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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.

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?


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.


The Hierarchy of Controls, Part Four: Personal Protective Equipment

The Hierarchy of Controls: Part Four

Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with.  Why?  Well, PPE is quick, easy, often less expensive than other options, and readily available.  What you might not realize, though, is that PPE is what OSHA considers to be a “last resort”.  When it comes to the Hierarchy, PPE is supposed to be used either a) while other controls are being implemented, b) in conjunction with other controls or c) when all other options have been exhausted.  In other words, a full body harness should not be your go-to fall protection solution. Yet, so many companies turn to PPE first.

Personal Protective Equipment really is exactly what the name implies: protection you use personally.  So, while a personal fall arrest system is considered PPE, a guardrail is not.  While a respirator is considered PPE, ventilation is not.  PPE includes most things required to be worn on the job, such as earplugs or other forms of hearing protection, hardhats, safety glasses or goggles, face shields, gloves, coveralls, steel or reinforced-toe boots, reflective vests, and so much more.  PPE is so prevalent among the workforce that you’d think injuries would be virtually non-existent, but they’re not.  Why?

Insufficient / Wrong PPE

PPE sometimes gets thrown at a hazard without really evaluating the situation.  Hearing protection is great, but does it do the necessary job?  Ear plugs are rated for noise reduction, so how do you know that grabbing that pack of earplugs out of the jar in the office will reduce the noise below acceptable levels?  Has a noise survey been performed?  If so, was the equipment selected based on that survey?  Or in terms of respiratory protection, has anybody determined what the dust in the air is composed of before deciding to buy a cheap box of dust masks?  Even if you know what the dust is made of, has anybody sampled to determine the levels to which your employees are being exposed?  PPE is not a game of guesswork, though it might seem that way if you were to wander into various workplaces throughout the United States.  Careful consideration needs to be taken to determine what PPE is appropriate to protect your employees from workplace hazards

PPE is Not Properly Cared For / Used

PPE is only as good as the user.  Safety glasses offer no eye protection if they are constantly left on top of the user’s hardhat.  A reflective vest offers no visibility if the user throws a coat over it when he or she is cold.  A respirator may do more harm than good if hazardous dust is allowed to accumulate on the inside of it and it is not properly cleaned.  A full body harness, rather than save your life, could cause serious internal damage and other bodily harm if it’s not worn properly.  Using PPE as a hazard control includes using it properly, maintaining it properly, and caring for it properly.  Harnesses are supposed to be kept hung in a cool, dry place, yet how many do you see lying around a jobsite or in the back of a truck exposed to sunlight (UV decay), rain, freezing temperatures, and more?  When that harness fails, is it because it was the wrong equipment?  No.  It wasn’t properly cared for.  Respirators should have change out schedules depending on the filters you are using and exposures your employees have.  Does your plan have one?  If not, how do your employees know when to get new cartridges.  Do they know to get new cartridges?  And can a user even use equipment properly if they don’t know if it should even be used in the first place?  Are your employees inspecting their PPE or are they just pulling it out of the toolbox and going to work?  How will they know if something has gone wrong if you do not have them doing inspections?  You can’t throw PPE at a problem and expect it’s going to help without the proper preparations.

Training

Which brings us to our next point: training.  How do you expect your employees to know how to properly inspect, use and care for their equipment?  If you don’t train them, there’s a good chance they may barely be able to figure out how to put a harness on, let alone how to put it on properly.  If you don’t train them, they could be using a respirator with cartridges that have broken through, but they have no idea because the hazard is not one they can smell or taste.  They may be using ear plugs that should do the trick, but have been inserted improperly.  You can’t assume people will just know what to do.  Not only is training a good idea, but it’s required by OSHA.  Take the time necessary to ensure your employees are able to keep themselves safe.  You don’t need to do an eight-hour training to show employees how to wear earplugs, but you do need to do some training. 
The Hierarchy of Controls is a phrase used often in the safety and industrial hygiene world.  If you weren’t familiar with it before this series, hopefully now you’re better informed.  Of course, now that you know what it is, there’s still a lot of work to do: you still need to investigate your hazards, you still need to determine what the best possible control is, you still need to design and implement that control, and you still need to train your employees.  A breakdown at any step could cause failure.  And, when human lives are at stake, failure is unacceptable. 

 


The Hierarchy of Controls, Part Three: Administrative Controls

The Hierarchy of Controls: Part Three

In the first two articles on the Hierarchy of Controls, we discussed controls that were intended to mitigate hazards at their source either through elimination, substitution, or an engineering solution that made it so the employee was no longer exposed.  With administrative controls, we take a little bit of a turn from that approach. At this point in the hierarchy, the reality is that the hazard is one that must be – or can be – lived with, so long as certain precautions are taken or certain levels of exposure are not exceeded.  Administrative controls, which may be used in conjunction with engineering controls and/or PPE, would also be required if work was to continue while engineering controls are being developed.  Ultimately, though, administrative controls are not the optimal solution and cannot be the selected method of abatement if a hazard, or employee exposure to that hazard, can be eliminated.

Examples of administrative controls are fairly simple: warning alarms, for example, are just that – alarms that let you know when something isn’t right.  An alarm might notify you of something as common as a guard being left open on a machine in a manufacturing process or it might be on the rotating structure of a crane working near power lines that could not be de-energized, to let you know you cannot swing any further.  Obviously, neither of these by themselves would eliminate a hazard, but they would provide an employee with a warning.  A more effective approach for the guard would be an engineering control: to have an interlock that prevented the machine from running when the guard was open. Without it, an employee could ignore the alarm and reach into the machine.  For the crane, the alarm would not prevent the crane from swinging closer to the power lines.  Instead, you are relying on the operator to heed the warning.

Labeling systems would also be considered administrative controls.  We see safety labels everywhere, but clearly they are not sufficient to protect workers.  Labels are often used along with other controls to keep employees safe.  Warning of high voltage, a certain chemical in use, or that an area is a high-noise area, among many other things, labels act as a good reminder for workers not to enter areas in which they do not belong, to follow certain procedures, or to wear certain PPE.  They, alone, will not protect a soul if they are not heeded by the employees.

This brings us to another form of administrative control: training.  You can put as many engineering controls in place as you want, you can require PPE, you can warn of hazards in an area, but if you don’t train your employees how to comply with the safety requirements, controls can still be bypassed.  Somebody who is not trained on the dangers of entering a high noise area may think it’s really not that big of a deal, for instance.  Perhaps you’ve substituted a non-silica product for sand in your sandblasting operations, but you still need sand in your facility for other applications.  If you don’t train your employees on the hazards of silica as well as what your new procedure is, how will they know to use the safer product (or why will they bother if they can’t find any, but sand is readily available)?  You may not have realized that training was an administrative control, but hopefully you’ve been using it all along.

One final method that needs to be discussed is a little more on the complicated side, compared to other administrative controls.  Reducing the amount of time somebody is exposed to a hazard can be an effective control, but it’s not as simple as placing a sign or adding a warning alarm.  For instance, hazards like noise and chemical exposure are often given permissible exposure limits (PELs) by OSHA that are measured in time-weighted averages (TWAs).  So for instance, Carbon Monoxide (CO) has a PEL of 50 parts per million (ppm).  This does not mean that the moment somebody is exposed to Carbon Monoxide in an amount greater than 50 ppm they are going to die, it just means that when you average out the amount an employee is exposed to over the course of an eight-hour day, it needs to be below 50 ppm.  There are also Short-Term Exposure Limits (STELs) and Action Levels (ALs) to be concerned with, and though we can see that determining an allowed exposure time might be a bit involved, we’d need more room/time than this article allows to go into detail on it.  Suffice it to say, as long as employee rotation through a job can keep the employee under all applicable limits, then it is an acceptable solution. While CO has a limit, in many cases, employers would find the source of emission and eliminate it because CO is much too dangerous.  A more common application of controlling exposure time might be in a high noise area or a hot work area.  By rotating other workers into these areas throughout the day or by simply putting a cap on the amount of time spent in them, workers can be kept below the allowable exposures for noise or heat.

Administrative controls can be simple, but remember, they are often not the best or sole solution.  Using administrative controls should almost always be looked at in the context of other controls that are being put in place to determine how they can be paired to provide employees with the best actual protection possible.  Now, with elimination, substitution, engineering controls, and administrative controls covered, we are left with one final level of the hierarchy in the next article: PPE.  Yet, if it’s the final level of the hierarchy, why is it that it is so often the first solution employers turn to?  The final article in our series will explain just that.

 


The Hierarchy of Controls, Part Two: Engineering Controls

The Hierarchy of Controls: Part Two

In the last article, we discussed the first level of control when it comes to protecting employees from recognized hazards: elimination or substitution.  The concept, while possibly difficult to implement, was simple to understand.  Unfortunately, this second step, engineering controls, is often more difficult in both concept and implementation.  (Note: there seem to be two schools of thought on this hierarchy or controls.  One is that substitution and elimination fall under engineering controls and the other is that they are separate.  For the purpose of this article series, we’ve chosen to separate them into different categories.)

Engineering controls, to put it as succinctly as possible, are methods designed to get as close to eliminating the hazard as possible, without actually eliminating it.  This is done by designing something into the facility, the piece of equipment, or the procedures themselves to reduce the hazard or the employee’s exposure to it.  As long as they are designed properly (and used by employees properly) they tend to be very reliable.

An example of an engineering control is isolating a hazardous portion of the process.  In manufacturing, for instance, a part of the process may be spray painting parts.  This task poses both health and ignition concerns.  In order to isolate the hazard, many manufacturers would utilize a spray booth.  The booth prevents the worker from inhaling the paint fumes and paint residue while also reducing the risk of explosions and fires.  A glove box for handling hazardous materials and chemicals is another example of isolation as the box allows the employee to do the work while not being exposed to the material/chemical.

A process change is also considered an engineering control.  This control is common (though maybe not common enough) when dealing with silica.  Using water to suppress concrete dust or a HEPA-filtered vacuum attachment to remove the dust from the air are not only good controls, they are – in ways – integrated right into the new silica standard.  Automating the hazardous work so that no employee has to be exposed is another example of a change in process.

Another option is ventilation, the most effective of which is local exhaust.  Local exhaust removes the hazard (in this case, a fume, gas, vapor, or dust) at its source, while general ventilation allows the hazard into the work area as it’s diluted to an acceptable level or as it’s pulled or pushed (depending on whether it’s a positive or negative pressure system) into an exhaust duct, door or window.  Dilution methods are really only able to be used in very low toxicity situations where employees are able to maintain a safe distance from the source.  General ventilation can be costly as large amounts of air need to be moved in larger spaces and that air often needs to be temperature controlled to keep the workplace comfortable.

Often, an engineering control doesn’t exist in a vacuum.  Some need to be used in conjunction with other controls, such as personal protective equipment, to ensure they are used and working properly.  Training is always required because no system is human-proof. In fact, engineering controls are definitely not a one-size-fits-all solution.  Before one is selected, it’s necessary to look at a number of factors.  How easy is it to use?  Your employees are going to be expected to use it properly.  An over-complicated system could greatly increase the possibility of human error or, worse yet, the possibility that your employees choose to attempt to bypass the system.  How reliable is it?  Engineering controls need to have a practically perfect rate of success.  If they don’t, not only are your employees not protected, but they may be operating under a false sense of security.   How much does it cost?  Yes, as safety professionals we like to think it’s “protect the employees, no matter the cost!” but in the end, employers do still exist to make a profit.  That’s not to say that a company will not implement necessary controls, but they’re not going to be happy if they spend a fortune on one solution only to discover that there is a cheaper and equally effective solution available.  Do your homework before selecting any one option.

Engineering controls are your best option when the hazard cannot be eliminated.  Ensure the safety of your employees by selecting/designing the proper solution and then train your people so that the control works as intended.  If the possibility of substitution, elimination, or engineering controls all fail – or if you simply as desire additional protection – administrative controls will be the next step.


The Hierarchy of Controls, Part One: Elimination and Substitution

The Heirarchy of Controls: Part One


If you’re a safety professional, it’s been ingrained in you since you were in diapers sitting through your first OSHA 30 hr. How many times have you caught yourself in a conference room shouting, “But don’t you understand?? PPE is a last resort!”?  Countless, I’d imagine, but the problem is that PPE is what people know.  PPE is easy and readily available.  Ask somebody what engineering or administrative controls they could have used to abate a hazard and they’ll look at you like you’re still wearing diapers (that is, assuming you’re not).

For those unfamiliar with the hierarchy of controls, a tiered approach to solving problems might seem alien.  Even for the initiated, some aspects of the hierarchy can be confusing.  So, rather than just tell you what the hierarchy is at face value, let’s take a more in-depth look at each level, starting with two of the easier concepts: elimination and substitution.

Elimination

The concept of elimination is easy, because it’s as simple as it sounds.  Take the hazard that your employees face and eliminate it. Done, piece of cake.

Right?

Maybe not.  The problem with elimination is that if the implementation of it was as simple as it sounds, everybody would be doing it, wouldn’t they?  What company would not choose to completely eliminate the chance of their employees getting hurt if doing so was simple?  Not many, I’d venture.  In fact, according to the hierarchy of controls, if Elimination is available to an employer, it is the option they must choose.  Remember, the employer has a duty to provide a workplace free of hazards to their employees.  If the employer is able to do that, but chooses not to, they could be looking at a Willful violation, should an OSHA inspection occur (not to mention employee injuries and fatalities that might occur due to your failure to remove the hazard).

If we are talking about elimination in terms of equipment or materials, such as removing some flammable gas containers from an area where hot work is being performed or eliminating an unnecessary blade on a machine, the solution should be 100% effective, as long as there isn’t a communication breakdown that allows somebody else to reintroduce the hazard back into the workplace or process.

Substitution

Again, this is pretty much what it sounds like.  With substitution, we are identifying a hazardous substance or piece of equipment and substituting a substance or piece of equipment that is not hazardous.  For instance, instead of a solvent-based paint, use a water-based paint.  Instead of sand-blasting, use a non-silica containing abrasive material.  If an alternative product exists on the market, substitution can be a very effective solution.

Except, there’s a reason why the hazardous versions still exist.  If the substitutions were perfect, they’d force the hazardous substances off the market.  So why don’t they?  Well, the downfalls of substitutions tend to usually be quality and cost.  Let’s take the paint example.  Paint used to be almost exclusively solvent based, but solvent based paints are high in VOCs (volatile organic compounds).  Over time, as VOCs were required to be reduced in solvent-based paints, other paints came on the market, such as water-based.  Early on, the quality of water-based paints was inferior to solvent based, so some companies probably continued to stick with the solvent-based to ensure a better job.  Unfortunately, something like that leaves a stigma and many people probably still believe to this day that solvent-based paints are superior despite the fact that with current technology, many water-based paints are not only equal to solvent-based but superior to.

Regardless of quality, though, cost can still be prohibitive.  Oftentimes, the production of a synthetic material costs more than the acquisition of a natural one, demand for the less hazardous version drives up its cost, or any other number of reasons that make the alternatives more expensive.  It’s this industry’s equivalent of why a grilled chicken salad costs $9.99 and a burger costs $5.  Cheaper usually does not mean better for you.

The other downfall to substitution is just because a material does not pose the same hazard as the one you’re replacing, does not mean it doesn’t pose a hazard at all.  An employer needs to do the necessary research to ensure that they are not replacing one hazard with another.

Elimination and substitution are not only great ways to abate hazards, but need to be your preferred way.  In other words, engineering controls, administrative controls, and PPE should not even come into the discussion until elimination and substitution have been ruled out (except in the case where PPE use is required at all times, like a 100% safety glasses policy).  Take the time to look at some of the solutions your company has come up with for the hazards in your workplace.  Are there situations where elimination or substitution could have been used?  You may be surprised how often your answer is “Yes.”

After you’ve done that, keep your eyes open and come back for our next article which will discuss what is meant by “engineering controls”.


Anatomy of a Fall

Anatomy Of a Fall


Anybody that comes in even the briefest of contact with the world of occupational safety knows that fall protection is a hot topic. There are blogs, social media groups, and even entire companies dedicated to it. While some topics are treated as an elective within an OSHA 10 or 30-hour course, fall protection is one that is required and it’s for good reason. Falls have been at or near the top of the list for occupational fatalities and at the top of the list for construction fatalities for years. Rather than getting better over time, the number of fatalities due to a fall is rising. According to the Bureau of Labor Statistic’s most recent data, occupational fatalities due to a fall to a lower level rose 11% from 2013 to 2014. Why do falls remain this great, mysterious thing? If workers truly understood where and why they happen, or what could be done to prevent them, we’d have no falls at all, right? Maybe understanding the fall itself can help prevent them. So let’s look at one step-by-step.

Prior to the Fall

Morning meetings have been held, tasks assigned, equipment distributed, and work is proceeding as usual. It’s during this time, however, that a bad decision is made. It’s at this point that you choose to climb to an elevated work area that is not guarded and do so without your personal fall arrest system. Maybe you aren’t trained in fall protection and either a) don’t know you’re supposed to have fall protection or b) are unsure of how to properly use it.  Perhaps management personnel knew that proper precautions weren’t in place, but put production ahead of safety. Perhaps, you actually brought your harness and lanyard but didn’t bother to hook up to the anchor point. Falls happen due to a lack of planning more than anything else.

At The Moment of The Fall

If you talk to people who don’t feel it necessary to use fall protection while working at heights, you’ll hear such things as, “I have very good balance,” or, “I have good reaction time; if I was going to fall I’d catch myself.” Agility and fast reactions aren’t enough however, as losing your balance often has nothing to do with a fall. Sometimes a platform gives way, or you’re struck by a falling object which knocks you unconscious. Sometimes you pass out or get lightheaded from a sudden drop in blood sugar due to a medical condition – maybe even a medical condition you did not know about. Sometimes a sudden gust of wind picks up and blows somebody clear off a roof. The fact of the matter is, balance means nothing against the forces of nature or a 5000 pound suspended load that went astray. Balance  won’t save you when, in reality, the moment of fall was probably one that you never saw coming.

If you can’t see something coming, how do you react? How do you “catch yourself”? Sure, maybe if you felt yourself losing your balance you could grab onto something to steady yourself. That’s obviously possible, but what if you just outright fell? What if you got knocked off a platform? The fact of the matter is that you’ve fallen 6’ in the blink of an eye and there’s nothing you’re going to be able to do to stop yourself.

The Impact

Let’s face it, the results of impact aren’t pretty. If they were, falls would not result in fatalities as often as they do. If you are “lucky” enough to survive a fall, you could be facing medical issues for the rest of your life. Not only can a fall break bones, it can rupture internal organs, cause severe concussions or another brain injury, and result in paralysis, a coma, or other permanent disabilities. And you don’t need to fall ten stories for this to be the case. According to one NIOSH study, more than 25% of all fatalities were the result of a 6 to 10-foot fall from a ladder. Make no mistake, other than the very rarest of exceptions, getting up and walking away unharmed from a significant fall is the stuff of action movies and cartoons.

The Aftermath

The immediate aftermath of a fall is chaotic and intense: people scrambling to call 911, others rushing to your aid, and still others are frozen in disbelief, panic, or shock. People are most likely not thinking clearly and may be putting themselves or others in danger while reacting to what just happened. Machine operators may leave equipment unattended, friends and co-workers rush through or into unsafe areas to get to you, some people may even be putting themselves in the same fall exposure you just had trying to get a glimpse of what happened to you.  Shortly after that, there’s the notification to your family and whether the fall was fatal or not. This is an extremely trying experience for both your family and the person tasked with making the call. Your spouse and children, your parents, your siblings, and your friends will be devastated. Counseling will be needed for many of them as well as co-workers. Those that witnessed the event may be traumatized and may never be able to return to that job themselves. For survivors, falls are life changing. If you’re able to work at all, you may never be able to work in your field again. Psychological issues are prevalent. Marriages fall apart. A fall affects so much more than just the physical well-being of the person involved.

In a fall, the moment of impact may seem like the end, but it’s really just the beginning. The fall may have involved just one person at first, but by the time it’s over dozens are affected. However, falls are preventable. There needs to be a willingness to plan in order to make sure the selected fall protection solution is appropriate. There needs to be a willingness to learn so an employee can ensure they know how to inspect their equipment and use it properly. There needs to be a willingness to do what’s right, even when it’s not the cheapest or quickest way to get things done. Given all that, maybe then, hundreds of lives a year won’t be lost on the job to fatal falls. Maybe then, hundreds of more people won’t have their lives shattered each year by the loss or debilitation of a loved one. Maybe then, the number of fall incidents will finally begin to decline.


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