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10 Fall Protection Tips for 2018

Fall Protection Tips for 2018

As we venture into a new year, it’s a good time to take stock of where we are and where we’re headed. It’s no secret that falls have been the leading killer in construction for more years than we care to remember and that fall protection (training or otherwise) has led OSHA’s Top Ten list of violations for way too long. Some way, somehow, we’re just not getting this right. As 2018 begins to pick up speed, here are ten things to consider that can help you do your part to prevent falls.

Plan Ahead for Fall Protection

In my experience, failure to provide employees proper fall protection stems greatly from a lack of planning. When we evaluate the upcoming work, look at plans, develop a safe, compliant method of fall protection, purchase the equipment, train our workers, and implement our plans properly, our people tend to be safe. However, when we leave fall protection to be last-minute field decisions, it’s rare that the proper equipment is available or that the site employees aren’t already feeling the pressure of schedule so that when they don’t have a compliant solution, they just get to work anyway. In some instances, site workers have usable equipment and want to do the right thing, but aren’t trained in what, exactly, that “right thing” is. Selecting proper anchor points and determining fall clearances are not things an untrained person will know how to do properly. All of this is eliminated when we plan.

Know What is New

Perhaps we can manage to be safe, but we certainly can’t be compliant if we don’t know what the latest regulatory requirements are. Last year, OSHA released its new Walking/Working Surfaces rule. This rule contained specific fall protection information for General Industry that had previously been found in the Construction regulations. Until the release of this rule, the General Industry standards did not address such things as Personal Fall Arrest Systems (PFAS). Also, other fall protection changes were made, such as the allowance for a Desginated Area for work on roofs and new standards for what qualifies as fall protection on fixed ladders. Those in manufacturing, warehousing, and other industries governed by 29 CFR 1910 should familiarize themselves with these rules if they are working at heights.

Know What Applies

Speaking of General Industry and Construction regulations, it is extremely important to understand which standards apply to you and to know that it is possible that your operations span more than one set of regulations. It is not uncommon to see a company who follows construction regulations the majority of the time have to comply with general industry regulations at other times. An example might be a mechanical company that does new HVAC installations but also services these installations down the road. New installations would be under 29 CFR 1926 and maintenance services under 29 CFR 1910. Knowing this is especially important in fall protection where something as simple as the height at which you need to be protected changes between the two sets of regulations. Still, knowing what applies to you can go much deeper than construction vs. general industry. Some companies understand which standards apply, but ignore or misunderstand the applicability defined within. For instance, I have dealt with many steel erection companies that try to tell me, or my employees, that nobody on their crew is required to have fall protection until 30’, this couldn’t be further from the truth. That rule actually states that Connectors, specifically defined in the regulation but often a team of 2 people, do not need to be tied off between 15’ and 30’ – or 2 stories, whichever comes first – but must be wearing all the proper fall protection equipment and have an available anchor point (Deckers, as well, get a similar exemption if utilizing a Controlled Decking Zone). That’s a big difference from “nobody needs fall protection until 30 feet.” (P.S. – that all goes out the window on a boom lift where all of the exemptions go away, and fall protection is required at all times).

Understand Fall Clearance

If you don’t recognize the term Fall Clearance, stop and review our fall clearance article for a quick refresher. Once you’re done you’ll probably fall into one of two camps: 1) I knew that or 2) I never stopped to think about that! Either way, it’s important that anyone planning fall protection be very familiar with Fall Clearance as well as it’s common pitfalls. Grabbing a harness and lanyard out of the job box will do you no good if the configuration of your fall protection equipment will allow you to strike a lower level. This is even worse when you are unaware that it will enable you to strike a lower level because the false sense of security you have may, in your mind, justify you taking more risks than you would have otherwise. Remember, if you’re wearing a 6’ lanyard with a deceleration device, the minimum height that your anchor point should be from the lower level is approximately 18.5’.

Have a Rescue Plan in Place

Most people think that a Personal Fall Arrest System (PFAS) is made up of three parts: the harness, the lanyard, and the anchor point. What’s missing from this equation is the life-critical rescue plan. Fall prevention plans such as guardrails and travel restraint don’t require rescue because nobody should be able to reach an unprotected edge, but the very nature of Fall Arrest means that if it has to be deployed, somebody will be left hanging from a platform, roof, or structure. That person is going to need to be rescued, and they are going to need to be rescued quickly. Once somebody falls and is saved by their PFAS, every minute is critical. Suspension trauma can begin to set in in a matter of minutes. This means that even though your worker was saved from the fall, their lives could still be in danger. Without a plan, you also run the risk of workers scrambling to attempt to rescue their co-worker in ways that could be putting their own lives in danger. The worst thing, however, would just be to realize that you don’t have the means to rescue somebody that has fallen. What could have been a happy moment turns to dread and helplessness? Planning is crucial; this includes calling your local fire department to visit the site, if you plan on summoning them for rescue, to ensure that they have the training and capability to rescue somebody. Discovering that you don’t have the means to rescue *after *the fact could be a fatal mistake.

Comfort Helps

While we’re talking about PFAS, it’s important to note that one of the challenges is getting people to wear the equipment and wear it properly. Let’s face it, harnesses and lanyards can be cumbersome or, at the very least, annoying and some people need to have them on for very long stretches of their day. If they’re uncomfortable, chest straps get loosened, leg straps unbuckled, and lanyards get left lying around. While it certainly isn’t required for you take comfort into account when purchasing your equipment, it could be helpful in ensuring compliance. If you look at all the available options for safety harnesses, you could find everything from no-frills harnesses for $60 to $200+ harnesses complete with padding. You can find heavy steel-cased retractable lanyards or lightweight, portable plastic cased ones. From a performance perspective, as long as the equipment meets the ANSI standards, it should all do the same thing. The difference is going to be in additional features and comfort. Perhaps spending a few more dollars here could result in your workers wearing the equipment correctly.

Collective Fall Protection

Not all fall protection involves harnesses and lanyards. Collective fall protection – also called passive fall protection – is a very effective method and, often, is the simplest for your workers. Guardrail systems like KeeGuard are a means of collective fall protection. One installation protects all the workers in the area. We call these systems passive systems because no one has to take any particular action to utilize them. As opposed to a PFAS where the user would need to don their harness, adjust it to the proper size, clip their lanyard to their D-ring and to an anchor point that was hopefully selected ahead of time, passive systems require nothing more than you going to work in that particular work area. This eliminates some of the risks caused by human error. Not all, mind you because humans still set up the guardrail in the first place, but some. Even when guardrail is installed correctly, there are still some inherent risks. Lack of inspections, lack of maintenance, people removing rails for various reasons, people actively bypassing the rails, or simple complacency while around the rails, could all prove to be deadly, but they could also be easily managed. Assigning a small team to inspect and maintain a guardrail is much simpler than ensuring that 20 individuals are all tying-off properly and all have acceptable anchor points.

Warning Lines for Designated Areas

No single fall protection subject has caused more debate, in my opinion, than the allowance for a warning line system while working on roofs. The fact that is missed most often is that the allowance for such a system was designed only for roofers or those performing roofing work under the construction standard. Just about every trade has attempted to commandeer this solution since its release and telling them that it’s not allowed has made for many interesting days on the job site. In the years since this became a viable solution, the use of warning lines for other types of work has been clarified via OSHA Letters of Interpretation and even codified to some extent for General Industry in the form of Designated Areas. However, simply put, if you are not performing roofing work, you cannot have a warning line at 6’ from the roof’s edge; only roofers are allowed that distance (10’ if the mechanical equipment is being used perpendicular to the line). At 15’, other workers performing construction work could utilize the line, running the risk of a *de minimis *citation from OSHA (no monetary penalty). For workers not performing construction work, you can get a rundown of Designated Areas here. Who can and who cannot use warning lines is not the only part of this solution that gets confused. Another thing that often gets missed is that – for roofers – there is no situation in which they can use a Warning Line and not have a safety monitor (and that that monitor can have no other duties but to ensure nobody is getting too close to the lines). If you are considering using a warning line system, ensure that you fully research the requirements.

Fall Arrest vs Fall Prevention

Fall protection breaks down into a couple of different categories: fall arrest and fall prevention. They are what they sound like. Fall prevention prevents people from falling in the first place, while fall arrest slows and stops (arrests) somebody’s fall after they have fallen. Put that way; it’s easy to see which one is preferable. Let’s be clear: even a perfectly planned and perfectly executed fall arrest system could result in injury (not to mention the difficulty of rescue as discussed above). If you have the option to prevent falls, do so. Guardrails and travel restraint will keep people from getting hurt because when used properly, nobody will have the opportunity to fall – even a few inches.

Fall Protection Training

I could end every article this way. If your workers don’t know what they are supposed to be doing, the odds that they will do it are slim. Here’s an experiment: take a full body harness, find somebody that’s never worn it before and ask them to put it on. Give them no direction, just time them. When they think they’re done, see if it’s on and adjusted correctly. How long did it take for them to get it wrong? I still see it so many times – companies handing people fall protection equipment and telling them to get to work (if they give them fall protection equipment at all). Train your employees. Don’t leave their actions to chance. Let them know what they should be doing so that they can recognize when something isn’t right. And, when they come to you to tell you something isn’t right, hear them out. Don’t dismiss them as troublemakers or primadonnas. That concern that they’re voicing could save somebody’s life.

2018 is here and, as we all know, will be gone before we know it. Take stock now. Review your fall protection program, ensure everyone is trained, have a Competent Person inspect your equipment if you haven’t already. To not do these things is to play with the lives of your employees.

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This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

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http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 years. He achieved his CHST in 2005 and his CSP in 2010. Though he focuses on construction, his background includes manufacturing, recycling, and warehousing facilities as well. John holds a Bachelor's degree in English from The College of NJ.

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