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How to Know When You Need Fall Protection – A Complete Guide

How to Know When You Need Fall Protection – A Complete Guide


Fall protection regulations can be tricky.  Depending on what industry you are in, what task you are performing, or what piece of equipment you are using, your requirement to have and utilize fall protection can be anywhere from 0’ to 30’.  That’s a big difference without even counting all the various requirements at heights in between.  So, how are you to know when you need fall protection?

The simplest answer is, absent the presence of equipment, machinery, or some substance you can fall into, if you are working more than 4’ above a lower level and do not have some type of fall protection, you MAY be in violation.  If you are not 100% sure if you are in violation or not, you either need to do some research or reach out to somebody who does know the answer.  Simply proceeding with your work because you weren’t sure of the specifics, is not acceptable. 

Industry

Let’s start with the quick overview.  Each of the OSHA regulations has its own starting point.  Keep in mind that each of these starting points has a caveat:  If you are working over some equipment or substance into which you could fall and do harm to yourself, then you must be protected from doing so even if you are mere inches above it.  All other requirements get overridden. 

Otherwise, the simple breakdown is this:

General Industry (anyone governed by 29 CFR 1910) – 4 feet
Shipyards (anyone governed by 29 CFR 1915) – 5 feet
Construction (anyone governed by 29 CFR 1926) – 6 feet
Longshoring (anyone governed by 29 CFR 1918) – 8 feet

Be careful though, because these numbers are by no means definitive.  There are many exceptions to these rules, most notably in construction, which brings us to how heights differ by task.

Task

Breaking the rule up into industry helps to give you a general idea of when you need fall protection given your task – but only in a very broad sense.  For instance, if the work you are doing is considered maintenance, then you would have to abide by the general industry rule, whereas any work deemed construction or demolition would mean you’d have to abide by the construction rule.  However, within those industries there are specific tasks that are treated differently.

A few notable examples are roofing and steel erection.  Both are considered construction activities, so they fall into 29 CFR 1926 which in general requires fall protection at 6’. However, here are your actual requirements for each:
Steel Erection –

  • No fall protection is required for anybody involved in steel erection activities until they are 15’ feet in the air.
  • At 15’, all workers involved in steel erection activities MUST have and utilize fall protection EXCEPT connectors and deckers.
  • Connectors must have fall protection and the ability to use it from 15’ to 30’ (or two stories, whichever comes first), HOWEVER, they may opt to not use it.
  • Deckers may utilize a Controlled Decking Zone (CDZ) from 15’ to 30’ (or two stories, whichever comes first).  For details on CDZs, refer to 29 CFR 1926 Subpart R.
  • At 30’ or two stories (whichever comes first), ALL personnel involved in steel erection activities MUST have and utilize fall protection, no exceptions.

Roofing –

  • Roofers (and only roofers – other trades working on a roof do not receive the allowances given to roofers) may opt to utilize a warning line and safety monitor system instead of other fall protection.
  • In such cases, the warning line must be 6’ from the edge of the roof (or more) or 10’ if mechanical equipment is operating on the roof and travelling toward that warning line.
  • Safety monitors are not optional.  While there are situations where a safety monitor may be used without a warning line (i.e. – on a roof less than 50’ in width), there is no situation in which a warning line can be used without a monitor.
  • This applies to low-slope or flat roofs.  It also applies if you have an elevated section of roof within the edges of a lower roof, if the elevated section is 6’ or more above the lower section.
  • Good advice for a roofer is, if you’re on a roof and don’t see something between you and the edge, you might not be properly protected, so ask.

What should be fairly obvious from the above two examples is that when we start to discuss specific procedures, things get very…well…specific.  Suddenly a catch-all rule doesn’t always apply…or can’t always apply.  Therefore, things get broken down further.  Bit by bit by bit.  This is not something you would just know or something that you could assume, so, before beginning your work, make sure that you understand whether or not there are different rules for the task you are about to perform.

Equipment


Equipment can also play a factor in when fall protection is required.  For instance, you must be properly tied-off at all times when in an aerial lift.  This overrides the 15’ requirement in the steel erection regulation as it is a more specific requirement and because the manufacturer requires it.  Scaffolding has a requirement of 10’ that exists solely for being able to work on top of one bay of scaffolding (often greater than 6’ high) without having to concern yourself with railings or other means of protection.  Ladders even have their own rules, depending on whether you’re just climbing or working from them.  With the new Walking and Working Surface regulation in place, new fixed ladders over 24’ must now have fall protection devices in place as opposed to the old requirement for cages or wells.  In order to find out if your equipment has a special requirement, refer either to the operator’s manual or to the specific section in the OSHA regulations that governs your equipment.

Of course, each of these situations that we’ve already discussed has additional rules, requirements, and exceptions that cannot be completely detailed in an article without completely reproducing the regulations.  It is important for you to fully understand the situation in which you are working before you work.  This can be done through your own research (www.osha.gov has great information), but it can also be done – and should also be done – through training.  All employees who need to utilize personal fall arrest systems MUST be trained in their use, but it is a good idea to train anybody that is utilizing fall protection equipment, even if it’s just railings, because it will teach them how to recognize hazards and how to avoid putting themselves in dangerous situations. 

In the end, to answer the question, “How do I know when I need fall protection?” is simple.  You might not, so trust your gut and if something doesn’t feel right, ask.  If you’re over the basic height requirement listed above for your industry and have no fall protection, don’t worry about whether or not you might be an exception to the rule.  Ask.  If you’re not satisfied with the answer you’re given, seek out somebody who knows.  Whether it’s a safety group on LinkedIn or a friend you know in the industry, find somebody who knows the answer.  Don’t put your life at risk because somebody else doesn’t know what is required, because once you fall, there is no turning back.

OSHA Provides a Deadline for Fall Protection Training

OSHA Provides a Deadline for Fall Protection Training

It seems like we’ve been talking about the “upcoming” and “recently passed” Walking/Working Surfaces rule for a long time and many people may remember that contained within the rule were some delayed effective dates.  This means that while most of the regulation was effective this past January, employers were given some extra time to come into compliance with certain aspects of the law.  Unfortunately, for those not paying close attention, these delayed dates have started rolling around, and they may have caught some employers completely off guard.  In fact, one key date just passed and, if you were not aware, you could find yourself in non-compliance.

As of May 17, OSHA requires that all workers are trained in both fall hazards and any equipment covered by the final rule.  Understand that this is not a new training requirement. Workers in fall protection situations should already be trained, however, you need to ensure that they have now received training on any new aspects of the regulation that apply to them.  This training includes what hazards they are exposed to and how you are protecting them, as well as how to utilize equipment such as Personal Fall Arrest Systems (PFAS – Harness, lanyard, anchor point).  If you’ve already done this, congratulations!  Keep on doing what you’re doing!

If you were putting off training employees, you no longer have that option.  Now that we’re past the deadline, here’s what OSHA requires you to do ASAP, to come into compliance:

1) Each employee must be trained by a qualified person, which, according to OSHA, is someone who “by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” It is important you ensure that the person delivering training meets this definition, not only so that your employees are receiving all the necessary information to keep them safe, but to ensure your compliance with the requirement should your training come under scrutiny.

2) Each employee must be trained on what fall hazards they are exposed to, how to recognize fall hazards, and what procedures they need to follow in order to keep themselves safe.

3) Employees must be trained on how to properly install, inspect, operate, maintain and disassemble fall protection systems that they use.

4) Each employee must be trained in the correct use of fall protection systems, including proper hook-up, anchoring, tie-off techniques, as well as methods of inspection and storage as specified by the manufacturer.

In addition, OSHA offers further specifics to which this deadline applies:

1) Employees must be trained in the proper care, inspection, storage and use of equipment.

2) Employees that use dockboards must be trained to properly place and secure it.

3) Employees who use rope descent systems must be trained in proper rigging and equipment use.

4) Employees who use a designated area must be trained in their proper setup.

OSHA also notes that retraining is necessary in certain situations, such as:

  • When an employee demonstrates that they don’t have the knowledge or skill they should have in regards to fall protection,
  • When workplace changes make the old training obsolete,
  • Or when new fall protection systems or equipment are being used.

Finally, OSHA requires that training must be understandable.  While this may sound like common sense, it is not unheard of for employers to have employees sit through a training session in a completely unfamiliar language just to make sure they receive documentation of training.  However, this caveat doesn’t just apply to which language a person understands.  If a person is illiterate, for example, this requirement could mean that they must be presented the information – and tested - orally.  As an employer, you will have the burden of proving that your employees understood the training, should OSHA audit your company.  This is often accomplished through some type of exam, whether written, oral, or practical.  Whichever way you choose, be prepared because OSHA will ask, “How did you know they understood it?”

If you are one of the companies that has not trained your people, get on it immediately.  A great number of incidents, injuries, and fatalities can be traced back to the fact that people were not properly trained for the work they do and the safe ways in which to perform that work.  Train your people now, before something happens.  Keep them safe by arming them with knowledge.

To find a fall protection training course near you, we recommend checking the following online calendars:

Finally, as a reminder, below are the remaining upcoming deadlines for the Walking/Working Surfaces rule:

  • *November 20, 2017 – Inspecting and certifying permanent anchorages for rope descent systems.
  • *November 19, 2018 – Installing personal fall arrest or ladder safety systems on new fixed ladders greater than 24’ in length and on replacement ladders, including on outdoor advertising structures.
  • *November 19, 2018 – Ensuring that all fixed ladders over 24’ including outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system.
  • *November 18, 2036 - Replacing all cages and wells used as fall protection with ladder safety devices or personal fall arrest systems.

Ladder Cages Are No Longer the Right Solution

Ladder Cages Are No Longer the Right Solution


If you’ve ever had the pleasure of climbing the side of a building, chances are you are well-aware of the round metal cage whose function it is to protect you from violently crashing to the ground.

Also, it’s likely that at some point during your ascent you thought, “How is this round metal cage supposed to protect me from violently crashing to the ground?”  Well, it looks like you weren’t the only one.  In fact, it was widely recognized that ladder cages did nothing in terms of worker safety and fall prevention. So, as of the release of the new Walking/Working Surface standard, ladder cages are being phased out. 

Now, don’t panic if you’ve got a facility full of them.  OSHA has various dates for compliance to allow for a gradual transition and to ease the financial burden on property owners/employers who find themselves needing to make a change.  For now, existing ladder cages are grandfathered in, but that will change eventually.

The first compliance date comes late next year and is the deadline for when employers must ensure that all fixed ladders have some type of safety system.  The deadline, November 19, 2018, still allows employers to select wells as their fall protection option as long as the ladder already existed. Technically, that means that a newly installed ladder between now and then could still have a cage installed because it will have been “existing” on November 19, 2018.  Of course, to make things easier going forward, employers could simply opt to install a ladder safety system or personal fall arrest system, as well, or as their main fall protection solution.

On that same date, all new fixed ladders (as well as any replacement ladders or ladder sections) will be required to be installed with either a ladder safety system or a personal fall arrest system.  No new installations will be allowed with cages or wells.
For the most part, that takes care of the near-future deadlines.  But, OSHA is phasing wells and cages out altogether, so while you may try squeezing new installations in before the deadline, keep in mind that in 20 years’ time (November 18, 2036 to be exact) all fixed ladders greater than 24’ in length will be required to have fall arrest systems or ladder safety systems. This means that your existing ladders with cages and wells will need to be retrofitted because there will no longer be any grandfathering allowed.  Granted, this is quite a way down the road, but there’s no sense in employers waiting 19.5 years and scrambling at the last minute to change everything in their facility.  

So, as mentioned above, this leaves you with a choice between two remaining acceptable solutions: ladder safety systems and personal fall arrest.  Most people are familiar with personal fall arrest systems (PFAS) – a harness, lanyard, and suitable anchor point.  The requirements here are no different than the requirements elsewhere: fall clearance, freefall distance, proper inspection and maintenance of equipment, anchor point capacities and training in the equipment’s use must all be taken into account just as if you were using this equipment to keep somebody from falling off the edge of a building.  Ladder safety systems, though, may be a little bit less familiar.  While they still require a harness, ladder safety systems are rails or cables that run the length of the ladder vertically.  An employee “ties-off” by hooking the front D-Ring of his or her harness to the trolley or rope grab and proceeds to climb.  Certain systems will require some manual action by the user while others will simply allow them to climb, locking into place only in the event of a fall.  Keep in mind that employees will need to be able to transition from the ladder to the level to which they are climbing without exposing themselves to a fall, so the ladder safety device may need to extend farther than the ladder.  Ensure that this is designed into the system when installed or it could cause problems later on.

Whichever method you choose – PFAS or Ladder Safety Device – your employees will be safer when climbing your fixed ladders than they were while relying on a cage or well.  Make sure you train them so they can properly use the equipment and are safe.  Improperly worn/used fall protection equipment may be offering nothing more than a false sense of security.  And false senses of security make people take unnecessary risks that could lead to disaster.  Make sure to review your facility and start taking the necessary precautions now.

4 Things You Need To Know About the New OSHA Regulations


The end of last year marked a significant update to the OSHA Fall Protection Regulations. With this new update, OSHA produced a 513 page document as a final rule on Working-Walking Surfaces and Personal Protective Equipment. Knowing that reading this regulation would be a feat of its own, we did the work for you. Download this ebook to learn more about the 4 core changes that you will want to know.

What's Inside:

  • New terms introduced by OSHA
  • Learn where on your roof you need fall protection
  • Understand the new requirements for ladder safety
  • New fall protection training requirements from OSHA


Understanding the New OSHA Approved Options for Fall Protection

Understanding the New OSHA Approved Options for Fall Protection

Late last year, OSHA published a long-awaited final rule on Walking and Working Surfaces.  One of the main reasons for this update to the existing general industry standard was an attempt to bring the fall protection requirements for manufacturing, warehousing, maintenance, and other similar operations more in line with the construction requirements.  To those who, at times, are governed by the construction regulations, much of the new rule will be familiar, specifically the section on Personal Fall Arrest Systems (PFAS).  However, this is definitely not all that is new.  Below is a guide to what has changed.

Fall Protection

Prior to this rule, the general industry regulations required that a company consider guardrails as their primary method of fall protection.  While passive systems are always a great option, they are not always feasible.  The new rule gives companies the flexibility to decide which method works for them, including Personal Fall Arrest Systems (harnesses, lanyards, anchor points, or what is commonly known as “tying off”).  The new rule not only allows for this type of system to be used, but also lays out requirements for their performance, use, and inspection.

In addition, the rule allows for certain methods to be used in situations that can be considered “temporary and infrequent.”  For example, work being performed on a low slope roof that meets the criteria for temporary and infrequent may be allowed to utilize a designated work area.  This area, 15’ back from the edge may preclude the use of other fall protection equipment, as long as all of the requirements set forth in the regulation are met.

Scaffolding

Rather than update the outdated scaffolding section, OSHA now requires that employers who are using scaffolding under the general industry regulations follow the construction guidelines found in 29 CFR 1926. This is a quick, simple change that could eliminate a great deal of confusion.

Fixed Ladders

Say goodbye to cages and wells.  Kind of.  Over the next 20 years (based on whether or not a ladder already exists, is being repaired or replaced, or is a new installation), fixed ladders that are over 24’ in length will need to be equipped with ladder safety devices or personal fall arrest systems.  Cages and wells will no longer be acceptable as they have not proven to prevent falls.


Qualified Climbers

This one only affects you if you’re in outdoor advertising, but the allowance for “qualified climbers” in outdoor advertising to climb without fall protection is gone.  The phase-in timeline for fixed ladders mentioned above applies, but if their ladders have no cages or wells currently, they have 2 years in which they could choose to install those to become compliant with existing regulations.  After that, they will still need to meet the timeline set forth for ladder safety devices or PFAS.

Rope Descent Systems

This part is basically taking an OSHA memorandum and making it law.  Companies that use Rope Descent Systems (RDS) may not do so over 300’ above grade.  It also requires that building owners provide (and employers obtain) information to show that the anchorage points have been inspected, tested, certified and maintained to meet the requirements.

Inspection of Walking-Working Surfaces

While this may seem like it goes without being said, it apparently needs to be said: employers must regularly inspect walking-working surfaces and maintain/repair them as necessary.

Training

What rule would be complete without a section on training?  Most notable is the fact that employers – as in construction – must train employees on how to use, inspect, store, and maintain their PFAS.  Workers in specified high-hazard situations must be trained in those hazards and the hazards associated with their fall protection equipment.  As always, workers must be trained in a manner that they understand.  It is the employer’s responsibility to determine what that manner is and to verify that their employees have understood the material.

While the changes may not be earth-shattering to many, the addition of the use of PFAS is a long-anticipated change that gives employers much more flexibility in determining fall protection solutions.  Likewise, while ladder changes may be costly for facilities that have many fixed ladders, the timeline helps companies to spread that cost out and, in the end, replaces an ineffective system with something that will actually prevent injuries and fatalities.  Some of these requirements simply make it easier by having one place to go, i.e. for scaffolding, rather than having to worry which regulations you are supposed to be following and whether or not those regulations match up.  And isn’t giving employers flexibility, making things simpler and preventing injuries and fatalities exactly what we want?


Using Portable Ladders Safely

Using Portable Ladders Safely


Whether you’re a plumber, painter, electrician, maintenance worker or any other number of trade professionals, the portable ladder is a go-to solution for difficult-to-reach work tasks.  Whether it’s an A-Frame or an extension ladder, we take for granted that they’re the safest way to do our jobs.  That may not be the case.  Ladders could be unstable, especially if they’re not being used properly.  In many cases, the Easi-Dec Portable Work Platform offers a much safer solution, but companies won’t invest the time or money needed to have them available.  Other times, companies are simply not aware there is another solution, so ladders continue to permeate our job sites.  Therefore, it is important workers know how to properly and safely use portable ladders.

Angles

Extension and straight ladders must be set at the proper angle in order to keep them from tipping back.  This angle is a 4:1 ratio.  In other words, for every 4 feet in height from the ground to the point the ladder makes contact with the structure, the base must be a foot away from the structure.  Now, most of the time, nobody is busting out a measuring tape.  There are two easy ways to tell if you’re at the proper angle.  1) Stand at the base of the ladder so that your toes are touching it.  Extend your arm at a 90 degree angle from your body.  If your hand touches a rung or a side-rail, you are approximately at a 4:1 angle.  2) Download the NIOSH ladder app.  Simply lean your phone along the rail of the ladder to see what angle you’ve set the ladder at.

Securing the Ladder

Most people are concerned about a ladder tipping backwards, but it’s much more likely it will actually shift laterally.  Therefore, it is important that you secure the ladder – near the top – to the structure to prevent it from shifting.  Do not use the ladder’s adjustment rope to secure it to the structure.  Ensure that somebody is holding the ladder in place during the initial setup.

Proper Height

Your ladder must extend 3’ above the level to which you are climbing, or there must be a grab rail that extends 3’ up.  While this is important when dismounting the ladder, it is even more important when mounting the ladder from the top.  The last thing you want is somebody walking to the edge of a building or platform and having to lean down to grab the ladder.  One moment of light-headedness could end in disaster.  To see if your ladder is properly extended, count the rungs.  There is approximately one foot between rungs.  

Setup

The ladder will never be a safe tool if it’s not set up in a safe location to begin with.  Make sure your ladder is on firm, level ground and that the safety feet are in place.  If you need to kick the feet up to dig into the surface material, that’s what they’re there for.  For an A-Frame ladder, ensure you’ve fully opened the ladder and locked it into place.  No A-Frame should ever be used while folded or partially closed.  This is not what the ladder is designed for and not how it’s tested.

Maximum Height

Your A-Frame ladder has a maximum working height.  You’ll notice a label that says “Do Not Work On or Above This Step.”  Pay special attention to the “On or Above” part.  Most people look at that and think that they can step on that step but not above it.  This is not the case.  And definitely, don’t ever straddle the ladder or sit on top of it.  In addition, the label on the side of the ladder contains a maximum working height in case you’re unsure.  If you can’t read the labels, that’s a whole different problem and you need new ladders.

Labels and Paint

Labels on the ladder must be legible.  If they are worn off or painted over, then you cannot use the ladder.  (NOTE: You do not need to destroy or throw away ladders because the label is illegible. Instead, call the manufacturer to get a new label shipped to you.) In addition, you must be able to inspect your ladder for cracks, defects, and damage.  Painting ladders with an opaque paint may prevent you from doing so, therefore do not paint your ladders.

Safe Use

You can set up a ladder as safely as you want.  If you don’t use it safely, you can still get hurt.  Always maintain three points of contact when climbing a ladder.  This means two feet and a hand, or two hands and a foot.  Doing this precludes you from carrying tools or materials in your hands – which is a good thing.  While working aloft, your tools should be at the very least in a tool belt or tool vest.  At best, they should be tethered to you.  Also, maintain your center of gravity between the side rails – no leaning off to one side or another.  Keep your eyes out for other hazards or unsafe conditions.  Many ladder accidents, for instance, occur when employees mount the ladder at the top by swinging around it.  Perhaps you can purchase ladder toppers to eliminate this hazard.  These toppers attach to the top of the ladder and extend the necessary 3’ above the surface you’re climbing to while allowing the worker to step THROUGH them instead of around.  Finally, only use ladders as intended.  Do not separate parts if they’re not intended to be separated.  Do not lash sections together.  Do not climb both sides of an A-Frame unless it is specifically designed for that.

Inspecting

Ladders are a tool, so you need to treat them like one.  Just with any other tool, you need to inspect your ladder prior to use and remove it from service if anything is wrong with it.  Do not take chances.  A new ladder is much more inexpensive than a broken bone or a lost life.

Training

Don’t believe that just because we use ladders at home that your employees know how to use them safely.  People use ladders wrong ALL THE TIME.  It is your responsibility as an employer to ensure that your employees are properly trained in the safe use of ladders and that you are designating a Competent Person(s) regarding ladders.  That Competent Person, according to OSHA, must be knowledgeable enough to recognize a hazard and must have the authority to correct it.

Ladders are a very familiar and very useful tool, but as such, people tend to become complacent when working with them.  Unfortunately, complacency can be safety’s mortal enemy.  Make sure that if you are going to choose ladders as the proper means for your workers to complete their work tasks that they are fully aware how to use them safely. Ladders are cheap.  People are not.


10 Safety Tips for Working at Heights

10 Safety Tips for Working at Heights


Whether you work at heights every day or just once in a while, your focus on safety during those times is of utmost importance. It takes one mistake to turn a routine work task into a fatality.  Falls are debilitating.  Falls are deadly.  You must be prepared to protect your employees each and every time they could be exposed.  Here are ten tips to consider if your employees work at heights.

1. Use Rails

When you can, use rails.  Passive protection is the easiest way to keep your workers safe and achieve compliance because there is nothing that they need to actually do to keep themselves safe (other than stay within the rails…and if your employees are climbing outside of protective rails, you’ve got bigger problems to address!).  Rails can be built by jobsite carpenters (as long as they meet the requirements set forth by OSHA) or pre-fabricated from a manufacturer and installed.  Pre-fabricated railings can be permanently affixed or portable to suit your needs.  Regardless of which type you use, once in place, you’ll find rails are the easiest fall protection system to use.

2. Select the Proper PPE

If you’re going to use Personal Fall Arrest Systems (PFAS), you need to ensure you’re choosing the proper equipment.  All full-body harnesses that meet ANSI standards will perform the same, despite their cost, however, that price differential is getting you something.  Sure, sometimes it’s just a name, but other times it’s functionality that you’re getting or sacrificing, such as extra D-rings, fireproof material, or arc-safe design.  Sometimes, a more expensive harness is more expensive simply because it’s been made to be more comfortable.  Do your research and decide what it is you need.  If you have workers welding at heights, then a standard nylon harness is probably not going to be what you need.  Perhaps Kevlar is the way to go.  And, don’t forget your workforce.  Perhaps comfort isn’t your main concern (though it’s certainly much easier to get cooperation from your workers if they are comfortable wearing the equipment), but that’s not the only consideration you need to make.  Harnesses are not one-size-fits-all.  Make sure your workers can properly adjust their harnesses so that they fit correctly.
Lanyards need to be properly selected as well.  Depending on the height at which you are working, a 6’ lanyard with a deceleration device will not protect your worker.  Instead, a retractable lanyard may be necessary.  Each situation is different, so you need to evaluate your working conditions and the task to be performed in order to give your employees something that will actually protect them.

3. Inspect Your PPE

Employees can use all the equipment they want, if they’re not inspecting it, it could fail at any time.  When it comes to harnesses and lanyards, while they need to be periodically inspected by a Competent Person (one with the knowledge to recognize the hazard AND the authority to correct it), they should also be inspected by the user prior to every use.  In order for this to happen, your users need to understand what it is they’re looking for, what is acceptable and what is not, and what to do when they find a problem.  The inspection should be thorough, but does not need to take a lot of time.  Even so, this brief pre-work check could save a life.

4. Ensure You Understand Fall Distance

You can wear all the fall protection equipment in the world, but if it allows you to hit the lower level before it engages, it’s pointless.  This may sound like a “common sense” statement, but you’d be surprised at how many people don’t seem to have “common sense”.  It is not unusual to go onto a construction site or observe a maintenance crew in a plant and see a worker at 10-12’ off the ground wearing a 6’ lanyard with a deceleration device.  While at first glance you might think that it should work, there are a number of reasons why it won’t.  First, you have to add 3.5’ of distance to account for the deployment of your deceleration device.  Already that means the lanyard itself is 9.5’ long.  Unless you are a 6” tall person, this is some pretty bad news.  Your actual fall distance needs to not only include the length of your lanyard when deployed, but also your body length below the D-ring and any sag in your harness and anchor system.  Count on a good 18.5’ minimum before you’re able to use a 6’ lanyard with deceleration device.

5. Ensure the Selection of Acceptable Anchor Point

As Grandpa said in The Lost Boys, “We’ve got rules!”  Sure, he was referring to drinking his root beer and not peeling the label back on the TV Guide, but he might as well have been talking about anchor points.  If you were to pick a construction site at random right now and see what they’re using as anchor points, you might assume there were no rules.  PVC pipe?  Not an anchor.  Decorative steel?  Not an anchor.  In fact, many more things will NOT be an acceptable anchor point than WILL be an acceptable anchor point.  Why?  Because the anchor point must support not just the weight of the person attached, but 5000 lbs. per person attached (or a factor of 2 if you’re having an engineer determine your anchor).  Many fixtures are not going to withstand those forces.  Structural steel using a proper beam clamp?  Sure.  A manufactured roofing cart or other manufactured anchor?  Sure, if installed properly.  Short of that, you’re going to need some documentation and/or an engineer’s approval to use something as an anchor point.

6. Ensure You Select the Best Means of Working at Heights (Scaffold vs Lift vs Ladder)

Just as harnesses are not one-size-fits-all, neither are fall protection solutions.  In some situations, a scaffold is going to be your best solution to work at heights.  If so, you’ll probably be able to equip them with rails, making your fall protection much easier to address.  Other times, scaffolds will be infeasible and you’ll find yourself on a lift.  Depending on the type of lift, you may or may not need to wear a harness and a lanyard (and properly tie off).  Still other times, you’ll need to use a ladder, at which point the requirements for fall protection become trickier.  In the end, thinking that a ladder is going to suffice no matter what situation you’re in (or a lift, or a scaffold, or any other means of elevation) is only asking for problems.  Evaluate your situation carefully and determine what the right piece of equipment is for that task in that location.

7. Use Ladders Properly

Don’t assume that just because you have a ladder at home, you know what you’re doing.   In fact, the safest way to live on this planet is to always assume you don’t know what you’re doing.  In most cases, you’re going to be right!  Ladders lie at the source of many industrial and workplace accidents simply because we take their use for granted.  Ladders are familiar.  You use them to hang your Christmas lights, paint the living room, change that annoying hard to reach high-hat bulb, and clean your gutters.  We use them so often that we must know what we’re doing because we’ve never gotten hurt before! Well, except for that one time you closed the A-frame on your hand.  Or that time, the ladder slipped out from under you.  Or that time you had a tool on top of that ladder that fell onto you.  Or that time….well, never mind.  Ladders are dangerous.  When improperly used, they’re REALLY dangerous.  First, make sure that ladders are the best way to do what you’re doing, then make sure your employees know how to properly use them.  3’ extension, 4:1 ratio, 3 points of contact, and secured.  If you don’t know what that refers to, you may not know how to use an extension ladder properly.  You know that sticker on a step ladder that says, “Don’t stand on this step or above.”?  If you think that means you can step there but no higher, you might not know how to use a step-ladder.  Provide proper training to your employees so that they use the tools they are being given the right way.

8. Know Your Roofing Regulations

Roofing regulations are some of the most misunderstood requirements.  Not only do roofers not know exactly what is required of them much of the time, but many other contractors working on roofs who are not roofers believe that certain methods of fall protection are available to them when, in reality, they’re not.  Warning lines at 6’ with a monitor are only allowed for roofers performing roofing work (and 10’ back from the edge if there is mechanical equipment traveling in that direction).  Notice the phrase “with a monitor” in the previous statement.  There is NO situation in which a warning line is an acceptable means of fall protection that does not also include a dedicated monitor being present.  There are a few that allow for a monitor with no warning line (low-slope roofs less than 50’ in width for instance), but none that allow a warning line with no monitor.  Also, notice the phrase “dedicated monitor” in that previous statement.  Monitors must have no duties that would distract them from performing as a monitor.  You see where I’m going with this?  There are many nuances to the rules for roofers.  If you are one, make sure you are familiar with the regulations and your requirements or speak to somebody who is.

9. Ensure Proper Use of Lifts

There are many ways in which a lift operator can do something wrong, so I won’t get into the actual operation of lifts here, but we do need to discuss fall protection in regards to lifts.  One thing that gets missed quite often is that any person in a boom lift, at any time, at any height, must be properly tied-off.  “Properly tied-off” not only means that they need to be secured to the engineered anchor point designed with the lift, but it means that they can’t wrap their lanyard around the rails and they need to have a lanyard that is actually going to protect them at the height at which they are working (see fall distance above).  With scissor lifts, things are a little different.  While the site you are working on or the owner of the facility/project may require you to tie-off in a scissor lift, there is no regulatory requirement to do so.  However, the moment you forget to close your gate or secure your chain, you are no longer protected by the rails and are now in a fall protection violation.  It’s that simple.  Also, keep your feet planted firmly on the platform.  Both of them.

10. Train, Train, Train

It’s been mentioned in various paragraphs above, but it can’t be stressed enough.  If you want your employees to work safely at heights, they must be properly trained.  Period.  The end.  Not only is training required by law, there is just too much room for error and confusion when it comes to a person without the proper knowledge trying to protect themselves at heights.  Falls are the leading killer in construction year after year.  Many people in other industries die from falls as well.  They are deadly.  Most of the time, there are no do-overs.  Arm your employees with the knowledge they need to keep themselves safe.
Working safely at heights does not come by chance.  It is not something you luck your way into.  Working safely at heights takes preparation, education, and determination.  Take this brief list and dive into some of the more in-depth articles it links to.  When it comes to fall protection, you can’t have too much information.


Creating a Safe Walkway

Protecting Warehouse Workers

Pedestrians are some of the most vulnerable employees in a warehouse setting simply because (as we’ve stated in some of our recent articles) in a physical battle between man vs. machine, the machine is going to win…especially when that machine is a rolling piece of equipment weighing thousands of pounds. Hoping pedestrians and operators are smart enough to avoid a tragic incident is not an acceptable – or very effective – safety precaution.  What, then, can be done to help ensure the safety of pedestrians?

One of the most important things you can do as a warehouse manager or safety manager is to control exactly where pedestrians are walking while in your warehouse.  Making pedestrian travel paths predictable helps to ensure that operators know where to expect people.  It’s not that operators should not be alert for pedestrians at all times, but walkways help the operators to know where the high foot-traffic areas are.

However, simply saying, “Stay close to the wall,” or “Don’t cross over there,” is not enough.  The first thing you’ll want to do is designate the walkway.  Very infrequently will you be able to put a physical barricade up along the entire walkway, but at the very least you can paint it so there is no mistaking where it is.  That being said, if you have the luxury of physically separating your people from your machines using rails or bollards, by all means do it.  Even if it’s just in certain places.  Systems like this Kwik Kit make it easy for you to erect an OSHA-compliant barrier in varying lengths or configurations. There is no substitute for a physical barrier.

Once you’ve painted your walkway and/or added rails or bollards, your personnel need to be trained.  Having walkways does you absolutely no good if people aren’t going to stay within the boundaries.  The walkways also do you no good if operators are going to barrel through them at high speeds.  Set time aside to explain to your employees the purpose of the walkways, the hazards they face if they were to travel outside of them, and what the disciplinary action will be if they violate your rules (whether as a pedestrian or as an operator).  No safety procedure is going to be successful if there are no consequences for those that don’t follow it.  And, it is important that if you are going to have disciplinary actions, that you follow through with them.  Anybody who is a parent is probably painfully aware of what happens when a violator realizes they are facing nothing but empty threats.

It is important to note that you will not be able to have walkways everywhere pedestrians need to walk, otherwise your entire floor would be painted, which would be as pointless as not painting them at all.  When you train your employees, you need to train them on what they need to do and/or where they need to go once they have to step out of a walkway.  Just like teaching a child to look both ways before crossing a street, ensure they understand that forklifts have the right of way because they simply may not be able to stop in time for them (at the very least not without losing a load). Also, pedestrians need to always ensure the forklift operator is completely aware of their presence before continuing by making eye contact with the operator.  Teach your employees not to place themselves immediately behind any machine or between any machine and a fixed object like a wall.  You never know when an operator is going to lose control, hit the gas instead of the brake, or back up when they mean to go forward.

Even though it is more difficult, none of this means that you still can’t control access to undesignated or more dangerous areas.  For instance, where your walkway crosses a highly traveled forklift path, you may choose to install safety gates.  These gates force the pedestrian to pause and ensure it is safe to proceed before automatically closing to prevent anybody else from wandering through.  In this day and age of walking and texting, physically preventing people from wandering into traffic has become a sad necessity.

Finally, make sure you know who is wandering through your warehouse.  There is no better way to keep a handle on the safety of everyone in your facility than by knowing who is in there at all times, that they are supposed to be there, they have been trained, and that they adhere to your policies.  Sending a random truck driver, for instance, to go to a bathroom in the middle of your warehouse can not only put your product at risk, but can put them at risk of physical harm as well.  This is your facility.  Ensure that anybody who sets foot in it goes home safely when they leave.

 


Protecting Warehouse Workers

Protecting Warehouse Workers


In a recent article, we discussed the overall hazards forklift use in a warehouse poses and what you need to do to have a successful safety program in such a situation.  However, let’s drill down a little further to see not only how we can protect our workers from forklift hazards, but also how to protect them from other hazards that exist in warehouse environments.

Impact Protection

One of the most prolific hazards in warehouse environments would be impact hazards, or what OSHA calls “Struck-By Hazards” (though, there is a fine line between struck-by and caught between – for instance, being hit by a forklift would be struck-by, while being pinned between a forklift and a wall would be a caught-between).  We know that powered vehicles pose a great risk, but so does product that’s being moved around and stacked up.  Poorly wrapped pallets, product stacked too high, and awkward shaped/weighted material increases the chance of having an incident. Aside from training your operators to stack material properly and drive safely, the most effective means of protection is to physically keep people away from areas that could be hazardous.

Various products exist that help to keep your machines and your people from any unwanted meetings with each other.  Bollards, for instance, are great for protecting an area from forklift entry while still allowing easy pedestrian access.  A battery charging station would be a great example of where you might want to use these.  You can set them close enough to the chargers to allow you to get the forklift where it needs to be, but still eliminate a collision with the equipment.  Meanwhile, your personnel can still get to the chargers without having to climb over anything or go around any significant distance.

For areas where you don’t necessarily need pedestrian access, there are other impact barriers available that resemble more of a sturdy fencing system.  These are great for use along pedestrian walkways where you don’t want a break in the protection. 

Sometimes, a change in operation leads to the need to protect an area you weren’t considering when designing your warehouse layout.  Luckily, products like this “Kwik Kit” are available.  Quick and easy to set up, these types of systems can be configured to whatever you need.  Whether a temporary work area to accommodate seasonal business or a new process that will be around for a while, one of these kits can be quickly assembled for fast, easy protection.

Fall Protection

Fall protection isn’t something that necessarily comes to mind when you’re first discussing warehouse safety hazards, but just like anywhere else, fall hazards exist.  Keep in mind, since warehousing and maintenance work fall under OSHA’s General Industry standards, all it takes is an exposure to a 4’ drop to require fall protection.  Warehouses that have mezzanines are especially susceptible to this.  Sure, a simple railing protects the edge, but what do you do when you need to get material up to that level? 
Unless you have the capability to drop pallets in over a railing, you are going to need to have a gate.  And, what happens when that gate opens?  Fall hazard.  Unfortunately, this fall hazard is often overlooked or ignored.  Standing behind a railing waiting for a load does nothing when there’s a break in the railing inches away.  One option is to ensure that all of your personnel on the mezzanine are tied-off whenever the gate is open, but this allows for human error.  A better option is to consider installing gates that don’t allow for exposure.  This method eliminates your personnel “forgetting” to tie-off, choosing a bad anchor point, or not properly inspecting their equipment.

Fire Hazards

Besides the storage of material that could be flammable, the very existence of powered equipment brings in a potential fire hazard (not to mention an atmospheric hazard if you’re using gas, diesel, or propane fueled machines).  It is important to ensure that your sprinkler systems are tested as required, that you are not stacking material too close to the sprinklers, that you are not stacking empty pallets too high (in many cases, a stack of empty pallets more than 6’ high could burn too hot for a sprinkler system to put out), and that you have enough fire extinguishers throughout your facility that are properly inspected and maintained.

Conclusion

While, for the most part, warehouse hazards tend to be similar in nature, where and how they happen can be as varied as the different types of product you store.  Evaluating your situation is critical before you begin operations, but if you haven’t done a thorough evaluation yet, now is the time to do it.  Remember, a good pedestrian in a warehouse walks cautiously, ensures operators know where they are at all times, sticks to designated walkways, and pays attention to mirrors mounted at blind corners.  The only problem is that not all pedestrians are good pedestrians.  Don’t leave safety to chance.  Evaluate, plan, implement, and review so that you can ensure the well-being of not only your employees, but everybody that sets foot in your facility.

5 Ways to Effectively Use Your Safety Budget

5 Ways to Effectively Use Your Safety Budget

Sometimes you may have the luxury of working for a company that says, “Safety? Whatever you need, you get.”  However, that is certainly not always the case.  More often than not, you will need to work within a budget to meet your safety needs.  While it’s nice to say that safety is of the utmost importance, therefore cost should never matter, the reality is that a company is in business to make money and if they’re not doing that, they won’t be around for very long.

When faced with the idea of meeting a budget, it’s important that you plan well to avoid being out of funds when something critical arises. Sure, you could try to “wing it”, and as long as you hit no major hiccups you could be fine, but if you misstep, the results could be disastrous.

Plan Ahead

As you have probably guessed, I’m not the biggest fan of the “wing it” methodology.  My suggestion?  Plan ahead.  There are a number of things you will easily know a year out.  For example, which training courses are you required to provide to your employees annually?  What medical surveillance needs to occur each year?  What PPE do you need to keep in stock?  What subscriptions and dues are you required to maintain?

Answering these questions could give you a good foundation for what you intend to spend over the upcoming year.  Keep in mind, though, that you’ll need to figure in turnover or expansion.  If you account for training based on the current size of your company, but your company intends to increase the workforce by 25% over the course of the year, you are going to fall short.  In the same scenario, if you based your PPE needs on the averages of the prior few years when your workforce was smaller, your numbers aren’t going to work.  It’s important to know the company’s plans and how they will affect yours.

All that being said, you can never account for every possibility, but you can use all of the information available to you to come up with a sound estimate.

Training

There are a number of ways to satisfy your training requirements for the year, the most cost-effective of which would be for you to handle training internally.  First, though, you need to ask yourself if this is feasible.  Are you, or is somebody in your company, qualified to teach your employees what is necessary?  Perhaps you can teach Hazard Communication just fine, but need to bring somebody in to do your Hazardous Waste Operations and Emergency Response courses.  If so, you’ll need to account for the 3rd-party trainer in your budget.  Is your budget tight?  Maybe you want to look at some online training (Side Note: I personally believe that online training cannot compare to real-world training and the interaction that occurs with a qualified, experienced instructor, but online training certainly can serve a purpose when you have financial restrictions). 

If money is a concern, it doesn’t hurt to weigh the cost of taking a train-the-trainer cost (for instance, for such things as First Aid/CPR/AED or the OSHA Outreach 10 and 30 Hour courses) versus bringing somebody in.  When making this decision, though, you also need to factor in the value of your time.  How much training will you be doing?  How invasive will it be into the rest of what you are trying to accomplish?  Is it better to be in the field and office concerning yourself with other issues while your employees cycle through classes with a third party trainer?  In other words, if you are tied up in training, does that prevent other important things from getting done?

Purchasing

There are definitely tricks to stretching your budget when it comes to purchasing PPE and other equipment.  In my opinion, skimping on quality isn’t one of them.  Look, a $30 full-body harness that meets ANSI requirements is going to, by definition, perform exactly the same as a $250 full-body harness that meets ANSI requirements, but there’s a reason for the price difference.  Whether it’s comfort, additional functionality, or some other reason, you’re sacrificing something to pay the lower price.  And, if it’s comfort, you’ve just made enforcement 1000x harder.  That’s not to say you need to spend $250 per harness, but make sure you know what you’re getting before you purchase.  Also, the key above is that they both meet ANSI standards.  Don’t be fooled by junk that makes its way to market.  Look for the ANSI standard numbers listed on the label or stamped into the equipment.

If you have the opportunity to buy in bulk, do it.  You will receive discounts.  However, even if you can’t buy in bulk, getting a representative with a supplier will often result in getting prices you can’t get off the website or in a store.

Wants vs. Needs

At some point, you have to determine what you want versus what you need and they definitely aren’t always the same.  Again, we’d all like to think that safety budgets should be unlimited but we need to work within the resources available to us.  Perhaps you’ve always splurged on fancy brand-name safety glasses that run you $10-$15/pair.  Well, it could be time to drop that down a notch, especially since you can probably find similar ones for less than $5/pair.   Do you turn every safety meeting into a two-day affair with breakfast and lunch?  Perhaps you need to look at if that is necessary.  Sure, we all want to keep our employees happy, but if you’re pressed for money, then maybe requiring students to bring lunch isn’t the end of the world or perhaps there’s just a less expensive way to feed them, rather than eliminating food altogether.

Efficiency Tools

There are many tools out there now that can help make you much more efficient in your work.  While you may look at some of them as an extra expense, what does it save you in your time or in money that bleeds out unnoticed because it’s in drips and drabs?  One example is an online SDS service.  Sure, you have to pay for a subscription, but how much time are you spending trying to make sure that you always have the most up-to-date SDS?  Most online services push new versions out to you as they become available.  And, if you’re not spending much time doing it, is your SDS book compliant?  Is it current?  Tools like this can make you more efficient, saving your company money. 

Training tracking software is another tool that may have some up-front costs but can save you a ton of time down the road.  If you’re using simple spreadsheets, not only do you have to spend time maintaining them, but you need to manually search to see who needs training refreshers and doing that way makes it easy to miss things.  Make sure you know what tools and technology are available to you so that your time and energy isn’t spent in the wrong places.

Conclusion

Budgets aren’t easy, and they certainly aren’t as much fun as being able to spend what you want when you want, but there’s no denying they’re a necessary evil.  Don’t go into them blind. Research, prioritize, and plan ahead.  You don’t always need more dollars, you just need to be able to get more out of the ones you already have.


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