By now, you may have heard: OSHA issued a new final rule in regards to electronic recordkeeping. Great! What the heck does that mean?
Well, funny you should ask, because I’ve got answers!
Just the Facts
Let’s start with the basics. The final rule was issued by OSHA on May 12, 2016 and will require certain employers to electronically submit their injury and illness data (300, 300a, and 301 forms) to the Agency annually (before these were only collected through an inspection, a survey, or when things like fatalities and hospitalizations required employers to notify OSHA).
Those required will be:
- Companies with 250* or more employees who are otherwise already required to keep these records.
- Companies with 20 to 249* employees in “certain industries”. This is primarily industries OSHA deems highly hazardous such as utilities, construction, manufacturing, retail, transportation, and health care.
- Other companies upon OSHA request.
*When determining your number of employees, you must include part time, seasonal, and temporary workers.
These requirements will phase-in beginning in July 2017 and will be fully implemented by March 2019.
In addition, the new rule includes new protections for employees against retaliation and will require OSHA to scrutinize incentive programs and post-accident drug/alcohol screening to ensure they don’t discourage reporting of illness and injuries.
In terms of anti-retaliation measures, employers must notify employees that they have a right to report work-related injuries and illnesses, that they will not be discharge or discriminate against for reporting them, and the employer is prohibited by law from discharging or discriminating against somebody for reporting a work-related illness or injury (effective August 16, 2016. While OSHA has had this in their purview for some time, the new rule allows OSHA to bring action even without an employee complaint of retaliation, which was previously required in order to begin an investigation).
As for discouraging employees to report, incentive programs must not punish an employee in any way for reporting an injury/illness. For example, if a monthly safety bonus is given, and an employee is not eligible if they have an OSHA recordable incident, OSHA may consider this retaliatory and/or a means to discourage an employee from reporting their illness or injury. In addition, blanket post-incident drug/alcohol testing will not be possible. While OSHA will still allow “for cause” testing and testing mandated by a government agency (i.e. – the DOT), the company is going to have to show that requiring drug/alcohol testing in any other instance was reasonable. For instance, if somebody gets a splinter that gets infected, they may not consider testing reasonable while if an employee swerved and crashed a company vehicle, they may.
What are the Consequences?
One major concern is that the reason many companies instituted blanket post-incident drug/alcohol testing was to eliminate any possibility of a false discrimination claim. The prohibition of this type of policy seems to open that back up. In addition, the National Law Review cited four consequences of this rule in a recent article they published. To paraphrase:
1 – Information will be used to identify new bad actors. Those reporting higher than normal injury and illness rates can expect their chances of inspection to dramatically increase.
2 – Electronic submission opens the door for data breaches and hackers. Personal information of injured employees could be vulnerable prior to the agency scrubbing that information from the files.
3 – This information will be made public, so companies could be negatively affected by this before they have a chance to defend themselves.
4 – The information will be made public, so may be used as a tool for unions to find companies whose workforce may be more interested in unionization.
5 – It’s a new weapon OSHA didn’t have before – the ability to cite any company reporting policy/procedure for being “unreasonable”.
This is now the law and, while it will take some time to fully implement, you can begin notifying and training your employees now. In addition, it’s probably time to review your incentive programs and drug/alcohol testing policies. Don’t let this catch you off guard. You know it’s coming, so make sure you don’t leave your company vulnerable to non-compliance.
Click here for more OSHA information.
So, you’ve decided to buy a Safety Gate! Great! But you know it’s never that easy. As with any other purchase, there are questions to be answered and options to be selected. Gates, while effective, convenient, relatively inexpensive, and easy-to install, are not one-size fits all. Yes, many gates can each be attached in a variety of locations, but it’s not the size of the connection that is the issue, but rather the actual function for which the gate is needed. Let’s take a look at some of the questions you will need to answer prior to your purchase and see how the gate’s function plays into your decision-making process.
1. Why are you Installing This Gate?
You are going to need to start with the basics, and the most basic of all questions is “Why?” Why are you installing this gate? What purpose will it serve? Who will use it? Have you had problems before that have led you to this decision? Are there safety regulations that require its use? Your answer may be simple or it may be complicated, but whichever it is, it is going to help you make the proper decision.
Some of the reasons you may be installing a gate could be to control access, as a warning of an upcoming hazard, or as fall protection. Different applications will mean different gates. The difference can be something as simple as the direction in which the door swings or if there is some type of lock on the gate. Gates used for fall protection will need to be a specific height to meet the standards and must be as strong as railings are required to be. Hash out your needs before deciding what to buy.
2. Where is the Opening Located?
Where your gate will be installed will play a big part in deciding what material your gate will be made of. An indoor gate, for instance, could be made of steel and last a long time, as long as you’re not in a humid environment or an industrial environment that could expose the gate to other corrosive materials. Using it outdoors, however, could be a problem because rain and ambient humidity could cause steel to rust. Your best options for an outdoor gate will be aluminum, galvanized steel, or stainless steel. All will be corrosion resistant, with the steel options being stronger – and heavier – than the aluminum option. Galvanized is probably the most economical way to go and will achieve the same corrosion protection.
3. How Big is Your Opening?
There are different sized gates for different applications. If you are simply setting it up for single person access to a ladder, then you might need an 18” or 21” gate. If you want a two person gate, you’ll obviously need a wider one. But the options don’t stop there. You could want a mezzanine or pallet gate. These are not only a wider design, but pallet gates are configured in such a way that when opened, the pallet itself is protecting the opening. All of the gates, when finished, return automatically to their original position, whether they be vertical sliding gates, horizontal, or swing gates.
4. How Much Use Will the Area Get?
The use could determine the type of gate you want. Heavy use could call for an automatic gate that doesn’t require your employees to push it open every time they pass through. Something used less frequently may not warrant this. Either way, the important thing is to ensure your gate has been cycle tested to the ANSI standard. ANSI BS 6375-2:2009 Clause 6.5 says that a gate should be tested through 90 degrees 50,000 cycles.
5. Do You Have Industry Requirements?
While OSHA does not necessarily require safety gates to be yellow, you’re going to want them to be highly visible. If it blends into the background, it can be just as dangerous as not being there. However, depending on your industry, there could be other requirements. For instance, the food industry may be required by the FDA to have stainless steel only. It is important that you know this so that in attempting to bring yourself into fall protection compliance with OSHA, you do not take yourself out of compliance with any other regulatory body you may be beholden to.
6. Who is Doing the Install?
Safety gates may be fairly simple to install, depending on where they are being installed, but you want to make sure the person doing so is competent. Lives could depend on it. Know that if you are planning on having somebody in-house install the gates, your supplier will often offer tutorial videos or other forms of instruction to provide all the help you need. If you are even remotely unsure of your installer’s competency, pay the extra money to have it done by a professional. Don’t take chances with your employees’ lives.
7. Has it Been Tested?
In addition to cycle testing, OSHA requires that gates meet certain load requirements. You can’t assume that just because a gate is made of steel that it will meet the requirements. Springs, hinges, and stoppers could all be potential points of failure if the gate is not tested. Do not assume just because a product is commercially offered, either, that it has been tested. Ask to see the proof of testing. A manufacturer should have no problem providing this testing, as Kee Safety does in this document.
While many safety gates might look the same, there could be some key differences. Use this list to help you determine what you need so you can provide the safest working environment for your employees. Gates can be simple, yet effective safety tools. Don’t let the selection of the wrong one be the cause of a tragedy you were trying to protect against.
Take a look around the neighborhood you live in. How many fences do you see? Probably quite a few, right? And, where you see fences, how many have no gates? I would venture to guess that the answer is “very few if any.” That’s because a fence is put up for a reason: to keep animals and/or people either in your yard or out of your yard. Without a gate, the fence cannot truly serve its purpose. And yet, on jobsites across America, railing after railing is erected to protect workers from falling – on roofs, on scaffolds, on all types of elevated work areas - without any mechanism to protect those same workers at the edge or floor opening from which they are accessing that work area. Why? How can railings be effective if they don’t offer complete protection? What good does a perimeter railing do if a worker can fall through the hole in which their ladder is situated?
Safety gates have been around for a long time, but for a variety of reasons, they are often not used. Sometimes it’s a lack of planning, other times it is lack of knowledge of product availability, and other times maybe it’s cost (though, if you’re spending the money to build or purchase a rail, the addition of a gate is minimal cost-wise). Whatever the reason, workers are being left unprotected and, worse yet, being given a false sense of security.
So what does OSHA say on the topic of Safety Gates. Are they required? Well, not outright. Let’s remember that OSHA rarely, if ever specifies how you must abate a hazard. What the regulations will say is that if you choose to solve it via method x or method y, then here are the requirements that method x or method y must meet. For example, OSHA provides regulations stating what criteria fall protection equipment must meet, but at no time does OSHA state that you MUST use rails, or nets, or personal fall arrest systems. The same applies here. OSHA doesn’t say you MUST use a gate, but gives situations in which a gate could be your solution and, if you so choose, what requirements must that gate meet.
Confused? Okay, here’s what OSHA says, for example, about guarding a ladderway floor opening or the access area to your platform:
Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
So, while OSHA is stating that these openings need to be protected by rails, they are stating that a gate is one way to protect the opening, the other being an offset. From a best practices standpoint, a physical barrier is always better than something that requires human diligence because humans make mistakes, humans get tired, humans get distracted. Keep in mind, if you decide to use the gate, it must offer equal protection to the rest of the railing. That means, top and mid-rails at the same heights and being able to withstand the same amount of force.
Another organization you should be familiar with, ANSI (the American National Standards Institute) addresses safety gates in relation to pallet drop areas. In ANSI MH 28.3-2009 section 6.4.3, a barrier is required to be in place to secure pallet drop areas at all times, even while the area is being used for handling materials. This means that a simple swing gate, sliding, gate, chain or removable railing is not acceptable. Only a dual-gate system would work in this situation because a barrier would remain in place at all times. Remember, ANSI are not regulations, they are guidelines. Often, OSHA will consider them best practice or industry accepted practices, but unless they are incorporated into the OSHA regulations by reference (or into the regulations of the state agency under whose jurisdiction you fall) they are not law. However, when a standard exists which is safer than what you are doing, it’s a good idea to do everything you can to meet that standard because in a court of law, you would need to be able to defend why you didn’t follow the recommendations of an organization as well-known, and widely referenced as ANSI, if their methods might have prevented an accident at your facility or site.
Safety gates are an easy to install, easy to use control that leaves very little room for human error. They do not hinder productivity or work quality and will help keep your employees, inspectors, contractors and visitors safe. A small investment keeps you compliant and your employees free from harm.
There are some things you can hand to somebody with no instructions and they’ll know how to use them: a pair of boots, a pair of gloves, safety glasses. A fall protection harness is not one of these things. To the untrained eye, a harness is just a jumble of straps and buckles with no semblance of reason. Wearing a harness improperly could render it ineffective, leaving the user hurt…or worse. So, how could wearing a harness get you hurt?
1. Your D-ring is in the wrong position.
Harnesses weren’t thrown together haphazardly with some straps that were laying around on a manufacturing floor. They were designed by engineers to take the forces exerted on your body in a fall and distribute them so that your fall can be safely arrested. Wearing the harness wrong will ensure that those forces do not get equally distributed and can almost guarantee that you will get hurt. When your back D-ring is in the wrong position, it is a sure sign that you are wearing the harness wrong. When you don your harness, have a partner check to see that the D-ring is situated exactly halfway between your shoulder blades. That does not mean it can just be in the center of your back – it must be in the center of your back at shoulder blade height. If you find it pulling to one side or another, you’ve overtightened one side of your harness. If you find it too high or too low, the harness may not be the correct size for you.
2. You’ve clipped your lanyard to the wrong D-ring.
Speaking of D-rings, many harness models have multiple D-rings. You may be tempted, for the sake of convenience, to attach your fall-arrest lanyard to a front or side D-ring. Don’t. Of course, those D-rings exist for a reason: positioning. Some workers need to work at heights in areas where a platform doesn’t exist (think of a utility worker up on a pole or an ironworker having to tie rebar on a pour-in-place wall). The front or side D-rings allow for the connection of a positioning lanyard, so that the worker may attach, lean back comfortably, and use both hands for their work. If you were to attach your fall arrest harness to a side or front D-ring and fall, the forces encountered in the fall would not be properly distributed, causing your body to “snap” to a stop. If that sounds painful, there’s a reason.
3. Your harness is too loose (or too tight).
A properly sized harness is not just a matter of comfort, it is a matter of life or death. Again, harnesses are designed to be used a certain way. Yes, all models are adjustable, but even those adjustments have limits. It is not okay to reach the last grommet, or pull a strap as tight or loose as it goes, and just say, “Oh, well, I guess that’s got to be good enough.” If you can’t adjust your harness to fit you, it is not the right size. Let’s look at the leg straps as a perfect example. If the leg straps are too loose, in a fall you would continue downward into them at a great force instead of you and the harness having your descent arrested together. This could cause rupturing in the place those leg straps would finally end up – right between your legs. If the straps are too tight, they could cut off circulation, causing a whole host of other problems. The rule of thumb for leg straps is that you should be able to fit a flat hand between the strap and your leg, but not a fist. Adjust your harness to the proper fit and if you can’t, get a new one.
4. Your chest strap is too high (or low).
This may sound like I’m repeating myself, but the truth is, you can be wearing a proper size harness and not adjust things correctly. The chest strap is a good example. You could adjust it to what feels like the proper width and still have it on wrong (hence, the need for training). A chest strap worn too high could choke you or injure your throat/jaw/etc. in a fall, while a chest strap worn too low could allow you to slip out of the harness if your fall were to turn into a head-first one.
5. Your straps are twisted.
Twisted straps could reduce the strength of your harness significantly. Any time you don a harness, have a second person check it to make sure they don’t see anything wrong with it and that no straps are twisted because there are places you cannot check once the harness is on. Harnesses are intended to save your life, so check, check, and re-check.
In the end, harnesses are not just some silly tool or piece of equipment that can be used without care. They are life saving devices, and it’s your life that depends on them working properly. Coincidentally, you are the only one that can ensure they work properly by using them as they are intended to be used, and by wearing them as they are designed to be worn.
In addition to proper adjustment, make sure your harness is in the right condition. Learn more about checking the condition of your safety equipment.
Back when I began in the field of safety, self-retracting lifelines (SRLs) were frowned upon by workers, not because the function wasn’t preferable, but because they were big, bulky and very heavy. Over time, things have changed. Technology has improved. And while the cumbersome clunkers still exist and have their purpose, many SRL’s have become much more portable, weighing as little as just a couple of pounds.
While early nicknames for the device, like “yo-yo” are misleading in how they function, an SRL works in much the same way a car’s seatbelt does. When a certain level of speed or force is achieved, a locking mechanism engages, arresting – in the case of the seatbelt - the forward motion of a car passenger or – in the case of the SRL - the downward motion of somebody falling. To see how this works is simple. Take your SRL and hold it in your hands. Slowly pull the cable or webbing out. If you do this slowly enough, it continues to play out until it reaches its full length. Now, let it retract. This time, snap the cable or webbing out. If you pull hard enough you will see it lock into place. Congratulations, you’ve just demonstrated how SRLs work without having to toss somebody over the side of a building!
The SRL is made up of a number of parts. The housing or casing is the part you see, for the most part. It is the plastic or metal enclosure that contains most of the parts including the locking mechanism; the drum, which is what the lifeline itself winds on to; the shaft, usually a steel rod in the center around which the drum rotates; the locking mechanism itself; the motor spring which is what keeps tension on the lifeline when played out; and the lifeline itself (with snaphook for attachment).
Used properly, an SRL should stop a fall in less than 24” if you’re using a Class A SRL. “Properly” is important, though. For instance, like most fall protection, the SRL should be anchored at the height of your harness’ D-ring or above. While some may hear “retractable” and think that the cable will pull you back if you begin to fall, this is not true. What is already played out will remain played out, so if you anchor the SRL at your feet, you are adding fall distance that can place too much force on your body. The very idea of the short arrest distance of an SRL is to keep those forces at very low, very safe levels. Using an SRL on a sloped roof could also be a problem as a fall that involves the worker slipping down the slope may not reach a high enough speed to engage the mechanism. Ensure that your SRLs are always properly installed and being used in accordance with the manufacturer’s instructions.
Maintenance is key. Allowing grease, dirt, paint, or any other material to build up on the lifeline or inside the casing could cause it to not work properly. Clean according to manufacturer’s instructions. Using the wrong type of cleaning agent could be as deadly as not maintaining the equipment. Ensure that it is stored in a cool, dry place to prevent rust, rot, and other types of material breakdown. Inspect the SRL before each use. Should an SRL be deployed in a fall, immediately remove it and all components of the personal fall arrest system from service. Before putting the SRL back into service, it would need to be recertified. Most of the time, in order for this to occur, the SRL would need to be returned to the manufacturer. However, some products exist now that allow for easy on-site recertification by a qualified, authorized person.
Research your options before purchasing fall protection. I find the SRL to be the preferable solution in situations where fall arrest is necessary because fall prevention through railings or other barriers cannot be achieved. Understanding how they work and what they do will help you to make the best decision for the safety of your employees.
Fall hazards are abundant and varied, making them difficult to protect against. Every single situation is different and employers need to work with employees to ensure that the correct solution is in place. The solutions may be easy or they may be complex, but either way, as the narrator of the opening sequence of The Six-Million Dollar Man said, “We have the technology.”
While the answer to a problem can be something like guardrails, very often employers are faced with the challenge of finding ways for their employees to “tie-off”. As they work through the process, it is important that they determine not just what the anchor point is going to be, but what type of lanyard to use. Many factors come into play when determining this, not the least of which is fall distance. But you can’t choose the proper equipment if you don’t understand the options available.
Each category could be further broken-down, but essentially there are three types of lanyards: shock-absorbing lanyards, self-retracting lanyards (or SRLs), and positioning lanyards. For the sake of this article, let’s assume that you’ve connected your lanyard – whichever type it is – properly. If, for instance, your anchor point is at your feet rather than at your D-ring or above, there is going to be a larger fall distance than what’s listed here and there will be excessive force exerted on your body.
These seem to be the most popular types, mostly because they are easy to use and it’s very obvious if they’ve been deployed or not. They are often 6 feet long and have an expansion pack on one end, or you might see the “bungee” style (though, be very aware of the fact that these are not bungee – they are not elastic and will not bounce a person back). It will not be as easy to tell if a bungee lanyard has been deployed in a fall. The expansion pack (which could be rip-stitch or glue) will expand up to another 3.5 feet in the process of slowing your descent. The same goes for the “bungee” style. The lanyard will start out at 6 feet and could be 9.5 feet after it has been deployed.
There are a couple of important things to consider when deciding on a shock absorbing lanyard. First, what is your fall distance? The link above leads to an article that shows you that you are going to need a minimum 18.5’ of clearance in order to use one of these. If you don’t have that, you need to consider other options. Second, why are you looking to arrest a fall after it has occurred, rather than stopping it from occurring in the first place?
Which leads us to our next options…
SRLs (Self-Retracting Lanyards)
To be fair, SRLs do also arrest a fall after it has occurred, however the distance in which they engage is short, leading to a maximum arrest distance (for a Class A SRL) of 24”. This is significantly different than the 3.5 feet plus the length of slack in your shock-absorbing lanyards. One of the features of an SRL is that there should be no slack since the lanyard recedes back into the casing when the tension releases. In recent years, SRLs have shrunk in size, reduced in weight, and become much more manageable than some of their predecessors. This is a great option in most fall protection situations.
These lanyards offer the least amount of flexibility. They are fixed length and are designed to keep you in place, rather than arrest a fall. You will see them in frequent use when doing rebar assembly for pour-in-place concrete walls. For some, these are the only lanyards that should be used in a boom lift. Many will argue that the forces exerted on the basket of a boom in the event of a fall while wearing a shock-absorbing lanyard or an SRL could cause a tip-over and a fixed-length positioning lanyard is the only way to go. Despite those arguments, valid or not, OSHA has not banned the use of any type of lanyard in a boom lift as long as you would be protected from striking the level below. Still, if you feel this is a concern, consider the positioning lanyard.
Even if you’ve determined which type of lanyard you are going to use, your decision doesn’t end there. Lanyards are made of various materials and not just for the fun of it. While many lanyards are nylon webbing, others are Kevlar or wire rope. Why?
- If you are performing hot work of some kind – welding, torch-cutting, burning, for example – you are going to want your lanyard to be made of a material that isn’t going to burn through when the slag hits it.
- Are you walking steel at the top of a newly constructed building? Well, the only anchor point may be at your feet. You’d better employ the use of an extended freefall lanyard which is manufactured to allow a 12’ freefall as opposed to your standard 6’ while maintaining the forces on your body below the allowed levels.
- Will there be situations in which you need to switch from one anchor point to another? If so, you may need to use a double-legged lanyard so that you are not exposing yourself to a fall when transitioning from one to the other.
There’s a reason why just saying you are going to “Tie-Off” is an insufficient answer when a safety professional asks what you are going to do for fall protection. There is no “One Size Fits All” fall protection solution. Each situation requires careful attention to detail so that the employees can be properly protected. Review your situations beforehand and come up with an agreed upon method, otherwise, there’s a chance your people in the field will grab whatever is in the nearest toolbox, regardless of whether or not it will actually protect them (if they use anything at all).
Way back in August of 2012, a new ANSI standard was released that addressed the use of retractable lifelines for personal fall arrest and in rescue situations. These self-retracting lifelines had been in use for quite some time and, as they had gotten smaller, lighter, and more inexpensive, they had also become more commonly used. ANSI’s standard – ANSI Z359.14-2012 – provided previously undeveloped guidance on performance, design, testing, markings, instructions, inspections, maintenance, storage, and remove from service of retractable lifelines. In so doing, ANSI also created two classes of retractables, which they called A and B.
Now, for the uninitiated, ANSI – the American National Standards Institute – does not write law. That is OSHA’s job. What ANSI does do, is write guidance standards for various products. From there, manufacturers tend to voluntarily adopt the standards for use in their testing (and, if a company has an incident as a result of their not meeting a published ANSI standard, OSHA will most likely want to know why they weren’t meeting the standard). Many companies will voluntarily adopt ANSI standards as “best practices” and OSHA will, eventually, incorporate many ANSI standards into the regulations by reference.
So, as noted, one of the key provisions of the Z359.14 – 2012 was that self-retracting lifelines would be divided into two categories – A and B. Which category a retractable fell into depended on the results of dynamic performance testing.
- Maximum arrest distance not to exceed 24” (610mm).
- Average arresting force not to exceed 1350 lbs (6kN) or maximum peak of 1800lbs (8kN).
- After environmental conditioning (hot, cold, wet), average arresting force not to exceed 1575 lbs (7 kN) or a maximum peak of 1800 lbs (8kN).
- Maximum arrest distance not to exceed 54” (1372 mm)
- Average arresting force not to exceed 900 lbs (4kN) or a maximum peak of 1800 lbs (8 kN).
- After environmental conditioning (hot, cold, wet), average arresting force not to exceed 1125 lbs (5 kN) or a maximum peak of 1800 lbs (8kN).
All in all, the two classes are divided by 2.5 feet of arresting distance and 450 lbs of arresting force.
What does this mean to you, the user?
The maximum arresting force probably won’t play into your planning very much. When worn with a body harness, both of these classes meet the OSHA requirement of limiting the arresting force on the human body to 1800 lbs. However, when planning your fall protection, the maximum arrest distance will figure into your fall distance calculation. Knowing which class your retractable is will allow you to use the proper value (24” or 54”) in your calculation. An extra two-and-a-half feet of stopping distance is significant. Planning for a Class A retractable when you are actually using a Class B could easily mean the difference before a fall being arrested safely and serious injury to a worker.
To make it easy, ANSI suggests that these classes should be listed on all product labels (which should be able to endure the life of the component being marked). While there’s much more to the Z359.14-2012 standard, don’t let the A and B classifications themselves confound you; they are important, but simple. Now you know the difference. And, as a certain real American hero/toy used to say, “Knowing is half the battle.”
The vast majority of the time, you buy a product and you expect it to work as the manufacturer claims it will. In order to find out, you use it: you plug in the television and turn it on; you start the car and take it for a test drive; you sit in the chair and see if it holds you. But, when it comes to safety products, if trying them out is the only way to test them, a failure of the test means injury – or worse – to the employee. So how do you know that something is going to perform as the manufacturer claims?
First and foremost, be wary of claims that any products are "OSHA Approved!" Let me be very clear about this: OSHA approves NO products. OSHA does not review product specs, test products, endorse products, or anything of the sort. What OSHA does do, is provide specifications that products must meet and/or refer to testing standards to which the manufacturers must adhere. If you see something stamped "OSHA Approved" then this should immediately raise a red flag. Discuss with the manufacturer or distributor just what that means. If they can't answer it, you may want to seek out the product elsewhere.
Use reputable companies. This is a sound piece of advice in many aspects of life. If you are doing research on the internet for your next big stock purchase, you'd choose information put out by Bloomberg Financial Markets over a report by crazywallyknowzaboutmoney.com (at least I hope you would). If you want to buy a car, you're probably going to go to a dealer that you know or were referred to over that guy in the plaid pants and greasy hair that's got a parking lot full of cars that were all previously owned by an old lady that only drove them to church on Sunday. Safety equipment should be no different. Look for the manufacturers you know and, if you're not aware of them, do your research by searching for them online (just not at Crazy Wally's). If I wanted a harness, I'd probably be looking at Guardian, FallTech, MSA, DBI Sala or somebody like that before I purchased one from NoFallz Fall Protection.
Look for the ANSI stamp. Every product should be tested in accordance with the applicable ANSI standards. Your safety glasses need to meet the ANSI Z87.1 standard, your fall protection needs to meet the Z359 and A10 standards, and so on. When they do, they get marked with that ANSI number. You can then purchase the standards to see exactly what testing is done to ensure the quality of the product you bought. But, even if you don't want to take it that far, at the very least you want to see the ANSI stamp. Without it, you cannot be sure how the product was tested, or if it was tested at all.
Test it yourself. Some things will not require further tests, though you could choose to do so. Others, like safety nets will require testing. For those that require testing through OSHA, the regulations lay out exactly what needs to be done. For instance, a safety net is required to be drop-tested after installation. This is not something you can make up on the fly. It is specifically laid out at 29 CFR 1926.502(c)(4)(i) – right down to weight and diameter of the sand bag you need to use and the height from which it must be dropped. Ensure that you follow the tests exactly as stated in the regulation to ensure not only your employees' safety, but to protect your company, as well, from the lawsuits that could arise due to your failure to comply.
Finally, ask questions. Your distributor should be an expert in the products he or she is selling. Ask as many questions as you need to ask to ensure you are getting what you believe you are purchasing. Ask for product specs, comparisons between different manufacturers (though be wary of the fact that they often get more incentive to sell one brand over another), and any issues they may have come across in the past. And, if you're talking about a product that may not be as off-the shelf as a harness, such as a modular work platform, see if your supplier will provide you with another client of theirs who has been using the product so you can get a first-hand testimonial.
When you buy safety equipment, you're usually hoping it will be worn or installed, but never used. However, if the time comes where it needs to perform its intended function, you'd better hope it works. You can greatly reduce the chances of any problems before you even spend a dime by following this advice, but whatever you do, don't leave it up to chance.
Sometimes it's obvious: you're about to work on a scaffold, at the edge of a roof, or on a piece of equipment fifteen feet high and you know instinctively
that guard rails are needed.
Other times, it's not so simple. Not because safety railing wouldn't be an intuitive solution, but because you may not stop to realize that a solution –
any solution - is even needed. The following are five examples of places where this might occur.
Roof hatches are safe because when nobody is climbing through them, they are always closed, right? Obviously, this is not true. It's pretty safe
to say that roof hatches are often left open to allow access back into the building while people are working on the roof. This creates a dangerous fall
hazard. Anybody not paying attention to where they are walking, whose view is obstructed, or who simply misjudges their step is capable of falling into the
hatch. Roof hatch safety rails help mitigate this hazard.
Yes, it's possible to institute a policy that requires employees to close hatches while they are on the roof (IF the hatch could be opened from the
outside), but even if it was possible to get workers to comply with this requirement 100% of the time, there could still be exposure when leaving the work
area. If a group of workers leaves at the same time, they will most likely gather around the hatch as they wait for co-workers to descend, thereby
rendering the closed-hatch policy useless.
Another reason rails are a good solution in this situation is that they provide a handhold (remember, a ladder must extend three feet above the level you
are climbing to, or there must be a handhold equally high). When ascending or descending through the hatch, the workers could use a properly installed rail
to provide them balance and security. In addition, a rail around the hatch helps to prevent workers from accessing the hatch improperly. Rails on the
sides, for example, could prevent workers from stepping across the opening to get to the ladder.
Skylights are even trickier because there is no visible opening to alert somebody to the fall hazard to which they are exposing themselves. Skylights give
a false sense of security. Workers don't usually have any concept of the weight capacity of the skylight dome. Sometimes, building owners have enough sense
to protect their skylights with screens, but often that costs too
much, would ruin the aesthetics of the building, or is just deemed unnecessary. The idea that maintenance personnel or contractors might need to perform
work on the roof often doesn't come into consideration. Whether it is during maintenance or during construction, skylights need to be protected. Permanent skylight guardrails can be installed to prevent the
maintenance team from having to lug fall protection equipment to the roof every time they have to work up there (or, let's face it, just plain go without
fall protection, which is more likely) or temporary rails can be erected around the skylights during construction. Either way, workers need to understand
that the skylight dome does not provide fall protection.
Roof to Roof Drops
I mentioned earlier that rails are often thought of for roof edges, but when
we think of roof edges, we tend to think about the building's perimeter. What about other parts of the roof that also create fall hazards? Many roofs
aren't a single elevation from north to south, east to west. When you have a change in elevation, it is important to note what the change in elevation is.
If it is greater than 6' for construction work or 4' for maintenance, short of having a parapet 39" or higher, you will need some form of fall protection.
From the moment your employees step off that ladder onto the higher roof, they are exposed to a fall hazard.
Next to Wall Mounted Ladders
Speaking of ladders, whether from one roof elevation to another or from roof to ground, most wall-mounted ladders tend to be near the edge of the roof.
Accessing these ladders exposes workers to a fall hazard. Whether workers are waiting at the top while somebody else descends or whether they are walking
to the ladder themselves, their exposure to the edge is no different than that of somebody working up there. At the very least, rails should be erected on
each side of the ladder to ensure that access is safe.
Parapets could provide you with all the fall protection you need – if they're high enough. Some parapets are obviously too low to be
considered compliant fall protection, while others might be close enough to fool you. Remember, unless they're a minimum of 39" high, they are not
acceptable as fall protection. If your parapet is over 21", then you need to mount rails to it or place a complete rail system inside of it to achieve
the necessary height. If it's not 21" high, you'll need to ensure that not only is your rail 39" or higher, but that you also have a mid-rail in place.
The biggest takeaway here is that the requirements are no different for any of these locations as they would be in any other situation. Safety rails are
safety rails. They need to be just as strong in these places as they would be anywhere else. They need to be just as high. It's just that they may be
needed in more places than you are thinking. Take the time to evaluate your work area, communicate your requirements and enforce your policies. It only
takes one second of complacency, one moment of clumsiness, one dizzy spell, to change the lives of your employees forever.
Falls remain the number one killer in Construction. Try as we might, we seem to have difficulty changing that fact. The overwhelming majority of fall fatalities occur because the worker was either not provided with proper fall protection, was not trained in its use, or chose not to use it (as opposed to, say, equipment failure). The problem is: fall protection solutions are not always easy. Finding a harness and lanyard might be simple enough, but where am I tying off? If I’m on a roof, for instance, is there anything to which I can tie-off?
There was a time where, short of a parapet high enough to fulfill OSHA’s requirements, the answer to this question in regards to roof work was almost always “No”. Perhaps the only structures on the roof were PVC pipes or large mechanical units with no piece to which you could secure your harness. That’s if there were any structures at all. The only option often turned out to be a warning line and monitor system, which is not really fall protection at all.
However, as technology improves, the “No” answer becomes less and less frequent. No longer do we need an existing structure. No longer do we need to penetrate the roof. Technology has brought us a wide array of mobile anchor points that can help solve many of your most difficult fall protection situations.
Let’s look back at the situation where we had a piece of equipment on the roof that we were unable to tie off to. Well, this may still remain true, but what if there was some supporting structural steel available or an engineer determined that a piece of the equipment was suitable to be used as an anchor point? You still might not be able to find a place to connect your snap hook, but a simple anchor strap could provide you the connection you need
NOTE: Anchor straps are specifically designed for fall protection use. You may NOT substitute rigging slings of any kind. Also, remember that in this situation, you are using the strap around steel. Make sure to protect the strap from the edges if it is not a strap with built-in abrasion protection.
Be sure to keep in mind the rating of the strap. This form of anchor point, just as any other, must be able to support 5,000 lbs per employee attached if being used as part of a fall arrest system. Connecting more could render this solution ineffective.
Tie-back lanyards are similar in concept except, instead of a separate piece of equipment, these lanyards are designed to wrap around your anchor and tie back to themselves. Since this is a major “no-no” with regular lanyards, it is important your employees are trained how to determine which type of lanyard they have.
Beam Clamps and Trolleys
Speaking of beams, structural steel is a great option when looking for an anchor point (not decorative steel or roof joists, necessarily, but good, strong, load-bearing steel beams). If your work is fairly static in location, you can get a beam clamp and if you need to travel, you can get a beam trolley. Both work under the same principle in which they tighten around the wider part of the beam, but the trolley has rollers.
A few considerations for beam clamps and trolleys:
- Can I get to the steel without putting myself in a fall hazard situation in the first place?
- Is the steel beam at or above D-ring level to reduce my freefall distance to less than 6 feet?
Mobile Anchors with Weights
Similar in look and design to fall protection stanchions that penetrate the roof membrane to be attached to structural steel below, the mobile weighted anchor performs the same task without roof penetration. The weights are broken down into manageable sizes and are moved around in a cart that often comes with the system. The catch here is making sure your employees are properly trained in assembling the anchor point. While not particularly difficult, assembly is more involved then wrapping a strap around a beam or tightening a clamp.
Some manufacturers now produce a “door bar”. This metal bar is adjustable in size and is wedged into place on the far side of a door or window jamb from where the work will take place. Used properly, the door bar can be a quick, easy, and effective solution.
A separate scenario in which anchor points are difficult to find is vertical entry into something such as a manhole. With the necessary retrieval equipment in place, adding additional lanyards could become cumbersome. Fall protection isn’t always required in these situations, but when it is, the simplest solution is to use your retrieval tripod, IF it is also designed as a fall protection device.
A common mistake is the assumption that all tripods provide fall protection. This is not true. In the event of a fall, a retrieval tripod that was not designed for fall protection would just continue to unravel until the employee struck the lower level. Make sure that if you are depending on your tripod, you check the manufacturer’s information to determine if it is suitable for that use. If it is not and you come across this situation often, it could well be worth your while to invest in a tripod that acts in both capacities.
Roof carts operate under similar principle to the roof stanchions mentioned earlier – weights in the cart help counteract the weight of the personnel attached. However, these carts are also designed with “feet” that will dig into the roof, or lodge in the fluting of the metal deck, in the event of the fall.
These carts appear simple, but have some nuances that are important to understand. For instance, many are designed with anchor points that allow for a certain number of employees using the cart for fall arrest and an additional anchor(s) for at least one employee using it for travel restraint. Understanding the cart’s capacity is of the utmost importance. In addition, it’s important to know which direction the cart should be facing based on the type of surface on which it’s resting. Do not attempt to use these (or any fall protection equipment, really) without reading the manufacturer’s instructions and/or being properly trained.
Sometimes, if not often on commercial structures, there is a parapet, but it’s just not high enough to count as fall protection, according to the OSHA regulations. In this instance, you may opt to use parapet clamp anchors. These are similar to the parapet clamps you may see being used as bases for guardrail, but some are also designed to be anchor points. Again, ensure that you are using one designed for this purpose because a parapet clamp intended to only be used as a rail base will not offer you protection as an anchor.
Some operations are a bit different and require a different approach altogether. For instance, in truck washing situations, unloading operations, or rail yard work (to name a few) it may be just as difficult to locate a suitable anchor as it would be during some types of roofing work. For these applications, you may choose to use a rigid lifeline system. While some of these systems are designed as permanent installations, others are wheel-mounted so they can be moved from one part of the operation to the next.
The fact remains that with each passing day, more and more technological advances occur that make the lack of fall protection indefensible. The ones listed above are only some of the products available for use. Many roofing companies still opt to use the warning line and monitor system even when actual protection is available. Sit down and assess your fall protection needs. Find out what options are available to you. Ensure that your employees’ lives are protected. Perhaps then we can knock “falls” off the top of that fatality list.