Fall Protection and OSHA
What is fall protection?
Go to any construction site and watch those who are working above a lower level. Should they be wearing fall protection? Should they be protected by fall-protection systems? Should they be using fall-protection methods? Do they need fall-protection training? Are they following fall-protection rules? Fall protection is a concept that’s hard to describe. Ask 10 people what fall protection means and you’re likely to get 10 different answers. Is it possible to make sense of fall protection? We think so.
On a Friday in June, an estimator arrived at a remodel job to look at a cedar-shake roof and estimate
the cost of an addition that a construction crew was building. He spoke to the supervisor at the site and climbed to the roof through an open skylight, using a metal extension ladder.
However, he was unaware that the contractor had used a sheet of thin insulating material to cover three 2-by-6-foot skylight openings in the roof (it had rained the day before). He stepped onto the insulating material, fell through one of the skylights, and landed on his back, 15 feet below.
The supervisor and two subcontractors heard the estimator fall and rushed to the accident. One of the subcontractors used his cell phone to call emergency medical services. EMTs arrived about five minutes later, stabilized the victim and took him to a hospital where he underwent emergency surgery for spinal injuries.
On a frosty December morning in southern Oregon, three electricians were on a store rooftop installing electrical wiring for an air conditioning upgrade. They began reeling out no. 4 copper wire. The supervisor held the reel as the journeyman electrician walked backward
about 185 feet toward the edge of the roof, pulling and twisting the wire to straighten it.
When he got close to the edge of the flat roof, he stumbled and fell over the 12-inch parapet at the roof’s edge. He was able to grab onto the parapet with one hand, but fell before the supervisor could reach him.
He fell about 22 feet to the ground.
Another employee dialed 911 and went to the aid of the injured worker. The worker suffered a punctured lung, severe head injuries, a fractured knee, and broken ribs, clavicle, and wrists. It had been his first day on the job.
How should we protect ourselves from falling?
For many in the construction industry, fall-protection equipment is the first thing that comes to mind: personal fall-arrest systems, safety nets, or guardrails, for example. But fall protection means more than equipment. Fall protection is what you do to eliminate fall hazards, to prevent falls, and to ensure that workers who may fall aren’t injured.
You accomplish fall protection by doing the following:
- Make fall protection part of your workplace safety and health program.
- Identify and evaluate fall hazards.
- Eliminate fall hazards, if possible.
- Train workers to recognize fall hazards.
- Use appropriate equipment to prevent falls and to protect workers if they do fall.
- Inspect and maintain fall-protection equipment before and after using it.
- Become familiar with Subdivision 3/M fall-protection rules.
What is your fall-protection role?
Everyone involved in a construction project has a role to play in preventing falls.
- Employers. Identify fall hazards at the site. Eliminate the hazards, prevent falls from occurring, or ensure that if falls occur, employees aren’t injured. Make sure that employees follow safe practices and are trained to recognize fall hazards.
- Employees. Follow safe work practices, use equipment properly, and participate in training.
Learn to recognize unsafe practices, know the tasks that increase the risk of falling, and understand how to control exposure to fall hazards.
- Architects and engineers. Educate employers about hazards that could expose workers
to falls during each phase of the project. When designing buildings and structures, consider fall protection and other safety needs of those who will do the construction work.
- Building owners and managers. Ensure that those who do exterior construction or maintenance work know how to protect themselves from falls, are aware of installed anchorages, and know how to use their fall-protection equipment.
- Equipment manufacturers. Ensure that fall-protection equipment meets federal OSHA and ANSI safety requirements and protects workers when they use it properly. Warn workers through instruction manuals and on equipment labels about the danger of using equipment improperly.
- Lawyers. Review your client’s construction bids to ensure that they comply with Oregon OSHA requirements. The documents should clearly state the client’s responsibilities for protecting workers from falls and for identifying and controlling hazards that cause falls.
Make fall protection part of your workplace safety and health program.
A workplace safety and health program is what you and your co-workers do to achieve and maintain a safe, healthful workplace. There are as many types of safety and health programs as there are workplaces, but not all programs are successful. What makes a successful safety and health program? There are seven elements:
Commitment. All employees — including company executive officers, managers, and supervisors — are committed to making the program succeed.
Accountability. All employees — including company executive officers, managers, and supervisors — are held accountable for following safe work practices.
Involvement. All employees, including managers and supervisors, participate in making the program succeed.
Hazard identification. All employees are trained to identify hazards, and there are procedures for conducting hazard inspections and reporting hazards.
Accident investigation. Managers and supervisors promptly investigate all accidents and near misses, then determine how to eliminate their causes.
Training. All employees receive training in identifying workplace hazards and learning safe work practices.
Evaluation. Managers and supervisors, with help from other employees, evaluate the program’s strengths and weaknesses at least once a year.
Before you begin a construction project, think about the hazards workers may encounter and what you can do to keep them safe. A successful safety and health program will protect workers from falls.
Prepare a safety and health policy
Does your company have a written safety and health policy? It should. A written policy reflects commitment to a safe, healthful workplace, summarizes management and employee responsibilities, and emphasizes the safety and health program’s role in achieving that goal. Keep the policy brief, commit to it, and enforce it.
Designate competent persons and qualified persons
The competent person will be responsible for inspecting all fall protection equipment, barricades, and tie off points before use every day. Only qualified persons may use fall protection equipment. The competent person shall ensure that all personnel are trained in the use of fall protection equipment. No fall protection equipment may be in use unless the designated competent person is on site and able to supervise. A secondary competent person may be designated to ensure that a competent person is on site at times. The person that is serving as the competent person at any given time must be informed that they have been designated and are responsible for the fall protection at that specific time.
You’ll find activities throughout OSHA’s workplace safety and health rules that are required to be conducted by competent and qualified persons.
Competent person and qualified person are terms that federal OSHA created to designate individuals who have the training and expertise to evaluate hazardous conditions, inspect equipment, evaluate mechanical systems, or train others how to work safely.
Who can be competent and qualified persons? OSHA offers the following definitions:
- The competent person. “Competent person means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” [1926.32(f)]
- The qualified person. “Qualified means one who, by possession of a recognized degree, certificate, or professional standing or who, by extensive knowledge, training, and experience,
has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” [1926.32(m)]
Determining who can be a competent or qualified person.
Although federal OSHA defines competent and qualified persons, it doesn’t provide specifics for determining who can assume these roles. The following guidelines may help:
- Know the OSHA rules that apply to your workplace. The rules will tell you if you need to designate a competent or a qualified person.
- If an OSHA rule that applies to your workplace requires a competent or a qualified person, note duties and responsibilities that the rule requires the person to perform.
- If an OSHA rule that applies to your workplace requires a competent person, that person must have the authority to take prompt corrective measures to eliminate hazards.
- Determine the knowledge, training, and experience the competent or qualified person needs to meet the rule’s requirements.
- Designate a person who has the knowledge, training, and experience that meets the rule’s requirements.
- Duties and responsibilities of competent and qualified persons required by Subdivision 3/M.
The competent person
- Serves as the monitor in a safety-monitoring system and is responsible for recognizing hazards that cause falls and warning workers about them.
- Determines that safety nets meet Subdivision 3/M requirements.
- Inspects a personal fall-arrest system after it arrests a fall and determines if the system is undamaged and can be used again.
- Evaluates any alteration in a personal fall-arrest system and determines if the system is safe to use.
- Supervises the installation of slide-guard systems.
- Trains employees to recognize hazards that cause falls and to follow procedures that minimize the hazards.
The qualified person
- Supervises design, installation, and use of horizontal lifeline systems to ensure that they can maintain a safety factor of at least two — twice the impact of a worker free-falling 6 feet.
- Supervises design, installation, and use of personal fall-restraint anchorages.
- Supervises design, installation, and use of personal fall-arrest anchorages.
- Makes a daily inspection of fall protection and fall prevention equipment and ensure it is in good working order and ready for use and meets requirements of OSHA and company policy. This includes the inspection of all areas where employees are expected to work that day. This inspection is to be logged in the Daily log. The competent person is not to allow any employee to work in an area that does not have adequate fall prevention or fall protection in place.
Each job site must have a designated competent person assigned.
How to evaluate fall hazards
The purpose of evaluating fall hazards is to determine how to eliminate or control them before they cause injuries. Below are important factors to consider in conducting an evaluation.
- Be sure to ask questions. Call one of the safety supervisors or safety managers for advice, call the Director of Safety and Loss Prevention for assistance. E Light Electric management is ready and available to assist you with your safety needs.
- Determine how workers will access elevated surfaces to perform their tasks. Will workers be using portable ladders, supported scaffolds, aerial lifts, or suspension platforms to reach their work areas? Which ones will they use? How and where will they use the equipment?
(Parts Four and Five describe the hazards associated with this equipment and how to use the equipment safely.)
- Identify tasks that could expose workers to falls. Using a set of work site plans, review the entire construction project. Evaluate each phase of the project from the ground up. Ensure that all walking/working surfaces have the strength to support workers and their equipment, then identify all tasks that could expose workers to falls. A walking/working surface is any surface, horizontal or vertical, on which a person walks or works.
- Identify hazardous work areas.
Determine if workers’ tasks could expose them to the following fall hazards:
- Holes in walking/working surfaces that they could step into or fall through.
- Elevated walking/working surfaces 10 feet or more above a lower level.
- Skylights and smoke domes that workers could step into or fall through.
- All openings such as those for windows or doors that workers could fall through.
- Trenches and other excavations that workers could fall into.
- Walking/working surfaces from which workers could fall onto dangerous equipment.
- Hoist areas where guardrails have been removed to receive materials.
Sides and edges of walking/working surfaces such as established floors, mezzanines, balconies, and walkways that are 6 feet or more above a lower level and not protected by guardrails at least 39 inches high.
- Ramps and runways that are not protected by guardrails at least 39 inches high.
- Leading edges — edges of floors, roofs, and decks — that change location as additional sections are added.
- Wells, pits, or shafts not protected with guardrails, fences, barricades, or covers.
Determine how frequently workers will do tasks that expose them to falls. The more frequently a worker is exposed to a fall hazard the more likely it is that the worker could fall.
Determine whether workers need to move horizontally, vertically, or in both directions to perform their tasks. How workers move to perform tasks can affect their risk of falling. Knowing how they move to perform tasks can help you determine how to protect them.
Determine the number of workers exposed to fall hazards. Generally, the more workers that are exposed to a fall hazard, the more likely it is one could fall.
Identify walking/working surfaces that could expose workers to fall hazards. Examples: floors, roofs, ramps, bridges, runways, form work, beams, columns, trusses, and rebar.
Determine fall distances from walking/working surfaces to lower levels. Generally, workers must be protected from fall hazards on walking/working surfaces where they could fall 10 feet or more to a lower level.
However, workers must be protected from falls of 6 feet or more from any of the following:
- Holes and skylights in walking/working surfaces.
- Wall openings that have an inside bottom edge less than 39 inches above a walking/working surface.
- Established floors, mezzanines, balconies, and walkways with unprotected sides and edges.
- Excavations with edges that are not readily seen because of plant growth or other visual barriers.
- Wells, pits, shafts and similar excavations.
Workers must also be protected from falling onto or into dangerous equipment.
Ensure that existing guardrails and covers meet Subdivision 3/M requirements. Guardrails must be designed and built to meet the requirements of 1926.502(b).
Covers must meet the requirements of 1926.502(i). (See Part Six for more information on guardrail systems and covers.)
Identify fall hazards that you can eliminate. Eliminating a fall hazard is the most effective fall-protection strategy. Ways to eliminate fall hazards:
Perform construction work on the ground before lifting or tilting it to an elevated position.
Install permanent stairs early in the project so that workers don’t need to use ladders between floors.
Use tool extensions to perform work from the ground.
Identify fall hazards that you can’t eliminate. If you can’t eliminate fall hazards, you need to prevent falls or control them so that workers who may fall are not injured.
Ways to prevent falls include covers, guardrails, handrails, perimeter safety cables, and personal fall-restraint systems.
Ways to control falls include personal fall-arrest systems, positioning-device systems, and safety-net systems. Use these fall-protection systems only when you can’t eliminate fall hazards or prevent falls from occurring.
Consider administrative practices. Administrative practices help prevent falls by influencing the way people work. Examples include substituting a safe work practice for a risky one, training
workers how to do their jobs safely, and disciplining those who don’t follow safe practices.
Determine whether anchorages are necessary. If workers use personal fall-arrest or restraint systems, they’ll need secure anchorages for their lifelines or lanyards. Anchorages for personal fall-arrest systems must be able to support at least 5,000 pounds per attached worker or be designed with a safety factor of at least two — twice the impact force of a worker free-falling 6 feet. Anchorages for personal fall-restraint systems must be able to support at least 5,000 pounds per attached worker or be designed with a safety factor of at least two — twice the peak anticipated dynamic load.
Consider other factors that could increase the risk of falls. Consider the environment. Will workers’ tasks expose them to overhead power lines? Will they need to use scaffolds, ladders, or aerial lifts on unstable or uneven ground? Will they be working during hot, cold, or windy weather? Consider ergonomics. Will workers need to frequently lift, bend, or move in ways that put them off balance? Will they be working extended shifts that could contribute to fatigue?
Summary: evaluating fall hazards
- Identify tasks that could expose workers to falls.
- Identify hazardous work areas.
- Determine how frequently workers will do tasks that expose them to falls.
- Determine whether workers need to move horizontally, vertically, or in both directions to do their tasks.
- Determine the number of workers exposed to fall hazards.
- Identify walking/working surfaces that could expose workers to fall hazards.
- Determine fall distances from walking/working surfaces to lower levels.
- Ensure that existing guardrails and covers meet Subdivision 3/M requirements.
- Identify fall hazards that you can eliminate.
- Identify fall hazards that you can’t eliminate.
- Determine whether anchorages are necessary.
- Consider other factors that could increase the risk of falls.