When it comes to fall protection, statistics show regulations alone are not working. The Dept. of Labor’s Bureau of Labor Statistics has seen workplace, fall related fatalities increase, despite improved technology, suggesting better training and controls are necessary.

These figures do not portray motivated individuals or companies taking a long, hard, look at their fall protection programs.

Some of the shortcomings are seen with companies that equate the term “General Industry” to manufacturing businesses alone, and don’t believe their company is required to follow the these
safety requirements. Compounding the problem, regulation language tends to be comprised of “legalese,” which is challenging to sift through and comprehend.

Individuals and their companies must spend time with these regulations in order to possess a thorough understanding and how to apply them. OSHA is a good start for a business to begin developing or evaluating its safety program if we keep in mind the word “start.”

OSHA provides businesses with a minimum standard of safety for safety professionals and consultants to build a proactive program, which should include components such as ANSI and
ASTM Standards and Industry Best Safety Practices. Personal protective equipment alone is not working. Companies rely on personal protective equipment as a quick fix to absolve and correct their workplace hazards. Unfortunately, the use of equipment is highly defeatable (Hierarchy of Controls) and ultimately less cost effective due to the associated training, re-training, replacement costs, as well as, a high reliance on worker behavior.

Training is not working in its current format. As we try to decide between Behavior Based or Incentive Based training, our workers are being trained by 10-30 minute videos so we can “check” the completed box. However, the ineffectiveness of current training methods is indicated in the safety statistics for workplace injuries and fatalities.

A successful “Safety Cowboy” requires knowledge. We must know the requirements, understand how to apply them, and realize when they are not enough, and how to strengthen (not bypass)
them to improve worker safety.

OSHA 1910 requires adequate fall protection when employees work four feet or above the lower level for General Industry sites (Retail, Commercial, Educational, Manufacturing, Hospital, Amusement Parks, etc.). Typical work-at-height activities include:
• Window Washing for Mid to High Rise Facilities;
• Roofing Activities;
• HVAC Maintenance;
• Machine Repair;
• Cranes;
• Conveyors;
• Processes;
• Ride/Attraction Inspection;
• Lifts;
• Ladders;
• Scaffolds; and
• On-Site Construction Activities.

The proposed ANSI Z359.1 Managed Fall Protection Standard addresses existing elements of a fall protection program; identifies missing elements; strengthens critical fundamentals and provides us with guidelines to own and use an effective fall protection program.

Generating a proactive approach to fall protection safety is a critical key to protecting our people while they work at heights. A strong fall protection program involves understanding what is adequate
and what is not. Adequate fall protection requires a pre-plan, training, design, job hazard analysis and competent knowledge of the regulations, standards and industry best safety requirements and practices.

The safety decision we make must be based on a thorough knowledge of the requirements and their application to the safety of our workers. Knowledge helps us to be practical and innovative in our fall protection approach, which should include the following:

• Preplanning;
• Fall Protection Regulations, Standards, and Best Practices;
• Engineering/Architecture Safety Design;
• Construction Safety;
• Hierarchy of Fall Prevention;
• Training;
• Fall Protection Equipment;
• Job Hazard Analysis;
• Abatement Options;
• Anchorage, Clear Height, Swing Fall Factors; and
• Rescue.

Our safety knowledge should include three recent ANSI Standards to incorporate into our safety culture: proposed ANSI Z359.1 – Managed Fall Protection; ANSI/IWCA 1-14.1Window Cleaning Standard; and1926.550 – Crane and Derricks. In addition, ANSI Z490.1 for training provides excellent guidelines to develop and/or strengthen your safety training program.

A successful ‘Safety Cowboy’ knows what is not working in our safety programs. This requires the ability to assess current conditions and strong problem solving capabilities to address and resolve these safety challenges.

The most common problem areas for fall protection include:
• Training – Lack of or Inadequate;
• Safety Design Criteria for Engineers, Architects and Contractors;
• Contract Safety Requirements for the Design, Renovation and Purchase of Facilities and Machines;
• Safety Requirements for the Purchase of Fall Protection Systems;
• Safety Criteria for the Design of Fall Protection Systems – Restraint, Arrest, Horizontal and Vertical Lifelines and Rescue;
• Outside Contractor Safety Requirements and Enforcement – OSHA Multi-Employer Policy;
• Owner and/or Management Support via Behavior and Resources;
• Qualified – Qualified Persons;
• Rescue Programs vs. 911;
• Job Hazard Surveys – Lack of or Inadequate;
• Cross Responsibilities without Adequate Safety Training;
• Enforcement with Consequences; and
• Insufficient, Dedicated Safety Time.

These “problem” areas can be addressed—when and if–adequate training takes place; please note the emphasis is adequate vs. inordinate. In our culture of checklists, fast-paced technology and cross-tasking, we neglect the art of problem-solving. Knowledge is the basis of innovation and clear thinking in problem solving. It allows us to follow the rules in a practical manner to maintain an effective/productive facility.

A successful ‘Safety Cowboy’ knows and lists what needs to be done. Based on our experience with the engineering and training of fall protection, five primary safety values always cause a stampede for our clients.
1. Engineers, Architects, & Contracts – Design Community;
2. Contract Safety
Language;
3. Training;
4. Rescue; and
5. Behavior/Attitude.

These are not the only challenges; however nine out of 10 fall protection elements can be categorized under these headings. Over the years, the most typical questions asked revolve around these
five issues.
• Why didn’t the engineer/architect/contractor “design out” the hazard during the blue print or conceptual stages?
• Why do we buy workplace hazards?
• What is adequate training?
• What is prompt rescue?
• How do we develop safe work behavior? Why didn’t the engineer/architect /contractor “design out” the hazard during the blue print or conceptual stages?

The design community does not “design out” safety, due to lack of knowledge, their definition of safety, and because WE did not require safety (our definition or need) of their service or product. Want to start a shoot out? Try telling traditional engineers they are not safety conscious. We were caught in a cross
fire a few years ago with civil engineers who insisted we were wrong.

Why? In their definition of safety, they were considering the requirements for which they were responsible. Seismic, building codes, wind, etc., safety issues were of utmost importance to this
group. However, designing safety requirements for construction, maintenance and use were not in their scope of education, experience or responsibility. It was not an issue of neglect but more of “they didn’t know what they didn’t know”.

Why do we buy workplace hazards? We continue to bring hazards into the workplace via the purchase of design, renovation programs for facilities and machinery. Why? We do not include safety professionals (in-house or consultants) in the development or decision making phases of buildings, machines or safety equipment.

Our purchasing contracts rarely include safety requirements such as third party testing verification, and even more rarely do we provide safety training to our purchasing divisions so their decisions include safety requirements. Many of us purchase equipment and machines from outside the U.S. but do we evaluate safety criteria or require these manufacturers to comply with U.S. safety regulations.

The process of ‘buy, use, identify hazards and retrofit’ is definitely a case of stepping over a dollar to pick up a dime. We are the consumer and have the right and responsibility to purchase safe products
and services. If they want to continue being a vendor for your business, safety training and knowledge is a must.

What is adequate training? Addressing adequate training is similar to answering why the chicken crossed the road. We need to examine if the training we provide is appropriate to what we require
of our at-risk worker (Authorized Person), supervisors and engineers. Does our training satisfy the requirements for these employees to safely preplan, perform, return or rescue according to their
fall protection roles and responsibilities?  FSM