A safety professional may read the title of this article and feel it’s child’s play. How could somebody not know how to look for risk? That same
safety professional may even be tempted to use a phrase that I cannot stand: common sense. I once heard a speaker explain that common sense is a
learned phenomenon. We cull the experiences of our life and, from them, develop our so-called common sense. This is very true. If I spent my entire career
reaching into a machine that wasn’t locked-out and nothing happened to me, I may believe that doing so was safe. This is the experience that develops my
Can You Rely on Common Sense?
That same scenario may seem like a lack of common sense to somebody who knows better, but we’re assuming that I have no other education or
experience to help me come to a better conclusion. Of course, this example is extreme; it would also require that I had no experience or knowledge to let
me know that rollers, gears, or blades were dangerous. The point of the matter is this: common sense is different for everybody, and therefore cannot be
It’s important for safety professionals to realize that what seems like second-nature to us now, didn’t always. The fact that we can walk onto a
construction site or a manufacturing floor and immediately begin pointing out unsafe conditions and practices stems from years of education and experience.
When I first began in the industry, I could barely tell one piece of heavy equipment from another, let alone start pointing out problems. It took time to
develop that particular skill set.
Walk a Mile in Their Shoes
To understand where a non-safety professional may be coming from, we need to put ourselves back in their shoes. Maybe you can’t remember what it was like
before you knew safety so well, so instead, think of a time more recently when you had to visit a new facility or, worse yet, a new industry with which you
were not used to dealing. Sure, there are things that carry over from facility to facility, from industry to industry, but most likely there were things
there you had yet to understand – new machines, new procedures, new tasks. The first thing you needed to do was learn what those machines, procedures and
tasks were. You needed to find out where the exposures were and how those exposures should be controlled.
The Importance of Risk Assessment
Yes, that’s right, you did a Job Hazard Analysis (JHA) or whatever preferred acronym you use for a risk assessment. Whether you stopped and did this on
paper or you ran through it in your head, you went through a very methodical process. The problem is that you went through this process because it is a
part of your training and background. Not so for your line employees, your laborers, or even members of management. Their inherent focus may be, “How do I
properly operate this equipment?”, “What is the most efficient way to operate this?” or even “This is a piece of cake, so I guess I no longer need to pay
attention,” not necessarily, “Where and why is this dangerous?”
Don’t Fish for Them, Teach a Them to Fish
It is important to instruct your employees that assessing risk is an important part of their job, not just something that is done for them
. Train them on the proper way to perform a JHA. This should include running through some practice assessments and reviewing the existing assessments for
your facility. When you see workers on the floor or jobsite, ask them what hazards are presented by their job and what they – or the company - have done to
reduce their exposure. This is no time to be protective of your job and skills. You want everybody thinking like you do when you walk into a work area
because you cannot be everywhere at once.
If the employees can’t tell you what hazards their job presents and what controls are in place, then how can they possibly be aware if those controls
or the precautions that they are supposed to be taking are effective?
What’s Wrong with This Picture?
Do you remember - as a child - doing those “What’s wrong with this picture?” puzzles? That’s how I approach every site or facility I enter. Consider the
original picture – your frame of reference – to be the OSHA regulations, your company procedures, and your general knowledge of what is safe or unsafe.
This original picture is how everything should be, in a perfect world. Next, you have the altered picture – the one with things missing,
backwards, changed, whatever. This is reality. This is the facility or jobsite you’ve walked into. Having the first page in hand makes it easy to spot the
problems, but what if you didn’t have that first page? What if you hadn’t known exactly how it should be, or had only gotten a quick glance? Now
it becomes harder to see the problems. Our jobs must include giving our supervisors and workforce that first page – that frame of reference from which to work.
Do You Have the Right Picture?
To achieve this, they must understand the OSHA regulations that apply to their work, but just citing them chapter and verse helps only a little bit. They
need to know how those regulations apply to what they do and be able to use them to help identify hazards. This is what the goal of a good OSHA 10 or 30 hour Outreach course should be – hazard identification. If you’re sitting through a class
with an instructor that is just trying to cram as much of the CFR text down your throat as he or she can do in 10 or 30 hours, then your instructor has not
been trained well and you have wasted your money. A good course teaches you the regulations and how to recognize if things are not right.
Now Do a Gut Check!
Finally, tell your people to trust their gut. No, common sense isn’t always good, but if something feels wrong to someone, most likely it is
wrong, even if they’re not sure why. Tell them to take the time to find out why they feel this way or to get somebody with more experience or knowledge who
can review it for them. In order for this to be successful, your company must be receptive to workers doing this. If every time a worker approaches a
supervisor with a concern they hear “Just get back to work,” they will quickly stop trying to raise issues. Yet, if your company encourages this,
eventually those same employees will begin to know why they feel something is wrong and, most likely, begin to be able to fix problems themselves, where
Experience, knowledge, and good training, with good coaching along the way will help your employees get to a point where spotting risks is child’s
play. It won’t happen overnight, but every day that passes is another day they’ve gotten better at it and another day they’ve stayed alive.
Perhaps you decided to read this because you thought, "Of course not! Everyone knows that is a crazy dangerous, not to mention non-productive." However, studies show that walking and texting are pretty much akin to walking blindfolded.
Isn’t this Just Common Sense?
Researchers at Stony Brook University (study published in Gait & Posture) confirmed what many think is common sense in a study of young people walking while texting or talking on mobile phones. The study showed that “cell phone use among pedestrians leads to increased cognitive distraction, reduced situation awareness and increases in unsafe behavior.” In short, it’s dangerous to walk and text!
As a baseline, the study participants were shown a target on the floor 25 feet away. Then with their vision obstructed, participants were instructed to walk at a comfortable pace to the target and stop. The researchers recorded time and accuracy observations of each of the 3 walks each participant completed.
A week later, one-third of the group completed the same task with obstructed vision focusing them on a mobile phone, one-third while talking on a mobile phone, and one-third while texting. Eric M. Lamberg, PT, Ed. D., co-author of the study, remarked, “We were surprised to find that talking and texting on a cell phone were so disruptive to one’s gait and memory recall of the target location.”
The study concluded texting or talking while walking phone slow task completion significantly with 33% and 16% respective reductions in speed. Additionally, texting participants veered off course demonstrating a 6% increase in lateral deviation and 13% increase in distance traveled. Another study by Jack Nasar, an Ohio State University professor, reports emergency room visits due to pedestrians injured while walking with cell phones have soared in recent years.
Mobile Devices on the Construction Site
Mobile device usage on a construction site places your workers in danger and reduces productivity. Construction sites are inherently fraught with more danger than streets and sidewalks. So the dangers pointed out in these studies are miniscule compared to what mobile device users face in a construction zone.
You may not have a policy against working blindfolded, but you probably do have a health and safety policy against operating machinery, driving, or even being present on a job site while intoxicated. Texting has the same effects as intoxication when it comes to multi-tasking. It is the safety professional's duty to Increase safety and productivity by establishing and enforcing a written mobile device usage policy.
Developing a Mobile Device Usage Policy
Tips to develop your mobile device usage policy:
- Prohibit mobile device use including talking, texting, emailing, browsing, gaming, or use of any other feature while engines are running on any kind of motor vehicle or machinery. Note that this includes company-provided and personal devices.
- Require any mobile device usage to be done outside the work zone. This may require additional signage at work sites.
- Provide tips for safe mobile device usage and etiquette anywhere. Examples include to pick your spot carefully when you stop walking to text.
- Distributed a written policy to all employees
- Require each employee to sign off on the policy.
- Enforce the policy.
Continue the discussion: How do you balance mobile device safety with the productive use of mobile devices on the job site?
It seems in life sometimes that getting a job is all about who you know, but regardless of whether or not that is actually the case, once you have a job, there is no doubt that keeping it depends on what you know. In only the rarest of situations is an employer going to continue to pay somebody that adds no value to their organization. If you’ve managed to land yourself a Safety Director’s position, it’s time to look at your track record and your approach going forward to determine if you’re doing what it takes to keep it.
Be a Salesperson
Not everybody likes sales, and that’s unfortunate for somebody in this field because there’s a lot of selling to do. As a Safety Director, you have the burden of showing an employer why something is good for them even if it doesn’t produce revenue and the burden of showing an employee why their behaviors need to change even though they’ve been doing something the ‘wrong’ way for years without negative consequence.
Let’s look at dealing with your employer first. As idealistic as we’d like to be about safety, the fact remains that it is and always will be just as dependent on the bottom line as any other department in your organization. “Because it’s the right thing to do” may be a great selling point when the economy is good and business is booming, but when a company is existing on marginal or no profits – or worse, losing money – safety seems to be one of the first items cut from the budget. Why? Because the Safety Department can’t show that it’s bringing in revenue. It is much harder to convince somebody that your department is worth it because you are not losing x amount of dollars than it is to convince somebody that your department is worth it because you are bringing in x amount of dollars. Not losing money is theoretical. Making money is concrete.
So, how can the idea of safety be sold? By knowing facts and figures. Find out the average cost of medical treatment for a hand laceration and compare that to investing in new gloves. If you’ve had these incidents it’s easier to pull up historical data to make your case, but if you haven’t, hop on the internet, the information is out there. Some employers may be thinking that if they cut their hand, they’d bandage it up and go back to work. They need to realize that it could be much worse than that: emergency room or urgent care visit, stitches, follow-up visits, possibly physical therapy, lost time or production, hiring and training of new personnel or cross-training of existing personnel to pick up the slack. Remember the statistic that indirect costs (retraining, lost production, etc.) are about 4x the direct costs (medical care and salary).
Selling safety to employees should, theoretically, be easier, but for some reason the workforce seems just as reluctant as employers to do what is necessary, despite the fact that it is being done to ensure their own well-being. Employees get comfortable in their way of doing things and don’t want to change (there’s that inertia again). Sometimes they are receiving pressure from supervision to work faster (and sometimes it’s just their own misconception that faster = better). Sometimes it’s simple stubbornness – the “don’t tell me what to do” factor. Other times, safety just isn’t “cool” or “manly”. Whatever the reason, it is an impediment to progress and you, the new Safety Director, need to sell the idea to them. Why is it better for them? Do you have proof? “Statistics are statistics, but how does it affect me?” And the biggest problem: “You don’t care about me, you just want to save the company a few bucks.” These are all obstacles you need to be prepared for. Perceptions need to be changed. Employees need to understand that every single one of those statistics was a person saying, “..but how does it affect me?” They need to understand that caring about them and saving the company money don’t have to be mutually exclusive. You will be selling the idea of safety your entire career.
On top of this, in order to keep your job, you’re going to need to continuously sell yourself. You need to show your employer that you are ‘the guy’ – that you are the person best suited for this job. Sure, once you have the position you have inertia in your favor (the idea that searching for, hiring, and training somebody and basically starting over from scratch is not worth the effort), but inertia is only so strong. You need to be effective. You need to show results. You need to show that you are innovative, hard-working, and effective. Do your job well and your record will speak for itself.
Be a Communicator
If the boss doesn’t know who you are, you’re expendable. If the workforce doesn’t know who you are, you’re going to be ineffective. In a larger organization, where a director has subordinates within the safety department, your time in the field or on the floor will be reduced as you worry more about policy and procedure, worker’s compensation case management, meetings, and other executive tasks, but in smaller organizations field presence is a much larger part of your job. Either way, a Safety Director needs to spend time in the trenches, but by no means should this time simply be spent floating around telling people what they are doing wrong.
If you want to keep your job as a Safety Director, you need employee buy-in to your program. In order to do this, you need to make sure they understand that you genuinely do care about their well-being. Accomplishing that is not hard. Instead of going into the field with the idea of finding all the mistakes, take the time to talk to the employees. Get to know them. Ask them how their weekend was or if their wife had the baby yet. Ask them how their daughter’s first year of college is going or if they saw the game last night. I had one employee on a job who was a tough, stand-offish guy who wanted to do the right thing but didn’t always take the time to understand what the right thing was. However, he also didn’t take kindly to being corrected. One day I got the best piece of advice: ask him about his dog. The next morning when I approached him, I told him I heard he had a dog. He lit up and started talking about his puppy and what a good dog she was. We chatted for a few minutes before I went on my way. Each day I see him, I now begin the conversation with, “How’s the dog?” And, when I need to discuss an issue with him, he is approachable and willing to listen to my criticism or suggestion.
Relationships with the men and women in the field are priceless. I’ve witnessed too many safety “professionals” make their jobs ten times harder because they feel the need to be adversarial with the workforce. They wield their power like a sword, chopping off the heads of those who do not comply (not literally, of course). This wins you no favors. In this situation, workers may actually not comply out of spite. Right or wrong, non-compliance is certainly not a desired outcome. I’m not saying there isn’t a time and a place for being stern and enforcing your disciplinary program, but as the saying goes, “You catch more flies with honey….”
In addition to direct communication with individuals, you need to communicate your message. Safety should always be on the minds of your employees, not just when you happen to show up in their work area. Meetings, signs, newsletters, and safety reminders are all ways to make sure both your employees and your employer are thinking about safety. Bad things can happen when your workforce becomes complacent, so remind them about safety so often that complacency becomes impossible.
And remember the “co” in communication – meaning “both” (okay, I understand that the actual word root here is “com”, not “co”, but play along!). Communication, to be effective, must be a two-way street. Listen to your superiors so you have a solid grip on what they are looking for and listen to the men and women on the front line. Often, they’ve been doing their job for years if not decades, so they probably know a thing or two about it.
Finally, none of this matters if you’re not getting results. You may feel you know more about safety than any other director out there. Maybe you can recite the OSHA regulations chapter and verse. Maybe you’ve been implementing behavior based safety programs since before they were popular. Maybe you could train a lemur to fly the space shuttle. It all amounts to nothing if your people are still getting hurt, your workers are still violating policies and regulations, your management teams have not bought into the program, and – as much as we hate to admit it – your statistics haven’t begun an upward trend. If you’re going to sell, are you closing the deal? If you’re going to communicate, does the other party understand what you’re saying? There are many safety programs out there – and many safety professionals – but are they any good? The only way to know is to monitor the workforce, collect, track and analyze data. If I don’t review or chart my near-misses for analysis, then reporting them does no good. If I don’t test the workers to find out if they understood what they were taught, then training may have been pointless. If I can’t get management to sign-off on a purchase order or agree to allow the time for training, then developing a program was worthless. Always review what you’re doing and strive to improve it. That is how to keep your job as a Safety Professional.
"It was just a freak accident."
"There was no way we could have seen that coming!
If you haven’t heard something like this, spend a little time doing incident investigation in an occupational setting. Trust me, it won’t take long. Statements like these perpetuate the belief that accidents are beyond our control and there are no precursors to them, however studies seem to indicate otherwise. Certain behaviors – or warning signs – exist that should trigger an alarm to anyone paying attention.
As safety professionals, we learn early on about the ‘Safety Pyramid’. This was an idea first proposed by H.W. Heinrich in 1931 that, when boiled down, showed that there were approximately 300 incidents for every major injury. Almost four decades and some terminology shifts later, Frank E. Bird proposed about 600 incidents for each fatal accident. The study, though, that is probably most relevant to us due to its chronological proximity is one conducted by Conoco Phillips Marine in 2003. This study showed that for each fatality there are 3,000 near miss incidents and 300,000 at-risk behaviors. That’s 300,000 opportunities (statistically speaking) to correct a problem before it becomes a fatality.
In other words, there are plenty of indicators that a ‘freak accident’ is about to happen. You just need to know what to look for. When it comes to falls, they are no different than other injuries or fatalities in this sense. An employee’s likelihood to fall is influenced by their behavior. If a certain employee tends to violate the rules, disregard his or her personal protective equipment, or generally wander around with the attitude that they are invincible and safety rules do not apply to them, look to them to be a potential victim. This is the person that has a higher probability of working at heights without proper fall protection (an improper anchor, an improperly worn harness, no fall protection equipment at all). This is the person that might walk out to the edge of the roof because they are ‘only going to be there for a second.’ This is the person that is going to do something to endanger themselves or others.
Should one of your ‘problem’ employees be assigned a task that requires them to work at heights, additional training may need to be held prior to the start of work or the disciplinary program might need to be reinforced. One way or the other, a company needs assurance that this employee is going to work safely, in order to avoid a ‘freak accident’.
In today’s economy, companies are trying to do more with less. While production has crept back up, a large number of people who have been laid off since 2009 have not returned to work – at least not in the same capacity they worked before. Many companies were forced to streamline their workforce and, in the process, found that they could do just as much with fewer people. Sometimes, this results in overtime pay and sometimes it doesn’t, but what it results in every time without failure is eventual exhaustion. People get overworked. People have breaking points. As people approach this breaking point, their work begins to get sloppy. They lose the ability to focus. Their minds wander. Details get missed.
What happens when that detail is attaching your snaphook to your anchor point or simply watching where you step?
Recent studies have shown that drowsy driving is just as - if not more - dangerous than drunk driving, yet some employers feel they can continue to work their employees for long shifts over long periods of time without any adverse effect. In reality, their ability to work will be impaired just as much as their ability to drive. Add your employees’ extra-curricular activities (believe it or not, they do have lives outside of work) on top of these long hours and you’re asking for an accident.
Sometimes, an employee can be their own worst enemy. Getting used to a job or feeling you know everything about it can lead to a level of complacency that could become dangerous. Let’s look back at a famous historical disaster – the Titanic. The largest ship in the world at the time was sailing through the north Atlantic and Captain Smith had iceberg warnings in his hand. They were going faster than they had intended to go, but on they went. Captain Smith believed that, should they encounter an iceberg, they would be able to turn in time. This might have been true on any of the ships Captain Smith had previously sailed, but the Titanic was larger. In addition, the seas were so calm that there were no whitecaps breaking at the base of the iceberg. By the time the watch saw the iceberg, it was too late. Captain Smith’s complacency was fatal.
By the same token, workers in every field can get to a point where they are so comfortable with the job they do, that they begin to do it on “auto-pilot”. They feel they know it “inside-out”. They may not only be unwilling to listen to advice or constructive criticism, but they even stop applying their own critical eye. Things, in their mind, are the same today as they were yesterday and the day before. Changes in process, tools, personnel, or environmental conditions may go unnoticed. Perhaps there’s always been a railing where they have to work, but today there isn’t. Maybe one of their co-workers has been replaced by somebody new. Maybe somebody leaked oil on the ground. Regardless of what the variable is, it gets missed. When a worker stops paying attention to these things, he or she increases the likelihood of an incident, and a fall is no different.
Granted, if somebody didn’t know what to look for, some of these precursors might easily go unnoticed, but the fact remains that they are there. A good safety professional must not only keep an eye out for these things, but must also ensure that other management personnel are aware of them, too. A company should be implementing programs that battle complacency (such as daily job briefings and management oversight) and, at the very least, be reminding employees to evaluate their tasks and work areas as often as possible. Near-misses should be reported and somebody should be reviewing all incident reports and safety violations for trends. Work hours should be reviewed. Are the extra shifts necessary? Is one employee overloading on hours to get overtime pay while others aren’t? Begin looking for these precursors and you will be on your way to doing the most important aspect of a safety professional’s job: incident prevention.
This is the million dollar question, isn’t it? For years, many of us in the industry watched as prizes were awarded to workers based on safety performance. Sometimes this meant a group lunch or a t-shirt, but other times it was something as big as a truck or boat being given away. This sounds great - generous even – but is it doing more harm than good?
What is the Issue?
The general concern with safety incentive programs is that while it may make workers think twice about doing something unsafe, it may also have the unintended (we hope) consequence of making workers hide injuries. Let’s face it: who wants to be eliminated from winning that boat because they sliced their finger open and needed a couple of stitches when that can easily be fixed by a quick visit to the emergency room and a little white lie that you cut yourself at home? Who wants to be the guy that gets an entire crew eliminated from the running because they broke a toe or two and needed to stay off their feet?
What does OSHA Say?
This question has been debated ad nauseum among safety professionals, but before we approach this from their point of view, let’s first take a look at what OSHA has to say about it. According to a March 12, 2012 memo released to the agency’s regional administrators (https://www.osha.gov/as/opa/whistleblowermemo.html), OSHA feels that while most incentive programs have good intention, they often create the unintended consequences mentioned above. Under point #4, the memo states:
Finally, some employers establish programs that unintentionally or intentionally provide employees an incentive to not report injuries. For example, an employer might enter all employees who have not been injured in the previous year in a drawing to win a prize, or a team of employees might be awarded a bonus if no one from the team is injured over some period of time. Such programs might be well-intentioned efforts by employers to encourage their workers to use safe practices. However, there are better ways to encourage safe work practices, such as incentives that promote worker participation in safety-related activities, such as identifying hazards or participating in investigations of injuries, incidents or "near misses".
The point of this portion of the memo is that if your employee feels pressured to not report an injury or illness because of your particular incentive program, it could be considered retaliation under whistleblower protection statutes (in other words, if you report an injury, you don’t get a bonus). OSHA does allow, in this memo, that a company would need to take into consideration whether the incentive award was or was not substantial enough to dissuade an employee from reporting in order to determine if it falls into this retaliation category.
In the end, OSHA’s stance is gray, and therefore, so is the answer to this question. OSHA does not come out and prohibit safety incentives. In fact, they state in the memo that they appreciate employers attempting to use safety as a performance metric, but they recognize the inherent danger in such a program.
To Incentivize or Not to Incentivize, That is the Question
Since OSHA does not ban incentive programs, you – as an employer – need to decide if having one is right for you and, if so, how it should be run. Some people that I’ve discussed this with simply do not believe in safety incentives. Their belief is that you already have two built in incentives:
- You are going home healthy and unharmed.
- Your paycheck.
Is Safety Optional?
Number two is interesting in that it infers that incentive programs propagate the belief that safety is optional; that safe work practices are to be followed only if you want to get a little extra something from your employer. This is most likely not the message you are trying to get across. By saying that a worker’s paycheck is their incentive, you are making the point that safety is part of your employee’s job, and it is expected of them just as much as you expect them to be at work on time and to perform quality work.
Still, many companies feel they need that extra something to get their workers to follow what may sometimes be time consuming or cumbersome rules. The key is to find a balance. A reward that is too large could cause employees to hide injuries while a reward too small could have no positive effect. A reward for injury-free work may need to be balanced by an equal punishment for failure to report. This, however, could also lead to murky waters. A punishment for failure to report could easily be twisted to appear as a punishment for getting hurt and you’re back in the realm of ‘retaliation’.
Focus on Leading Indicators
Perhaps the best route to take is one that OSHA recognizes in their memo and one many safety professionals struggle with: leading indicators. For years, the focus of incentive programs or recognition awards has been on trailing indicators: recordable or lost time injuries, OSHA incident rates, and similar metrics. This measures employees after the fact, rather than trying to encourage them to be proactive. Some leading indicators include participation in incident investigations, number of near miss reports, and training sessions attended. The catch here is that:
- You need incidents to have incident investigations in which to be involved.
- You need near misses in order to report them.
- Sometimes production schedules don’t allow for attending training sessions above and beyond what is already required.
These indicators may be a good starting off point, but a program needs to be developed to effectively utilize them. Can it be successful? Sure, but so can an incentive program using trailing indicators when developed properly.
A Properly Developed Program
And that’s where the key lies: a properly developed program. Should safety be incentivized? If you and your company are willing to put the time and resources into developing an effective program that is beneficial to the well-being of your employees yet doesn’t have negative unintended consequences, yes! If not, then avoid incentives because they’ll be nothing more than a dog-and-pony show that not only may not work, but may actually put your employees in harm’s way.
What do you think? Share your thoughts in the comments section below.
Every safety professional wishes this was a simple answer. One height across all tasks and industries would certainly make enforcement easier, but this is not the case under OSHA. Whether the varying height requirements for fall protection are for good reason or not is up for debate, but the fact remains that they are law and they are what can be enforced. However, keep in mind that contracts and/or site policies sometimes go above and beyond the regulatory requirements, so you need to be aware of what the rules of your site are.
There must be a starting point from which to work so that when nothing else seems to fit, you can know what the default answer is.
- For General Industry, this is at 4’.
- For Construction, the default answer is 6’.
- In shipyard work and marine terminal work, your trigger height may be 4’ or 5’ depending on the situation
This means that at any point your employees are exposed to heights equal to or greater than these, they must have some sort of protection, whether it be fall arrest systems, railings, or some other means. Look around your facility or jobsite. Are there locations above these heights where employees could be reasonably expected to go? If so, are they protected? If not, what is your plan?
The No Minimum Height Rule
There is an instance in which there is NO minimum height, and it is important to understand. If your employees are working over dangerous equipment, machinery, or any hazard into which they could fall, they must have fall protection at all times or machine guarding needs to be put into place. No exception.
Exceptions to the Basics
There are a number of exceptions to the basic rules – the aforementioned defaults, many in the construction industry. Remember, construction is dynamic. It is harder to recognize a fall hazard and have a railing system permanently installed like you might be able to do on a manufacturing floor. Due to this, a few exemptions have sprung up over the years.
According to Subpart L of the Construction regulations, fall protection on scaffolding is not required until you are greater than 10’ off the lower level. This allows scaffold users to not have to worry about rails or other means of fall protection every time they set up a single bay or level of scaffolding. Most frame scaffolds are greater than 6’ high, but less than 10’. This exemption allows for unprotected work on top of a single bay of scaffolding.
There is, however, an exception to the exception. Boom lifts fall under the scaffolding regulations. Anyone in the basket of a boom-lift must be tied-off at all times using a travel restraint lanyard. This is due to the potential to be brought above the 10’ mark (and let’s be honest, the vast majority of work done from a boom lift is well above 10’) as well as the potential for being catapulted from the basket.
The Steel Erection regulations, Subpart R of the Construction standards, are notorious for being lenient and difficult to understand. Simply put, anybody involved in steel erection activities is not required to have fall protection until they are 15’ in the air (the exception to the exception would be somebody in a boom lift who is still required to be tied off at all times). Here’s where it gets tricky. Connectors – those employees on a steel erection crew actively receiving and connecting steel members – do not need to be tied off up to 30’ or two stories, whichever is less. HOWEVER, they MUST be wearing the proper fall protection equipment and have an approved anchor point after 15’. In this situation, a connector may choose to not tie off, but the ability to tie off must exist.
Common problems safety professionals run into while attempting to enforce this subpart are all members of a steel erection crew believing they get the 30’ rule or every member of the crew trying to claim that they are connectors. It is important that the safety professional be aware of the definition of a connector and who is required to be tied off at what point. In addition, many crews either forget or are unaware of the ‘or two stories, whichever is less’ portion of the rule. Connectors may be required by law to be tied off at, say, 24’, if it was two stories of 12’ each while they would not be required to be tied off if it was one story of 24’.
Deckers are also allowed a 30’ exception. This exception basically says that deckers may establish a CDZ (Controlled Decking Zone) into which access is restricted and in which fall protection is not necessary. This exception is good, just as the connector’s exception is, up to 30’ or two stories, whichever is less.
Stairs and Ladders
Most people don’t think about fall protection when it comes to ladders and stairways, mostly because stairwells are often enclosed or have some type of railing by the time you are using them, but in construction this is not always the case. OSHA requires in subpart X that all stairways having four or more risers or that rise more than 30 inches be equipped with a stair rail along each unprotected side or edge. This is important to remember since temporary stairs are often built on jobsites or new staircases are installed without railings and/or without the walls that will eventually enclose them.
Ladders are a bit different and fall protection mostly comes into play with fixed ladders. With fixed ladders, the key number to remember is 24’. In any instance where the climb on a fixed ladder is greater than 24’ or where the climb is less than 24’ but the top of the ladder is greater than 24’ above a lower level, fall protection must be provided as one of the following: a ladder safety device, a self-retracting lifeline, or a cage or a well.
Climbing Vertical Rebar Assemblies
For this exemption, you need to dig a little deeper. In the past, concern was raised as to whether or not fall protection was needed for employees climbing on the face of a vertical rebar assembly such as one that would be constructed for a wall that was to be poured in place. In a letter of interpretation dated December 23, 1994, OSHA states that fall protection is not required while the employees are in motion up to 24’ because they consider the multiple handholds and footholds of a vertical rebar assembly to provide similar protection as that of a ladder. However, just as in the ladder standard, should that employee need to climb to a height greater than 24’, they would be required to utilize fall protection. In addition, note that this exception is given during climbing or moving only. Once the employee reaches their place of work, they would need to have fall protection which could be a harness and lanyard or a positioning belt.
In the end, there is no single simple answer. As a safety professional or the person in your organization responsible for employees working at heights, it is imperative that you look at each situation and determine what is required. Be aware that certain companies may perform activities that fall under the general industry regulations and others that fall under the construction regulations. Find which standard is applicable, then find the section within that standard that addresses the work you are performing. Remember that a more specific section (vertical standard) always overrides a broader section (horizontal standard). For instance, Subpart R for steel erection (a vertical standard) overrides Subpart M for Fall Protection (a horizontal standard). If there is no applicable section to what you are doing, remember your industry defaults. And don’t forget to check if your facility or jobsite goes beyond the OSHA requirements. When it comes to falling, you can never be too safe.
One of the most neglected aspects of Fall Protection is the rescue and retrieval plan. Sure, you've selected your harnesses and lanyards, debated the feasibility of railings, and calculated your fall distance, but what do you intend to do once the worker has fallen? While the worker is dangling from the structure is not the best time to develop a plan. The time is now, before work at heights begins. Here are five things you need to consider when developing the rescue and retrieval plan:
1. You Don't Have A Lot Of Time
Whatever plan you come up with needs to happen fast. Orthostatic Intolerance – also known as Suspension Trauma – can occur in as little as 20-30 minutes and sometimes less, depending on a person's health and/or the nature of any injuries sustained in the fall. Rescue needs to begin immediately. But what is your plan? Are you positioning a lift beneath him to which he can be lowered? How long will it take to get the lift there? Is the ground below safe for a lift? Questions like these need to be answered ahead of time because if you're doing it after a fall, you're wasting precious time.
According to an informational bulletin released by OSHA (https://www.osha.gov/dts/shib/shib032404.html) Suspension Trauma's symptoms include faintness, breathlessness, sweating, paleness, hot flashes, increased heart rate, nausea, dizziness, low heart rate, low blood pressure, and greying (loss of vision). Factors that can affect the severity include inability to move the legs, pain, injuries during the fall, fatigue, dehydration, hypothermia, shock, cardiovascular or respiratory disease, and blood loss.
Suspension Trauma occurs due to the pooling of blood in the legs (due to gravity and exacerbated by circulation being cut off by the harness). Adding to the danger of Suspension Trauma itself is the fact that when a person who is suffering from Suspension Trauma is brought to the ground, the natural reaction will be to lay them down. This can cause the pooled blood to rush back to the heart too quickly, sending the worker into cardiac arrest. Again, time is of the essence so that it never gets to this point.
2. A Rescue Plan Is Not One Size Fits All
What works in one instance for fall rescue and retrieval will not necessarily work in the next instance. Rescue from a high-rise, for example, will be much different than rescue from the construction of a one or two story office building. And, not only will your plan need to be different from project to project, but it will also possibly need to be different from one phase of a job to the next. Perhaps when the steel is up, the sub-grade levels have been completed, and the area around the building has been back-filled and compacted, an aerial lift can be used for rescue, but what do you do while that mass excavation is still open? What if a large concrete pad is being poured right where you need to set up the lift?
Construction is dynamic – the environment is in a constant state of change. Because of this, your plan must be constantly reviewed. In certain general industry settings, you may be able to come up with one plan, insert it into your corporate health and safety program, train to it, and rest reasonably assured that you are covered. Construction, in most cases, will not allow you this luxury. Your rescue and retrieval plan must be not only site-specific, but it must also be location, phase, and task specific while considering surrounding work activities.
3. Your Victim May Not Be Able To Help
Products exist that help prolong the amount of time before Suspension Trauma sets in. For example, you may have a pack on your harness that can be deployed in the event of a fall which contains straps – or steps – into which you can place your feet to relieve the pressure on your legs. This is an excellent product but it relies on one very critical assumption – that your victim is conscious. Whether the straps are manually deployed or automatically deployed from the force of the fall, the victim will still need to be able to step into them.
Additionally, if you've got people working alone at heights, how do you know they've fallen? Can you see everywhere your employees are working? Is somebody on constant watch to make sure there's nobody hanging from a lanyard? Sure, the workers have phones or radios, but refer back to the previous paragraph – just like you can't step into a strap, you can't make a radio or phone call if you're unconscious. Nor can you make one if your radio or phone was dislodged in the fall, plummeting to the ground five stories below. Keep this in mind when developing your plan and, better yet, never allow anybody to work at heights by themselves.
4. They Make Stuff For This
You don't need to re-invent the wheel every time you come up with a rescue plan, nor do you have to jury-rig some customized equipment (and, in fact, you shouldn't). A simple web search shows you that equipment and kits exist that are designed for just this purpose (for example: fall protection rescue equipment). Figure out your particular circumstances, review available equipment, and devise your plan. Also, know your limitations – just because a kit or piece of equipment does exist, doesn't necessarily mean the personnel you have in place are capable of utilizing it. They must be trained and demonstrate the ability to do what is necessary. Let's not forget: somebody's life is literally on the line. If you feel the rescue is beyond your abilities, speak to your local fire department to see if they are trained and if it's feasible for them to be on-site during the work. Obviously, this would most likely not be possible for an entire job, but perhaps it would be for one particularly difficult task. If the local fire department isn't trained, is there a private entity capable of rescue at heights?
5. Was It Even Necessary In The First Place?
Remember OSHA's hierarchy of controls? The first is, can you engineer out the hazard? While you will not be able to eliminate every fall hazard in construction, maybe there are ways to eliminate the hazard during certain tasks. Have you looked at the possibility of rails instead of fall arrest? Have you considered a retractable lanyard instead of a 6' lanyard with a deceleration device? What about travel restraint so that your personnel cannot reach the edge? Obviously, sometimes the answer is going to be that you have considered other possibilities and they are just not feasible. That's fine, but the important thing is that you did consider them. It's hard to believe anybody wouldn't agree with the statement that preventing somebody from falling is better than rescuing them after they've fallen, so why not plan your jobs that way? If you can eliminate the fall, you can eliminate the need for rescue and retrieval. If you eliminate the need for rescue, you've eliminated the possibility of Suspension Trauma.
In a perfect world, rescue would always be simple. Then again, in a perfect world, maybe our workers would be able to fly. We are forced to face the realities of this world and those realities are that falls still remain the number one killer in construction and the fatalities are not always caused by the fall itself, but are sometimes caused by the aftermath. Those working at heights need to be prepared and need to act fast so that a would-be rescued worker does not become another statistic.
I recently wrote an article detailing how to ensure you are using your fall protection equipment properly. If you are the inquisitive type, it may have left you asking the question, “How, exactly, does a safety harness work?” In reality, there is a fairly simple answer to this question: distribution of force. But what does that mean and why is it necessary?
Bye Bye Body Belts
To see why it’s necessary, we only need to go back a few years – prior to January 1, 1998 to be exact. For the more seasoned safety professionals among us, this may conjure up an image of a time when fall protection, if worn at all, sometimes consisted of a body belt. Nowadays, the body belt has been banished to the Island of Misfit Toys (or, more accurately, to the role of ‘positioning device only’ [29 CFR 1926.502(d)]) and for good reason. What the body belt accomplished when the forces exerted on the body in a fall were too great was to concentrate those forces into a person’s waist, essentially causing them to snap in half. This was not, obviously, the desired outcome of a fall event.
Protect the Vitals
According to OSHA, personal fall arrest systems (PFAS) must limit the maximum arresting force on an employee to 1800 pounds when used with a body harness [29 CFR 1926.502(d)(16)]. The harness then takes these forces and, through its system of straps and buckles, distributes them to the parts of the body best suited to absorb force and support your weight: the large muscles of the upper thighs, chest and shoulders, as well as the bony mass of the pelvis. In doing so, it diverts the forces from the more vulnerable parts of your body: the groin, stomach and neck. Keep in mind, however, that safety harnesses are designed to protect you in a fall and, unlike harnesses such as those used for mountain climbing, are not designed for prolonged suspension. The same technology used to distribute force throughout your body could cut off circulation, leading to suspension trauma.
In addition to distributing force, the design of a full body harness serves to keep an employee upright in a fall. This allows a deceleration device to properly deploy, but also keeps the spine vertical, which is the position in which it can best absorb compressive forces of a fall. Ultimately, this position is the optimal position for rescuing or lowering a worker to a safe location. Even so, this upright position could cause blood to pool in the legs. Upon retrieving a fallen worker, emergency personnel will often lay him or her down. The blood that had been pooled in the legs can, in this situation, rush to the heart causing cardiac arrest. This is why rescue plans are so critical. This potentially fatal result of suspension could occur after as little as 10-20 minutes.
Remember, as I stated in the aforementioned article, none of this matters if the harness isn’t worn properly or does not properly fit the user. Adjust all of the straps and buckles to ensure a snug, but not overly-tight fit. It is important to note that while that the majority of harnesses out there were not designed with women in mind. While a typical harness will do the required job, there are women’s harnesses on the market that do things such as keep shoulder straps to the side of the chest, support the hip and pelvic area different, and/or reduce stress on the lower back. Research the products available to you, and make sure to select the harnesses most appropriate for you or your workforce.
Nothing could be worse in safety than a false sense of security. Somebody who believes they are protected by a certain piece of equipment might take more chances – even unknowingly – than they would if they believed they had no protection at all. Yet, we see it every day: a railing that isn’t secured, a body harness that doesn’t fit properly, a respirator that hasn’t been fit to the user’s face. These are just a few examples, but there are countless others out there.
While this is a dangerous phenomenon regardless of which hazard is supposedly being abated, it is particularly deadly when dealing with fall protection. One mis-step could cost an employee their life if they are not properly protected. So, have your workers been trained? Do they even know if they are using their fall protection properly?
To determine this, we first must give a brief rundown of what fall protection is. Usually, when employees are told that fall protection is required, they automatically refer to it as being “tied-off”, but being tied-off is just one way of achieving fall protection. Actually, there are two types of fall protection: fall prevention and fall arrest.
Fall Prevention vs. Fall Arrest
Fall prevention includes, but is not limited to, solid rails, wire rope rails, and even travel restraints (harnesses attached to lanyards that do not let you reach the edge from which you could fall). Fall arrest is what employees often mean by “tied-off” – a harness, lanyard, and anchor point.
Let’s focus on this grouping, known as a Personal Fall Arrest System (PFAS). When using a PFAS, the first thing you, as a worker, are going to do is put on your harness. There is a lot of room for mistakes here. Somebody who has never worn a harness before or has not been trained in the proper way of using one might pick one up, stare at the jumble of straps and buckles, and feel completely lost. Maybe they’ll ask for help, but it’s likely they’ll struggle through, do their best to put the harness on, and get it completely wrong. This leaves them dangerously unprotected. Workers MUST be trained in the proper use of the fall protection they will be using, as well as the fall hazards they will face.
Proper Harness Usage
Once trained, the first thing that MUST be done when donning a harness is to inspect it. Whether you ever actually fall or not, you must treat this piece of equipment as if it is going to save your life EVERY time you put it on. Check every strap for signs of wear, every buckle, every plastic fitting, every grommet. Check the tag to find out when it was last inspected by your company’s competent person. If you feel the harness is good for use, then it’s time to put it on.
The easiest way to orient the harness is to grab the D-ring (obviously if it is a harness with multiple D-rings, we are talking about the one that goes in the middle of your back) and let the harness hang. This will give you a better idea of where the shoulder straps, chest strap, and leg straps are. Step into the leg straps (unless they are the type with grommets that you will secure later) and put the straps over your shoulders. Connect the chest strap. Before going any further, have a second person check the harness. You don’t want any twists in the straps and there is no way you can see everything behind you. This is a step that is OFTEN skipped.
Now that you’ve got the harness on, you need to adjust it. How often do you see the construction worker with the leg straps of their harness dangling a foot below their groin? Or a D-ring either at the small of a workers back or being pulled over to the side? How often are buckles not buckled? By treating this as a dog-and-pony show, you put yourself at serious risk. Leg straps that are too loose can shoot upward in a fall, rupturing testicles. A loose chest strap could allow you to shoot right out of your harness in a head-first fall, like a sausage being squeezed from its casing. Straps that are too tight could cut off circulation. It is imperative that all adjustments be properly made. For the leg straps, the one adjustment that seems to be wrong most often, use this rule of thumb: once adjusted, you should be able to slide an open hand between the strap and your leg, but not a closed fist. Once you’ve made all of your adjustments, tuck the ends of your straps into the provided fasteners. You don’t want a piece of the harness flopping around either to be caught in a piece of equipment or to be knocked loose.
Proper Lanyard Usage
Now, if you’ve done this correctly, you’re ready to attach your lanyard. However, do you know which lanyard you should be using or did you just take whatever was in the gangbox? Before selecting your lanyard you need to ask one simple question: how high above the lower level is my anchor point? The last thing you want to do is to think you are protected, only to discover that when fully deployed, your PFAS allows you to strike the lower level. I’ve seen workers ten to twelve feet off the ground using 6’ lanyards with deceleration devices. If they had stopped to calculate their fall distance, they would have realized that they actually needed 6’ for the length of the lanyard, plus 3.5’ for the length of the deceleration device once deployed, plus 1-2’ of sag in the system/harness, plus 4-5’ of body length below the D-ring. That’s 15.5-16.5’ of clearance needed from the anchor point. Of course, it doesn’t hurt to add a little extra to be on the safe side. I personally do not allow the use of 6’ lanyards with deceleration devices unless the anchor point is at least 18’ above the lower level. If you don’t have this distance available, you need to look at other options, such as a retractable lanyard or railings. Retractable lanyards will lock within a few feet of detecting a fall.
If you’ve selected the proper lanyard, is it attached properly? For a lanyard with a deceleration device, you want to ensure the deceleration device is attached to your D-ring. This will help to ensure that nothing interferes with its proper deployment. For a retractable, the casing should be attached to your anchor point. If you’ve got a lanyard that looks like a bungee cord, it can be worn either way. Just ensure the lanyard you are using has never been deployed. That’s easy for a deceleration pack because you would be able to see that it was open, but for a bungee-style cord, you may not be able to tell. In order to find out, at one end you will notice a red tag tucked into the webbing. If this is out, the lanyard has been involved in a fall and must be taken out of service. Retractables have different ways of notifying you, so make sure you check the user manual to know exactly what to look for during inspection.
Proper Anchor Point
So you now have your harness on properly and have selected the appropriate lanyard. What do you tie-off to? Will any pipe do? OSHA states that “Anchorages used for attachment of personal fall arrest equipment shall be…capable of supporting at least 5,000 (22.2kN) per employee attached.” [29 CFR 1926.502(d)(15)]. Five-thousand pounds per employee attached. If you are not using structural steel or an engineered anchor point (such as in an aerial lift or on a device manufactured for fall protection), you need to know for sure that the anchor point is sufficient. This must be done by a ‘qualified person’ which is normally interpreted in this situation as a registered professional engineer.
Proper Fall Clearance
In addition, your anchor point should limit your free-fall distance to 6’ or less. If you are using a 6’ lanyard with a deceleration device and you are tied off at your feet, you will free-fall more than 10’ before the deceleration device engages (6’ length of the lanyard plus at least 4’ from your feet to the D-ring). This will place dangerous forces on your body’s internal organs. Always look for an anchor point that is at least level with your D-ring. If this is not feasible, other alternatives must be considered, such as railings, retractable lanyards, nets, etc. (some manufacturers do produce lanyards that allow a 12’ free-fall while keeping the forces below acceptable levels, but standard lanyards allow for 6’).
Real Fall Protection
As you can see, it’s not as simple as throwing your harness on and going to work. Not if you want to be protected. Following all of the steps listed above helps you to work safely at heights, but nothing is as important as good training – which is required by OSHA for anybody using fall protection [29 CFR 1926.503]. And, remember, when you are provided with a harness, a lanyard, and an anchor point, use them. Wearing your harness and hooking both ends of the lanyard to it does you no good in a fall. Many workers have died while wearing harnesses and lanyards simply because they never hooked their lanyard to the anchor point. In the end, there’s only one person who can be fully responsible for your well-being: YOU!
One of the most overlooked areas of a fall protection plan is the rescue section. For many professionals, this is due to heavy emphasis put on protection and prevention rather than rescue and retrieval.
From a young age we learn that 911 is THE ANSWER when any accident happens. In fall protection planning, stating that you will call 911 is not sufficient. A detailed rescue plan should be established and thoroughly understood by all workers. By including a rescue section in your fall protection plan you can limit exposure to risk and combat suspension trauma.
Do You Need A Rescue Section?
Rescue sections are only required in fall protection plans that have fall arresting components as opposed to fall prevention and restraint. Even if your fall protection plan does not require a rescue section it is in the best interest of you and your workers to include one.
What is a Fall Rescue Plan?
A rescue plan is a strategy or procedure, planned in advance, to safely retrieve a person who has fallen from an elevated work surface and is suspended in a full body safety harness. This may include self-rescue or a mechanically aided rescue using a davit arm or rope and winch. This plan must be documented! A rescue plan should be worksite specific.
Fall Protection Rescue Plans are Required By OSHA
For the Construction Industry, according to OSHA 1926.502(d}20: “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves”
For General Industry, according to OSHA 1910.140(c}21: “The employer must provide for prompt rescue of employees in the event of a fall”
Factors to Consider When Planning A Prompt Rescue
- Hanging in a harness vertically can cause a person to lose consciousness
- Suspension trauma varies from person to person
- Rescuing a worker from a fall is just as important as preventing a fall
- Making sure that rescue equipment is readily available (Rescue Safety Equipment)
- Identifying the type(s) of system you will use
- Providing training for all employees
Rescues are dangerous and should be planned carefully. Confined space is especially dangerous. According to the CCOHS, each year, 60% of confined space fatalities are would-be rescuers! Employees who are not properly trained for a confined space rescue place high risk on themselves and the entrant(s).
Types of Rescue Techniques
- Non-entry - a rescue that is conducted without entry into the confined space. A rope or winch is typically used.
- Entry by others - Most companies do not have trained employees for emergency rescue, these rescue attempts are led by a local fire department.
- Entry by trained employees of the company - This is ideal for a prompt rescue, each employee should be trained and at least one member should CPR certified
Rescue planning is essential to the safety of workers. To begin developing a documented rescue plan you can use a fall protection rescue plan template. For a successful rescue plan the IC (Incident Commander) as well as the rescue team will need to take charge and think through the entire rescue process so the worker does not get injured or die from suspension trauma.