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Fall Protection Is Not Intuitive
Keep Fall Safety from Slipping Through the Cracks

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. FSM

 Kevin E. Wilcox, PE, CSP is a principal with LJB Inc., and a professional structural engineer as well as a certified safety professional with more than 15 years of experience.

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