan and system per OSHA 1910.23(b)(1). It doesn’t matter if we are talking about areas where folks seldom go—or areas of your facility visited only for sporadic maintenance. Personnel exposed to leading edges over 4 feet require fall protection. For construction workers, fall protection is required for workers exposed to unprotected leading edges in excess of 6 feet.
Question 2—Do you have engineered fall protection systems on premises, and if so, is the equipment’s certification current and documented?
OSHA does not mandate a re-certification schedule for engineered fall protection systems such as horizontal lifelines and rigid track systems, but equipment must be visually inspected for wear and damage before each use and ANSI guidelines suggest documented annual inspection and re-certification. Most manufacturers, including DFP typically warranty their parts and labor for a period of one year and recommend annual re-certification. Annual inspection and re-certification requirements may seem like an unnecessary expense, but when you consider the financial costs associated with an equipment failure, the message is clear. Keep on top of your annual re-certifications. We recommend annual re-certification for general duty systems and more frequent inspection and re-cert timetables for harsher work environments.
Question 3—Is your fall protection training program current, documented, and up-to-date?
Even though you may require fall protection training for new employees, what about folks who start working in new areas? Any time an employee fills in for a sick or vacationing co-worker, or transfers to a new department, they are exposed to new, potential fall hazards. Be aware of changing work circumstances and how an employee’s training requirements may evolve. And remember, we all have a tendency to become complacent over time. Below are the relevant sections of the OSHA regulations as they pertain to fall protection training:
The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. If the employer relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training.
The latest training certification shall be maintained.
“Retraining.” When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (a) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
Changes in the workplace render previous training obsolete; or
Changes in the types of fall protection systems or equipment to be used render previous training obsolete; or
Inadequacies in an affected employee’s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill.
Retraining is required when workplace conditions or new fall protection equipment renders previous training obsolete.
Keep detailed written records documenting employee training, including names and dates of fall protection training and the signature of the individual conducting the training class.
Question 4—Who designed and installed your fall protection system?
It is not uncommon for an organization to train an employee to serve as a “competent person.” This designation means the individual has taken classes to identify hazardous working conditions, train employees on the safe use of fall protection equipment, and inspect PPE and fall arrest systems for signs of wear. We routinely see instances where a “competent person” also selects anchor points and works with an in-house PE to design and install a fall arrest system. All of this may sound good, but if the “home made” fall arrest system fails and a worker is injured or dies, your company is liable. If your system fails an OSHA inspection, again, you are liable. When you work with a company that specializes in the design and installation of fall arrest systems, the vendor assumes ALL liability for the system. If something does go wrong, having a fall protection company assume complete liability for system design, installation, and certification protects your company—and your assets. In case you are wondering, these insurance requirements are quite substantial.
Question 5—Do you have a documented rescue plan to satisfy OSHA 1926.502(d)(20)?
The best equipment and training are of little use in the absence of a rescue plan. Even the safest workplaces can become accident scenes, and even the most conscientious workers can fall. OSHA regulations on rescue are admittedly vague on this subject with language calling for “prompt rescue.” ANSI Z359.2-6.1 calls for rescue subject contact in under six minutes. Dangling from a body harness for even short time periods can cause suspension trauma—a medical condition causes dizziness, blurred vision, and shortness of breath. Left untreated, a worker suffering from suspension trauma can suffer oxygen deprivation to the brain, which may result in death. Make sure you have a written rescue plan and that your employees have trained properly to implement a rescue procedure. After a fall, response times are critical. Only calling 911 for EMS assistance is NOT an acceptable rescue plan. In addition to internal efforts and partnering with your fall protection company, working with the local fire department to develop a rescue plan specific to your facility prior to an actual emergency is a best-practice.
The point here is not to answer every potential question about fall protection or provide a comprehensive list to verify the safety of your facility. Instead, think about the 5 questions posed above as a starting point toward building a safer working environment for your employees. If you have additional questions, or wish to discuss your safety program with our fall protection experts, contact Diversified Fall Protection for further assistance.
Diversified Fall Protection designs, manufactures, and installs OSHA Compliant fall protection systems, including horizontal lifelines, rigid trolley beam fall arrest systems, vertical lifelines, and rooftop guardrail. To learn more about our turnkey approach to fall protection, please contact us for expert assistance with your safety needs.