UPDATE: OSHA recently unveiled its top 10 most frequently cited violations for 2010, and topping the list is Fall Protection. With 7,139 violations, Fall Protection is still at the top, switching places with last year’s first place holder, Scaffolding. OSHA reported that 260 workers died in 2010 from falls, which continues to be the leading cause of death in construction. So, you’ve developed an exemplary employee safety program and the shining gem is your fall protection program.
Using an organized approach and ANSI guidance for completing a “Fall Hazard Survey Report,” you have identified all the areas that workers are exposed to falls from height. Adhering to the hierarchy of fall protection, you’ve also been able to engineer out many of these fall hazards by bringing the work to the ground. Outstanding! For several of the remaining areas, you’ve installed passive fall restraint systems like guard rails and parapets. Great! Still, there are several areas that could not be protected by engineering out the hazard or providing passive restraint.
For some of these areas you are able to protect your employees from falls with active restraint, using body support and a restraint lanyard connected to a suitable anchor that prevents the worker from falling. Good. But, there are still a few remaining areas that you could not protect your employees from falls using the lower hierarchy solutions, and the only feasible solution was the use of personal fall arrest systems (PFAS). OK. You are still providing a compliant and possibly the most logical and feasible program that will provide a high degree of fall protection for your work force. Job well done! Or is it?By taking the steps covered above and using the “Hierarchy of Fall Protection,” the employer is doing exactly what OSHA expects of them to protect their employees from the devastating injuries resulting from falls. However, there is one more piece to the puzzle…what are the potential outcomes and OSHA expectations after an employee falls? Especially if the employee is using PFAS.
OSHA’s Fall Protection regulations state that the employer shall provide prompt rescue in the event of a fall, or shall assure that employees are able to rescue themselves (OSHA 1926.502 and 1910.66 app. C). Although both regulations include “self-rescue” as the first choice in most cases — can we really rely on a worker to self-rescue in the event of a fall? What if the worker is injured during the fall, or what if a sudden medical emergency caused the fall? Are we confident that the individual will be able to perform self-rescue? In our opinion, relying on an employee to provide self-rescue after a fall does not fully meet the spirit of OSHA Fall Protection regulations. In fact, we feel that the only way to provide 100% rescue coverage is to assume that self-rescue is not a reliable option.
The irony is that an employer with an inadequate fall protection program may not face the need for a fallen/suspended worker rescue capability. In this environment, if the employee falls and has no PFAS, there is probably no need for rescue; it is more likely now a recovery. At this point, what the employee really needs is a “help wanted” ad to replace the employee and a very good lawyer.
Just a few years ago it was fairly common for employers not to be aware of the “after fall” hazards created by the PFAS. The understanding was that the PFAS did its job and the emergency was averted. However, in 2004, OSHA published a Safety and Health Information Bulletin (SHIB 03-24-2004 updated 2011 https://osha.gov/dts/shib/shib032404.html) that provided advice and information on suspension trauma/orthostatic intolerance. In fact, the bulletin states that “research indicates that suspension…can result in unconsciousness, followed by death, in less than 30 minutes.” As a recognized hazard, an understanding of suspension trauma makes it clear that post fall arrest suspended workers are still at risk of serious and possibly fatal injury even in the absence of primary injury prior to, or during the fall.
Although OSHA regulations do not assign a specific time criteria to what constitutes “prompt rescue,” ANSI Z359.2 does. ANSI recommends that “physical or verbal” contact be made with the fallen worker within four (4) to six (6) minutes. Notice that ANSI includes verbal contact in their recommendation. It makes sense that if verbal contact is established, the fallen worker’s condition can be assessed and a determination made on the general urgency of the situation. For example, if responders can establish verbal contact with the fallen/suspended worker, and the victim is alert and oriented, has normal or near normal breathing function, and has no obvious signs of bleeding, then the rescue can be approached in a measured manner. Responders should also remind the suspended worker to “bicycle” their legs — or to deploy any system that is designed to delay the onset of suspension trauma. Obviously, the victim needs to be rescued in a safe and expeditious manner before the onset of suspension trauma, if possible.
However, if the victim is unresponsive, or showing signs of breathing difficulty, or active bleeding, then the sense of urgency should be elevated and the victim must be rescued ASAP. This presents a true dilemma for the employer who has not included a prompt rescue capability in their comprehensive fall protection program.
In fact, it is common to refer to a PFAS system as having four components:
(2) An energy absorbing lanyard.
(3) A suitable fall arrest anchor.
A great way to ensure that a prompt rescue capability is available in the event of a fallen/suspended worker is to complete a “Fallen Worker Rescue Preplan” for all areas where employees are working at height. For general industry facilities, which tend to be fairly static, this can be done initially with periodic review and updates as needed. For the typical construction industry with its dynamic activities, a much more diligent and regular review of rescue needs and rescue plans may be needed.
Employers have a few options in developing a prompt rescue of fallen/suspended worker capability. Coordinating with municipal emergency responders is one option. Contracting third party professional rescue services is another possibility — especially during turnaround activities or major reconfigurations/additions. Or, the employer can choose to develop an in-house rescue capability made up of their own employees that are trained and equipped to perform the types of rescues that they may be confronted with at their facility.
Whichever option the employer chooses, it is of utmost importance that the employer vets the rescuers, even their own in-house assets, to ensure that they can actually perform the types of rescue, including the worst case that they may be responding to. For those using an outside rescue service, it is a great practice to invite the rescuers to the facility for the purpose of rescue planning and a performance evaluation of their capabilities. It is very common for outside rescuers to be caught off guard when confronted with unique structural or victim access constraints upon seeing the facility for the first time. This may be so significant that the rescuers find themselves unequipped or lacking in the skills required to provide rescue.
The recent advent of pre-engineered rescue systems has also lulled many employers into the belief that these systems will provide an all-encompassing rescue capability. While most of these “Plug–and–Play” systems do provide a certain level of performance, they also have limitations, especially if access to the fallen/suspended worker requires a rescuer to be put on line to make physical contact with the victim. In this case, it is quite likely that the employer may need to consider a technical rescue capability exceeding the capabilities of a pre-engineered rescue system.
The need for a more technical rescue approach can only be determined after a thorough evaluation of rescue needs based on Fallen Worker Rescue Preplans. We often refer to this as a fallen worker “walk-about” where knowledgeable representatives of the employer (usually the competent person or the competent rescuer) tour the facility to develop Fallen Worker Rescue Preplans. These individuals will need a thorough understanding of the work processes, the areas of workers at height, the access routes, the types of PPE/PFAS being used, and most importantly, an understanding of the techniques and equipment necessary to affect a safe and prompt rescue.
Once the Fallen Worker Rescue Preplans have been completed, they become part of the comprehensive fall protection program and should be reviewed and updated as necessary. With the seemingly continuous advent of new rescue equipment and techniques, it would be a great idea to review your preplans to see if there are opportunities to add these innovations, especially if they provide a safer and more efficient means of rescue.
In summary, it is of utmost importance for employers to ensure that their workers at height (especially if using PFAS) are afforded prompt rescue should they fall and remain suspended from their PFAS system. Whether the employer chooses an outside rescue service or elects to develop an in-house team, they should ensure that the rescue team can perform any and all types of rescues they may be summoned to. If a pre-engineered rescue system or a technical rescue capability is determined to be the most appropriate route, ensure that the rescuers receive thorough, high quality training on the types of systems they will need to employ.
If you would like more information or need assistance in preparing your Fallen Worker Rescue Preplans, please call Roco at 800-647-7626.