Managers in charge of developing a fall protection program for a company must develop a policy that is in line with OSHA standards as well as existing company safety policies. The scope defines who the policy applies to, types of activities the policy applies to, locations the policy is in force, date the policy entered into force, duties and responsibilities of those involved in the fall protection program and delegation of those duties and responsibilities. Ongoing responsibilities include inspection, record keeping, maintenance, equipment replacement, incident reporting, enforcement, accident investigation, training and changes to the plan.

A hazard analysis, or fall hazard survey, is a key step in the development of a fall protection program. It identifies each fall hazard that exists at the facility and any other locations the policy covers.

Along with the location of each fall hazard, the analysis should include the type of hazard, a sketch of the hazard, how often workers are exposed to the hazard, duration of exposure, height of a potential fall, control method (see step 3 below), fall protection and rescue equipment to be used at the site of the hazard (if applicable), and environmental conditions that could affect selection of appropriate fall protection equipment. Environmental conditions might include presence of chemicals, sparks or flames, sharp or abrasive objects/surfaces, moving objects, and unstable/uneven/slippery surfaces, among others.

The fall protection hierarchy details the preferred methods of controlling a fall hazard. The ultimate control method is to engineer out the hazard, which is usually only an option during the design stage of a new facility. The next best control is to change work procedures so that workers are not exposed to the hazard. If an area must be accessed, the best control is to install passive fall protection systems such as guardrails, handrails and covers for floor openings. If passive fall protection is not a possibility, fall restraint systems that prevent the worker’s center of gravity from reaching the fall hazard should be used.

Extra diligence must be exercised with restraint systems because they do not double as fall arrest systems; a restraint lanyard will not reduce the forces of a fall. If none of the above methods will suffice, a fall arrest system, which is designed to reduce the forces of a fall, should be used. Whenever a fall arrest system is in place, a rescue plan must also be in place. The potential for injuries necessitates timely rescue. The injury may have been the cause of the fall, or an injury may have occurred during the fall.

Furthermore, a worker hanging in a harness may suffer from suspension trauma, a condition in which lack of motion and constricted veins may cause blood to pool. Suspension trauma does not always result in long-term injuries, but the possibility demands prompt response. The most important elements of the rescue plan are identification of the rescuer, that is, who will perform the rescue (in-house personnel, emergency services or a combination of the two), and what type of rescue system or equipment will be used at each fall hazard. Rescue should be as simple and as safe as possible.

Classroom education for authorized persons – workers that will be exposed to fall hazards on a regular basis – should begin with coursework that teaches the trainee how to recognize fall hazards, how to eliminate or control fall hazards, applicable regulations including OSHA and ANSI and the worker’s responsibilities under those standards, and how to use written fall protection procedures.

A more hands-on portion of training should include how to select, inspect, use, store and maintain fall protection equipment. Training should occur whenever a new employee is brought on board, and periodic assessments of employees’ knowledge and skills – including written assessments and skills demonstrations – should be conducted at least annually. Standards require refresher training every two years at a minimum, sooner if the work place changes, new systems/equipment are issued, or the worker doesn’t display adequate knowledge.

Equipment should be inspected prior to and following each use. When inspecting equipment, ensure all required markings and labels are present and legible; make sure all elements affecting equipment form, fit and function are present; and look for evidenceof defects in or damage to hardware, straps, rope or cable, mechanical devices and connectors, including evidence that the equipment has been subjected to a fall event.

Equipment must pass a more rigorous inspection according to the timeline set by the manufacturer. A supervisor or safety manager (program administrator, qualified or competent person) should inspect each piece of equipment according to the manufacturer’s instructions and record the date of inspection and condition of each piece of equipment.

Certain items, such as self retracting lifelines, must be sent to an authorized repair facility for servicing and recertification.

Should a fall or near-miss occur, the manager or supervisor should conduct an incident investigation, the results of which should be recorded and kept on file. Investigations will help determine if the fall protection program has established the appropriate control method for a given hazard, if the training is adequate, and what improvements are needed to ensure such an incident doesn’t occur again.

The fall protection program must be updated every time an investigation results in a recommendation for improvement, and whenever a new fall hazard is identified or an existing hazard is modified. A copy of the fall protection program should be kept wherever an active fall protection system is in use. FSM

Jim Hutter is a senior training specialist with Capital Safety, Red Wing, MN, which designs and manufactures height safety and fall protection equipment. For more information, go to www.capitalsafety.com or call 800-328-6146.