No one would argue over the
importance of reducing falls,
since workplace falls can result in serious
injuries and fatalities. But, if you ask what
should be done to reduce risks, you might get
glazed looks and a wide variety of answers.
Perhaps this is partly why preventing
falls is such a significant challenge for
safety professionals.
“It’s just plain common sense that
falling is dangerous, but protecting yourself
from a fall doesn’t register the same
way in the brain,” said Kevin Wilcox, PE,
CSP, and principal at LJB Inc., an Ohiobased
design firm.
“A worker in a manufacturing plant
doesn’t need significant instruction to
properly use safety glasses or a hard hat,”
said Wilcox. “But, using a safety harness
in a way that will save their life is just not
intuitive.”
Evidence of this misuse of fall protection
equipment is abundant and can be
seen at nearly any construction site,
among other places.
While Wilcox knows that improper use
of safety harnesses is not solely responsible
for an increase in fall fatalities, he
does point out a striking paradox.
Fall fatalities have increased 30 percent during the same period that overall workplace
fatalities decreased 12 percent. Additionally,
according to the Bureau of
Labor and Statistics (BLS), occupational
fall education and safety-related equipment
sales also increased during the same
1995-2007 timeframe. Clearly something
isn’t working.
Wilcox is on a mission to expose the
paradox – and save lives. Falls may not
be frequent, but when they do occur, serious
injuries—or even death—are a likely
result. Therefore, it is critically important
to fully understand the risk posed by fall
hazards. By basing decisions on a comprehensive
understanding of your fall protection
issues, you can make the most of
your fall protection investment.
Top Three Mistakes
The most common mistakes made by safety professionals attempting to confront
the fall protection issue are:
Mistake #1: Do Nothing — Don’t become
paralyzed by the apparent complexity
of the problem or the sheer number of
hazards and potential cost to abate them.
Both are common for any employer with
even a moderate-sized facility. To get
started, refer to the ANSI Z359.2 standard
and form a committee. The committee
can start identifying hazards and prioritizing
them based on the level of risk.
This strategy helps keep the team focused
on spending time and money
wisely. If you find yourself needing more
help, supplement the internal committee
with outside expertise from a Qualified
Person. Tapping into an expert in fall protection
helps you develop an effective program
from the outset – one that is
compliant, comprehensive and sustainable.
A facility manager may be afraid that if
a hazard is identified and not fixed, OSHA
will issue citations or insurance underwriters
may increase policy costs. Wilcox,
however, says this simply isn’t the case.
Wilcox says that regardless of whether a hazard is “known” or “unknown,” legal
precedent has established that an organization
could be held responsible. Therefore,
a “hear no evil — see no evil”
approach doesn’t let you off the hook.
You have a legal mandate to provide a
safe work environment.
“OSHA wants to support organizations
that are focused on improving safety,”
Wilcox said. “It is more likely that OSHA
will look favorably on a company that is
systematically eliminating their hazards
than one that has no program at all, as the
participants in the Voluntary Protection
Program will attest.”
Mistake #2: Solve the Wrong Problem
— Don’t guess what needs to be fixed. Instead,
it is better to conduct a facility-wide,
wall-to-wall fall hazard assessment with
the help of a qualified safety professional.
The assessment can be an extremely useful
tool to evaluate probability and severity
and the resulting risk posed by fall hazards.
While all hazards greater than four feet
above a lower level (for general industry)
need to be abated at some point, basing
decisions on accurate evaluations helps you avoid spending valuable time
and money on solving problems that do
little to reduce the risk of injury in the
facility.
Based on his experience, Wilcox identifies
an average of 1,000 hazards for
every million square feet of manufacturing
space. With the potential of so many
hazards, it is essential to develop a system
for abatement. Otherwise, the fall
protection program is reactive rather than
proactive.
Studies by a leading consumer products
manufacturer have shown that this reactive
type of program can cost 10,000
times – that’s not a typo – more than one
where the hazards are identified and an
abatement strategy implemented over a
period of time.
Wilcox’s company, LJB Inc., takes a
comprehensive approach when it assesses
a facility. The company uses a proprietary
system that evaluates numerous factors in
both the areas of probability and severity.
For example, probability considerations
include the number of workers exposed to
the hazard. On the severity side, LJB uses algorithms to correlate the height of a possible
fall, the landing surface and likely
level of injury. Today, the design firm is researching
the medical impact of falls from
different heights, which will influence
severity.
“Basically, we consider the likelihood
of an OSHA-recordable incident due to a
fall—and we determine the likely severity
of an injury if there were an incident. We
use these factors to help organizations determine
where to focus their abatement efforts,”
said Wilcox.
Mistake #3: Choose the Wrong Solution
– Ask your employees for their input,
understand all their tasks and gain consensus
on proposed solutions. Fall protection
is a complex and broad topic, so it is critical
to involve as many stakeholders as possible
and consider a variety of options.
Evidence repeatedly shows that those
organizations that involve all their stakeholders,
continuously communicate, and
create team buy-in are the most successful
in reducing and eliminating fall hazards.
Functional areas to include on the team
are: maintenance, engineering, safety, production and finance.
Teams that understand all aspects of
safety tasks, consider multiple resolutions,
involve employees, and engage OSHA
Qualified Persons to oversee proper installation
of hazard abatements have the
best track records and improvements.
Additionally, don’t assume that all professional
engineers are Qualified Persons.
The field of safety poses unique challenges
that are not part of the training and education
of a typical structural engineer, just as education
for most safety professionals doesn’t
include advanced engineering courses.
For example, selecting the right anchorage
point for a safety harness lanyard
is critically important, but highly complex.
Improper clearance and inadequate
anchorage strength are two issues that can
appear on OSHA’s radar when it investigates
recordable incidents. These issues
are often overlooked by structural engineers
who are only concerned about the
strength of a potential anchorage.
What to Look for in a Qualified Person:
• Recognized degree or professional
certificate;
• Extensive knowledge and experience in
the field of safety;
• Capable of design, analysis, evaluation
and specifications for working at
heights;
• Integrates safety and engineering;
• Integrates OSHA regulations and ANSI
standards;
• Understands safety equipment uses and
limitations.
Logic Over Intuition
A consistently safe environment for
your workers can be achieved by stepping
back from the daily routine, setting priorities,
and building a manageable and sustainable
program. The bottom line for any
safety program is to reduce risk and improve
safety. Every hazard that gets
abated reduces the risk of injury. Wilcox
urges every organization to get started and
do something to reduce risk.