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Keeping Pace with Fall Protection

Tuesday, August 08, 2017

We all know that initial safety training is a crucial element of our programs that aim to keep our employees protected from harm at work. For any and all hazards (or potential hazards} to which we expose our workers, we must ensure they understand the nature of the hazards and how to protect themselves.

Initial safety training and proper safety equipment, combined with good old-fashioned experience, goes a long way in ensuring a safe work environment. But, at times, we must provide re-training for our employees – and there are many reasons for this.
For example, if our employees demonstrate a lack of knowledge or acceptable performance in regards to any particular hazard, we must provide re-training. If the process or equipment changes, we must provide re-training. If new safety equipment (includes systems as well) is brought into the program, we must re-train our employees on its proper use. And, finally, if there are changes to safety legislation or best-known practices, we need to re-train.

It seems that every week a new piece of fall protection equipment is brought to market – and for the most part, these emerging technologies make work-at-height safer than ever before. Additionally, these newer fall protection items tend to be lighter, more comfortable, easier to operate, and can even perform multiple safety functions. This is all great news, but not every item/system is right for the varied situations encountered at our workplaces. But when we do introduce a new piece of fall protection equipment to our workforce, it nearly universally calls for some degree of re-training. The manufacturer’s instructions for use may be a great starting point to satisfy this training, but it is always a good idea to provide some degree of formal training on the equipment, and then document that training.

The extent of this re-training is dependent on the complexity of the new equipment and the authorized person’s general knowledge base. Sometimes the user manual does not cover all the points that the re-training should convey. For example, harness-mounted self-retracting lifelines are becoming more and more prevalent in the work-at-height environment. In addition to the standard training for pre-use and periodic inspections, proper mounting, operating capabilities and limitations, at least one other point of training seems to be required. The worker cannot walk too quickly away from their anchorage lest they engage the arresting mechanism which abruptly stops the worker in their tracks. This may at times create a new hazard by jerking the worker off balance or causing them to drop objects they may have been carrying. I have even heard some tales of individuals suffering minor injuries due to the sudden stop. So, even though you may not find this point of training in the user’s manual, it comes with experience and should be included in the re-training for this type of new equipment.

Another reason to provide re-training for fall protection has to do with an observed deficiency in an authorized person’s knowledge or performance regarding fall protection. Now this can become a little tricky to find the root cause of the deficiency. Is it truly a lack of knowledge on the authorized person’s part, or is it a disregard for required procedures? Sometimes it's a mix of both. No matter the primary cause of the deficiency, if that authorized person is to remain on that job, it is incumbent on the employer to provide proper re-training. And I will say it again, document that re-training!

We have recently had a significant legislative change to the general industry standard for fall protection. On Nov. 18, 2016, OSHA 1910 Subpart D “Walking-Working Surfaces” was published and became effective on Jan 18, 2017. The major changes to this final rule have to do with physical changes to existing and future structures regarding the phase-in of ladder safety systems,

• Eliminating the outdated general industry requirements for scaffolds and adopting the construction industry’s scaffold standards,• Guidance on the use of rope descent systems and qualified climbers, as well as some other changes. But the most significant changes that will drive training and re-training requirements is the added flexibility of using personal fall protection systems for authorized persons. These personal fall protection systems include fall restraint, work positioning, and personal fall arrest systems (PFAS). OSHA has eliminated the mandate to use guardrail systems as the primary fall protection method and now allows the general industry employer to determine the fall protection method that they feel is best suited for the nature of the work at height. And this now includes personal fall protection which was not addressed prior.

For general industry employers, who prior to the new Subpart D did not allow their employees to use personal fall protection systems other than in accordance with 1910.66, the option to do so now will be deemed compliant. And, of course, this will require initial training and re-training for the use of personal fall protection equipment and systems. Additionally, employers that introduce the authorized use of work positioning and personal fall arrest systems to their workplace will also have to provide training on rescue of these workers if they are relying on an in-house rescue capability.

In the years I have been involved with safety and rescue training, one subtlety that I observe is this:

Oftentimes an employer or their employees do not realize they have a training deficiency until after they've gone through the training.
This is certainly true when it comes to rescue training. At the conclusion of nearly every rescue class I teach, at least one of the students says they never realized what all was involved in rescue and what the limitations of certain rescue systems were. And this is consistent with my interviews and reviews of rescue programs when I am asked to perform needs assessments at various facilities. Unless you have a background in technical rescue, it is very difficult to visualize the systems, skills, and equipment required to safely access and rescue a fallen/suspended victim.

Both OSHA and ANSI require employers to provide "prompt rescue" of employees they authorize to work at height while using personal fall arrest systems. OSHA has published a Safety and Health Information Bulletin recognizing suspension trauma as a workplace hazard affecting workers that use personal fall arrest systems. Many employers address rescue of fallen/suspended workers in their fall protection programs, but stop at merely developing written policies that may fall well short of the requirements needed at the time of an incident. This falls back to my earlier point that an employer that has a limited background and understanding of the complexities of performing rope rescue, especially if it requires technical skills beyond the simplest rescue, may not understand what the true requirements are for their facility. Sort of like that general saying last year that “We don’t know what we don’t know.” So, training for rescue is a subcategory of fall protection training that does not have as much easily accessed guidance and resources to rely on as a guide.

Quality training will include several of the points that I have detailed so far. The training will be pretty specific to the job with very little time spent on irrelevant material. The training will be of the type that best transfers the information in either a vocational or academic manner. The training will close the gaps that have been identified and arm the employer and the students with a better understanding of what is truly required to perform the job, which is especially true for rescue. But finally, the training should be delivered in such a manner that it captures the students’ interest. The best outcome of training, the classes where the student finishes with the highest level of retention, understanding and performance, are the classes that compel the students to engage in the learning.

I think it is a safe assumption to say that we have all sat through classes wondering when and hoping for the class to end. Looking at our watch is one thing, but when we are tapping it to see if it is even still working is a really bad sign. I am not suggesting that educators have to provide entertainment, but there is a demonstrated positive difference in classes delivered by an engaging trainer as compared to a very dull, monotonous trainer.

In addition to seeking an engaging trainer, it is important for the trainee to take some ownership in the learning process as well. This is where the adult learner has an advantage over younger learners. We as adults generally understand that the training will result in a better understanding of the job requirements and in many cases is a factor in career progression.

I encourage you to seek out the training that your employees need. Or, as an employee yourself, seek out quality, applicable training. Review the course syllabi and determine if it will close those knowledge and skills gaps that you have identified. Always back up those fancy sales brochures by reaching out to others to get their opinion on their experiences with the training in the past. Also, remember to consider re-training as needed and always document. These things are important for the overall quality and credibility of your safety training programs.

Article by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc. 

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Rescue Toolbox: Petzl Rescucender

Wednesday, July 05, 2017

The Rescucender is one more quality piece of rescue hardware for your toolbox. Roco is proud to have been one of the first rescue training companies approached by Petzl to be shown the new device and asked to evaluate it. We were excited to see and use it from Day 1, and we then added it to our training kits as soon as they became available.

There’s no doubt, as computer assisted design (CAD) and precision computer numerically controlled (CNC) machines are used more and more in designing and manufacturing new rescue hardware, we are seeing some absolute gems coming to market. And I say gems, referring to function as well as appearance. There are still times when stamping and casting hardware is appropriate, but if there is a good reason to machine a piece from solid aluminum stock, it generally results in a lighter, smoother, more precise piece of kit.

And that is the case with the new Petzl Rescucender. It is primarily machined out of solid forged aluminum with some bits that are manufactured in a more traditional manner. But the end result is one of those gems. I have been waiting for an NFPA-rated, one-piece mechanical cam for quite some time; and now it is here. My first experience with a one-piece cam was with another Petzl product known as the Shunt. The ease of loading it onto, and stripping it off, the rope made it so much faster and greatly reduced the chance of dropping it. This is especially important when 300 feet or more on a tower!

The limitations of the Petzl shunt made it inappropriate for most technical rescue operations except for certain specialized situations such as during rope access or tower rescue when we are generally dealing with lighter rescue loads. The maximum rope diameter that the Shunt can handle is 11 mm. The new Rescucender is NFPA 1983 T Rated and accepts rope diameters from 9-13 mm.

But as important as the ease of mounting/dismounting is, what I really like about the shunt, and now the new Rescucender is the fact that the shell and the shoe are no longer connected together with a light cable or a thin piece of fabric. I have a few pet peeves, and one of them is seeing rescuers strutting about with a two-piece cam hanging from their gear loop unassembled. The shoe is clipped but the shell is just flapping in the breeze hanging from that thin tether waiting to get jammed into a piece of the structure and break free from the shoe. And, if you don’t believe that happens, you haven’t been doing this long enough, or it may be that your team is really good about assembling their two-piece cams when storing or hanging them from their gear loops. So that whole problem of the shoe ending up in Kansas City while the shell is somewhere in Oshkosh is now eliminated with the introduction of the Rescucender.

The attachment hole in the cam arm is extra-large which allows for rotation of your connector. This doesn’t sound like that big of a deal, but once you start using equipment that allows rotation of the connector from end to end, you will appreciate it. 

As with any piece of rescue equipment, it is important to be properly trained in its use. The action for opening and closing the Rescucender becomes very intuitive in a short amount of time. The engagement and movement of the shoe along its guides oozes precision and the solid feel in your hand lends a high degree of confidence. The device is equipped with a spring that has a light action and is primarily intended to prevent fouling. Our experience is the cam runs rather freely down the rope in vertical applications when attached to a pulley. This provides the convenience of creating longer “throws” with a Z-rig or piggy-back hauling system. The balance between the spring action and the need for the cam to remain open in progress capture applications is spot on. It also has just enough passive camming action to remain in place without back-sliding during rope ascents. It runs free when you need it to, and then grabs the rope when needed.

We all know that the pin needs to be completely seated in most two-piece mechanical cams, the new Rescucender does not have a removable pin but instead has dual safety catches, one on each side of the body. Once the device is installed on the rope, it is important to check that there is no “red” of the visual indicators showing. You will feel and hear a distinct click when the safety catches engage. Additionally, the problem of installing the shoe the wrong way in the shell is now eliminated as the Rescucender does not allow 180 degree rotation of the shoe in relation to the shell.

I continue to be excited about the evolution of rescue equipment. It doesn’t seem that long ago that we moved from goldline ropes to kernmantle, but years would go by without seeing any major breakthroughs in modern equipment. Well, those days are over. It seems that the digital era, as well as the push from various agencies and users, combined with the “out-of-the-box” thinking of equipment designers is driving the rapid emergence of better and better rescue mousetraps.

It’s a good time to be in rescue, it always has been, but the versatility, precision, and safety of modern equipment sure makes our tasks easier today than ever before.

Article by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.
Pictures courtesy of Petzl

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Roco Rescue Training in North Dakota

Monday, January 23, 2017

Roco is excited to be conducting several Rescue & Fall Protection Workshops at the 44th Annual Safety Conference next month in Bismarck, ND. This will kick off our working relationship with the ND Safety Council to provide safe, effective confined space rescue training for their membership. 

What's more, the North Dakota Safety Council (NDSC) is currently constructing a new safety campus in Bismarck that will house a 5,000 square foot hands-on training lab. Roco, as a training partner, will provide high-level technical rescue courses at this new facility on a year-round basis.

For the conference on February 20-23, we will be conducting a number of hands-on rescue workshops and presentations to be presented by Roco Lead Instructors Dennis O’Connell, Pat Furr, Brad Warr, Eddie Chapa and Josh Hill. Sessions include:

  • Intro to Competent Person Requirements for Fall Protection
    2/20 9am-6pm (classroom w/demo)
  • Confined Space Entrant, Attendant, and Supervisor Requirements
    2/20 9am-6pm (classroom w/demos) 
  • Tripod Operations
    2/21 11am-5pm (hands-on training) 
  • So You’ve Fallen, Now What?
    2/22 10am-11:30am (classroom)
  • Dial 911 for Confined Space Rescue
    2/22 1:30pm-2:30pm (classroom w/demos)
  • Confined Space and Rope Rescue...
    2/22 1:30pm-5pm (hands-on training) 
  • Trench Collapse Rescue Considerations
    2/22 2:45pm-3:45pm (classroom) 
  • Fallen/Suspended Worker Rescue
    2/23 8am-11:15am (classroom w/demos) 
  • We look forward to meeting you at Roco booths (#202 & #203) or in these training sessions. For more info, click to NDSC’s 44th Annual Safety & Health Conference. Don't forget to register online at www.ndsc.org for these training sessions.
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Where Do You Fit Best on Your Rescue Team?

Wednesday, September 28, 2016

By Pat Furr, VPP Coordinator & Corporate Safety Officer for Roco Rescue, Inc.

At the start of nearly every rescue class, I'll ask, “Okay, who here is afraid of heights?” Usually a few folks will raise their hands, but the vast majority don’t. I then qualify the same question by saying, “By afraid, I don’t mean that you are so overcome with fear that you cannot function – only that when you are at height you get a little case of the butterflies…” Then a few more hands will go up, but typically still fewer than half the class. I continue by adding that I’m always am a bit concerned for the folks that didn’t raise their hand as it means one of two things. First, it may be they are not being totally honest, but more concerning to me is they truly are not afraid of heights...and this is scary.

Human beings are born with an innate fear of heights. This is natural, and quite protective. I’m certainly afraid of heights, and I still get butterflies. It’s just that I’ve learned how to get those butterflies to fly in formation, so I can then function just fine at height. The day I climb atop a wind turbine tower or get that first peek over the edge of some serious exposure, and I don’t get that familiar feeling, that’s my sign to hang up my harness and ride the keyboard full time. This feeling is our not-too-subtle reminder that we do not have wings…and it is a healthy reminder!

There is a point to this, and I’m about to get there. Over the years, I've had some students with a serious case of YMIC (young male immortality complex). They will insist that they are not afraid of heights – or anything else, for that matter. I've found, when it comes time to go over the edge while hanging from that skinny little ½” kernmantle rope, backed up with a ½” safety line, our superheroes tend to freeze like the statue of Michelangelo. They won’t budge, can’t speak, or look any direction but down! Most often, these individuals gradually gain trust in their equipment; in the techniques they’ve learned; and perhaps, most importantly, in themselves. While they may never be "comfortable" going over the edge, they can still be valuable members of their rescue team. Some can be very strong in many other rescue skills such as knot tying, rigging, friction control, mechanical advantage, etc. They can also be excellent in logistics, developing action plans and other key areas.

First, know your weaknesses as well as your strengths. Then, identify your weaknesses and strive to make them your strengths.

A second tenet I live by is to enter a rescue knowing that you will be an asset to the effort. But sometimes, it’s not possible to do this, and having an unusual fear of heights may be one of those times. Avoid crossing the line from being an asset to becoming a liability – creating a situation in which your team would then have to deal with “two” victims. This is huge – especially in an emergency. And that’s what this article is all about. 

Before I go any further, a bit about egos. There is simply no room for egos during a rescue. When the call comes in, it’s about one person and one person only, and that is the victim. We all have our pride, but we need to “park it” until everyone, including the victim and the rescuers, are safe and sound. As trained rescuers, we all have something to contribute. Each of us has a role to fill in the rescue effort and be an asset to the overall effectiveness of our team.

So, how do we learn what our best role as a rescuer may be? Here’s one way. Practice as a team in simulated rescues that are scenario driven and mimic the types of rescues that your team may be summoned to perform. It is during these practice sessions that you will discover your strengths and your weaknesses. It is important for ALL team members to honestly critique each other as well as themselves to help determine the best way to fill the different roles on the team.

As your team practices more often, trends will start to surface. One rescuer may be particularly strong at climbing and can rig cleanly and efficiently while hanging from work positioning equipment. Another rescuer may be your “ace in the hole” for rigging anchors. A third may be so good at converting lowering systems to haul systems, that it’s an obvious choice. Then, there may be some that don’t shine at any particular skill, but are reliable haul team members or can run the SAR cart with the best of them.

All teams have a spectrum of performers, whether it’s a football team, a production assembly line or a team of cooks and chefs in a large restaurant. The same holds true for a rescue team. Some of the factors that affect performance may be physical. Let’s face it, our 5’4” 150-pound “Hole Rat” can pass through tight portals and operate in congested confined spaces easier than most 6’ 6” 280-pounders. Sometimes it’s mechanical aptitude. We see it all the time in training rescuers. Some folks have a natural mechanical aptitude and can understand and build rescue systems as if it were second nature, while others struggle to get it right on a consistent basis.

And, yes, a pronounced fear of height that may inhibit a rescuer’s ability to perform effectively at height is yet another factor to consider. Other things include leadership qualities, attention to detail, general physical strength, comfort with breathing air systems, the presence or lack of claustrophobia and the list goes on. The only way to realize and understand these abilities and limitations is to practice as a team – and practice often – while staying attuned to these individual abilities and limits. Understand them and use them to your advantage in determining who is the best fit for the various team member roles on any given rescue effort. And please, please do not take it personally. Again, we all have our pride and want to shine; however, we all can shine as a team! And the best way to shine as a team is to understand, as best we can, where each member best fits and can contribute most.

Remember, so much of rescue is about mechanical systems, safety, victim packaging and other easily defined considerations. As rescuers, I invite you to take it to the next level. Think about the harder-to-define factors such as individual team member skills AND limitations. Help each other as a team arrive at the best mix of the right people in the right positions – and all for the good of the victim!
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New FreeTech™ Harness May Help Delay the Onset of Suspension Trauma!

Friday, August 12, 2016

The new FreeTech™ Harness from Roco & CMC allows the user to safely and easily transfer their body weight into a seated position. Thus, possibly helping to delay the onset of suspension trauma. This figure-8 style fall protection harness integrates the patent-pending SwitchPoint™ System which allows the user to safely and easily transfer  body weight from the dorsal connector on the upper back to the front waist location of the harness. This transfer reorients the user into a seated position.   

Key Features:

• Unique SwitchPoint™ System technology helps prevent suspension trauma
• Comfortable design for extended wear
• Easy to don and doff using the quick release buckles
• Secure quick-connect buckles are fast and simple to adjust
• Contrasting thread colors aid in inspection
• Integrated Fall-Arrest Indicator
• Corrosion-resistant hardware
• Lanyard attachment loop
• Made in USA, of domestic and foreign components
• One size fits most, 130 lb (59 kg) – 310 lb (140 kg)
• UL Classified to ANSI Z359.11

Watch the video below, or to place your order now, click here.

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Roco's New RescueTalk™ Podcast

Wednesday, June 08, 2016

RescueTalk™ Podcasts explore critical topics for technical, industrial and municipal rescue professionals, emergency responders and safety personnel. Learn about confined space rescue, OSHA compliance, NFPA standards, fall protection, trench rescue, off-shore considerations, rescue equipment, training and more. Get it now.
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Q&A: Fall Pro Recert

Wednesday, June 01, 2016

READER QUESTION:
I went through competent person for fall protection several years ago and since that time a lot has changed regarding the types of fall protection equipment and systems that are available. Should I get update training for this role?

ROCO TECH PANEL ANSWER:
Yes, definitely. In fact, ANSI Z359.2 states competent person training update training shall be conducted at least every two years. It is always a great idea for competent persons to stay abreast of not only any legislative changes, but also to stay current on consensus standards such as ANSI, and certainly on emerging equipment technologies. It is amazing how quickly new fall protection equipment is becoming available. It wasn’t long ago that harness mount self-retracting lanyards were just a drawing on an engineer’s desk, and now there are so many different versions it is mind boggling. OSHA’s recognition of suspension trauma as a workplace hazard to fallen suspended authorized persons has created an entire market segment for systems to help deal with this hazard. So receiving update training for this crucial role at least every two years is certainly a great idea.

READER QUESTION:
Can I complete competent person for fall protection training via an on-line course?

ROCO TECH PANEL ANSWER:
We discourage that type of course other than for learning the legislated requirements. There just is no substitute for hands-on training. One of the most important responsibilities of a competent person for fall protection is the performance of periodic equipment inspections. I can’t imagine having any way to show competency of this skill without demonstrating it to a live instructor/evaluator.

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Training to Become a Fall Pro 'Pro' Is a Never-Ending Journey

Thursday, November 12, 2015

Article by Pat Furr, as printed in OH&S, November 2015

Whatever training you attend and complete should be viewed as the launching point to get you started on learning everything you can about fall protection.

Gravity doesn't need to go to school. She is a master at pulling all objects toward the center of our blue planet and has been doing so since the dawn of time. So, yep, she is the grand master. Whereas we mere mortals are still learning how to counter her effects. Part of our learning is how to protect our workers at height from falling into her grasp. And OSHA recognizes we are still learning and thus requires employers to provide appropriate training to protect their workers at height—as well as from the grand master's constant grip.

There are several roles and responsibilities within any comprehensive fall protection program, and there are just as many courses of instruction that provide a baseline of knowledge and skills designed to get the individuals occupying these positions started or to enhance their ability to perform in these roles. But no single course of instruction currently covers, nor will one ever cover, every bit of knowledge needed for every work at height situation.

There is an old joke that goes like this: "What do you call the bottom graduate of medical school?" The answer is, "Doctor, of course."

What does that have to do with fall protection training, you may ask? Well, the rest of the story is that very often that bottom medical school graduate goes on to become a leader in his or her specialty. And that happens because they practice. That's why they call it practicing medicine, I suppose.

So this is where it will begin to make sense. Fall protection training is the beginning and should not and cannot be thought of as the "end all" for whatever role and responsibility for which you are training. Whatever training you attend and complete should be viewed as the launching point to get you started on learning everything you can about fall protection. This includes compliance requirements; fall protection system capabilities and limitations; the dynamics of a fall, including clearance requirements and swing fall; post-fall rescue; and, as importantly, what is the best fit for your Authorized Persons.

Gaining the knowledge and understanding of these and many other facets of fall protection requires continuous self-study and research. It also requires getting out and visiting your facility to find out what the structural geometry is and to learn about the processes, as well as the Authorized Persons' needs and concerns.

During the past 35 years, I have attended training for all sorts of occupational duties, and the one common denominator has been that all of them provide a foundation to build from. For the most part, I felt I could function in the role I was being trained for, but I would equate it to functioning at the "apprentice" or "journeyman" level. I knew I still had much to learn before mastering the task.

This is especially true for fall protection training. To learn every single OSHA requirement regarding fall protection is a very tall order. I don't know of any fall protection Competent Person course that covers it all or would attempt to cover it all. And to know the particular challenges of every location where work is performed at height can only be gained through experience. In order to move toward mastering the craft, it is important to take the initiative to learn beyond the formal training.

However, self-study is so much easier than it was 15 or 20 years ago. The ease of accessing OSHA standards, letters of interpretation, summaries and explanations of final rules, and other OSHA resources pertaining to fall protection on the World Wide Web opens up a wealth of information.

It is also my good fortune that I visit many different client sites where I encounter a smorgasbord of fall protection challenges that provide learning opportunities. Oftentimes, I am able to recite the information nearly verbatim that pertains to the issue, but as often as not, I need to do some research to locate the answer or to refresh my memory once again. This is expected and, in lieu of a photographic memory, there is just too much information to learn and retain with 100 percent accuracy.

With the emerging technologies in manufacturing and design of fall protection equipment and systems, it is often a great learning exercise to visit some of the leading equipment manufacturers' and retailers' online catalogs. It is actually pretty exciting to peruse these sites and see many of these modern solutions. And the equipment isn't limited to lanyards and body support, either: There are solutions such as temporary or permanent retro-fitted guardrail systems, harness mount SRLs, nonpenetrating anchor connectors, temporary user-installed horizontal lifelines, and the list goes on. Inviting a fall protection dealer representative to your site may prove to be very educational and beneficial time spent.

Sharing Lessons Learned

Back in my military days, we had a program known as "CROSSTELL," which was a formal messaging system designed to share lessons learned and to disseminate new ideas or techniques between common users. Within the private sector there are similar programs known as BKP (best known practices) or BKM (best known methods) that often provide a vehicle to share useful information within a common industry or within a single corporation. The warning here is to cross-check the BKM or BKP to ensure it is indeed compliant with any applicable legislated requirements. And if you develop what you feel is a BKM or BKP, don’t be bashful about sharing.

Much of the continuing education we have talked about so far is in "black and white" in the form of regulations or interpretations, or a form of equipment that has accompanying printed user instructions. The intangibles are often the most difficult and dynamic pieces of the puzzle to learn. Getting out into the work environment is a very big part of your ongoing self-education.

Performing a fall hazard survey as outlined in ANSI Z359.2 is a great starting point for learning the various means of protecting workers from falls. Always keeping the hierarchy of fall protection in mind, performing a comprehensive assessment of the known and potential areas for work at height will definitely provide an education. Now is the time to take your knowledge of compliance requirements, the BKM/BKPs, a broad knowledge of the equipment that is available, and then determine what will work best for the configuration of the structure, the environmental conditions, and also through interviewing the workers who will be employing the equipment to learn what their needs are. Will they need equipment that provides a high degree of mobility? Are they concerned about heavy or bulky equipment or exposed to hot working environments? Do they need equipment that can be set up and taken down quickly to facilitate moving from point to point? This can only be determined by talking to and listening to the Authorized Persons and their foremen.

By considering a formal fall protection course of instruction the endpoint for your fall protection training, no matter what capacity you are working in, is doing a disservice to your co-workers and to yourself. Accepting the onus of continuing your "training" through self-study, visiting the equipment offerings, and assessing the working environment and the needs of the workers to do their jobs is all a part of your continuing—ongoing—fall protection education.

About the Author


Pat Furr is a chief instructor, technical consultant and VPP Coordinator for Roco Rescue, Inc. As a chief instructor, he teaches a wide variety of technical rescue classes, including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. In his role as technical consultant, he is involved in research and development, writing articles, and presenting at national conferences. He is also a new member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard. Prior to joining Roco in 2000, he served 20 years in the U.S. Air Force as a Pararescueman (PJ).

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Who is your Fall Protection MVP?

Wednesday, October 29, 2014

The following article was featured in the September issue of ISHN, and authored by Roco Chief Instructor Pat Furr.
Every team has their most valuable player or person, their MVP. When you consider all the personnel who make up the fall protection team at your facility, who is your MVP?

Chances are it is your Competent Person. OSHA defines a Competent Person as “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” In order to do their job and become your Fall Protection MVP, it is very important that your Competent Person be.....well, competent.


Understanding Regulations & Standards

Competence can come through formal training, work experience, self-study, or most likely a combination of all three. Areas in which the Competent Person must be well versed include a thorough understanding of legislated requirements pertaining to fall protection. A great deal of time must be spent visiting the applicable OSHA regulations that apply to the type of work activities that the Competent Person will be overseeing.

This can be rather daunting, but there are plenty of resources to help in this effort. OSHA provides clarification through the issuance of letters of interpretation, Safety and Health Information Bulletins (SHIBs) and safety posters, and several training institutions provide formal training covering OSHA regulations as part of their curricula.

In addition to understanding the OSHA legislated requirements, it is also helpful that the Competent Person use consensus standards, BKM, and certainly any company policies that strengthen the OSHA required protections. The ANSI/ASSE Z359 family of standards is a big help, especially Z359.2 titled, “Minimum Requirements for a Comprehensive Managed Fall Protection Program.” This document provides recommended guidance for roles and responsibilities, training, fall hazard surveys, procedures, the hierarchy of fall protection, anchorages, inspection, maintenance and storage of fall protection equipment, rescue procedures, incident investigation, and evaluating program effectiveness.

Meeting the Needs of Authorized Persons

The Competent Person is in a unique position. They must communicate to the Authorized Persons that will be employing the fall protection procedures and systems, and also to the Program Administrator. In many cases, the Competent Person may be the Program Administrator, too. In this position, the Competent Person must strive to understand the needs of Authorized Persons regarding systems and equipment that will not create an unacceptable hindrance to their job.

If the fall protection equipment is so burdensome that workers cannot do their job, or is very uncomfortable, there is a better chance they will be reluctant to use it. So one of the most important aspects of the Competent Person’s education is to stay abreast of the types of fall protection equipment and systems commercially available. With the recent explosion of modern, lightweight, multi-function, easily deployed fall protection equipment and systems, the question of feasibility and overcoming reluctance on the part of the Authorized Person is becoming a concern of the past.

Fall Hazard Survey

The “Fall Hazard Survey” is a great tool for the Competent Person to use to identify existing and potential future fall hazards at the worksite, and to determine means to abate those hazards. This exercise is outlined in ANSI/ASSE Z359.2 and provides a systematic approach to this most valuable step. I refer to it as the fall hazard walk-about — a top-to-bottom, north-to-south, thorough physical review of all areas in which current or future work at height may be performed. The goal is to identify fall hazards by type and to identify one or more means to eliminate or control hazards while keeping the hierarchy of fall protection in mind at all times.

Once the Fall Hazard Survey is completed, it may call for the use of active fall protection equipment and systems if falls cannot be eliminated through engineering controls. In this instance, the Competent Person may have to impose limits on work activities and prescribe specific guidance on equipment and non-certified anchor point selection, and also on equipment use limitations to control swing falls and clearance requirements. Procedures put into place to eliminate or control fall hazards should be documented and included in the fall protection program.


Rescue Planning

One often overlooked duty of the Competent Person is to prepare or ensure that written rescue pre-plans are developed for any identified fall hazard that calls for the use of personnel fall arrest systems. I advocate development of a rescue from height pre-plan anytime employees are performing work at an elevated location that is accessed by means other than a stairwell or elevator. This includes platforms that may be protected by passive restraints such as standard guardrails or parapets. Always consider the possibility that a worker may be injured or become suddenly ill while at this elevated position and will need prompt rescue to get them safely to ground level.


Equipment Inspections & Incident Investigation

There are two primary types of fall protection equipment and system inspections, and the Competent Person plays a role in both types. The Competent Person is tasked with performing OSHA-mandated periodic inspections and any periodic inspections in accordance with the manufacturer’s instructions for use. Pre-use inspections of fall protection equipment will be completed by the Authorized Person, but the training on these pre-use inspections and the person who ensures that these inspections are indeed completed is the Competent Person. If any equipment fails a pre-use or periodic inspection, it is immediately removed from service. In the unfortunate event that there is a fall from height incident, the Competent Person will participate in the investigation.

Role Recap

I’d like to summarize the role of the Competent Person “According to Pat” by saying they:

  • •  Must be very knowledgeable of the OSHA fall protection regulations.

  • •  Identify and understand all areas where work is performed at height and provide solutions adhering to the hierarchy of fall protection by completing a thorough and honest Fall Hazard Survey.

  • •  Have a finger on the pulse of traditional and emerging technologies for fall protection equipment and systems. Provide solutions to the Authorized Persons that are comfortable, convenient, and may be safer than what is currently being used.

  • •  Understand the capabilities and limitations of rescue systems.

I hope you have your own “Fall Protection MVP” at your work site and, if not, maybe it is time to groom one.

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A Job Hazard Analysis for Work at Height

Thursday, July 31, 2014

The following article was featured in the June 2014 issue of ISHN, and authored by Roco Chief Instructor Pat Furr.

As part of my safety consulting duties, I have seen many fall protection programs for a wide variety of industries. When I ask about an employer’s fall protection plan, it’s pretty scary to be told, “Well, I can show you our program in two minutes”— and then see no more than a locker with a rag-tag assortment of body belts, harnesses and a few six- foot energy-absorbing lanyards of questionable integrity.

Now, it is rare to come across such an inadequate program. But truth be told, the comprehensiveness, diligence and effectiveness of the programs I have assessed run a fairly wide spectrum from so-so to top notch.

Top-notch programs all had several common elements, but the one element that stands out the most as being consistently included in the best programs is the completion of fall hazard surveys.

A Comprehensive Survey

The fall hazard survey, or what I like to call the fall hazard “walk-about,” is a critical early step in the process of assembling a comprehensive managed fall protection program. And a survey should be conducted again when certain changes occur including, but not limited to, changes in the facility configuration, changes to work processes, changes to legislated requirements, and the emergence of modern fall protection equipment solutions.

Outlined in ANSI Z359.2, the fall hazard survey is an effective means to identify areas where work is performed at height, identify ways to eliminate or control fall hazards, and help determine which hazards require the highest priority when it comes to allocating sometimes limited resources. A comprehensive fall hazard survey is the best way to identify and understand the types of fall hazards that need to be addressed to provide the best protection to your workers at height.

This requires that the Qualified or Competent Person do a top to bottom, left to right, tour of the facility to identify known areas where work at height is currently being performed, and any areas where future work at height may take place.

It may be helpful to have an area foreman or even an Authorized Person with thorough knowledge of the specific work areas available to ask questions regarding the work process and their needs and concerns.

The goal of this survey is to not only identify areas of work at height, but to determine the most protective means of abating the fall hazards.

 
The goal of this survey is to not only identify areas of work at height, but to determine the most protective means of abating fall hazards.

The Qualified/Competent Person must have the “Hierarchy of Fall Protection” in mind at all times. By having the goal of eliminating the fall hazard first and foremost, any opportunities to bring the work to the ground or to perform the work from the ground should present themselves during this survey. This may require a change in the configuration of certain structures, or the retrofitting of systems that allow the work to be performed from the ground. This may incur some significant costs, but in the long run the changes will be more than offset by avoiding a fall from height and the direct and indirect costs of such an accident.

Continuing the survey while still adhering to the Hierarchy of Fall Protection, the Qualified/ Competent Person may have to consider the use of fall restraint measures, either passive measures in the form of guardrails or parapets, or active measures in the form of body belts or harnesses with lanyards anchored in a way that the system prevents the Authorized Worker from reaching the leading edge of a fall hazard. Once active measures are employed, it is critically important to work with the Authorized Persons to understand what their work activities entail to come to a solution that provides the needed protection but also considers their need for mobility.

If the lower echelons of the Hierarchy of Fall Protection cannot be employed, a fall arrest system may be the only feasible solution.
 

A Fall Arrest Solution

If the lower echelons of the Hierarchy of Fall Protection cannot be employed, a fall arrest system may be the only feasible solution. This is where the Qualified/Competent Person’s knowledge of current fall arrest systems and components really shows its value. Lightweight, breathable, multi-function fall protection equipment available today protects workers while also providing the ease of use and freedom of movement that has been missing for many years. This is an important tool that the Competent Person can use to their advantage when faced with any resistance from certain Authorized Persons.

During the fall hazard survey, consider the presence of any environmental factors that may affect the performance of the fall protection equipment or systems as well as an alternate solution, specialized materials, or even a reconfiguration of the structure/process. Environmental factors can include hot objects, sharp edges, slowly engulfing materials, chemicals, weather factors, or any other environmental factor that may render the fall protection equipment ineffective.

Document Findings

Once the entire facility has been surveyed, it’s time to document in writing the findings and the means to abate the identified fall hazards. The Fall Hazard Survey Report becomes a part of the written fall protection program. It should be reviewed periodically and whenever there is a change to legislated requirements or a change in the facility or fall protection equipment.

Plan for Rescue

If any identified areas require the use of fall arrest systems, then that triggers the need to complete a written rescue pre-plan. It is my opinion that rescue

If any identified areas require the use of fall arrest systems, then that triggers the need to complete a written rescue pre-plan.

 
pre-plans should also include anywhere workers are performing work at height, such as elevated platforms that have been accessed by means other than elevators or stairs, with the goal that the rescue plan provides a capability to get the injured or suddenly ill worker to the ground promptly.

Time to Train

Once the Fall Hazard Survey is completed and documented, it is time for the Qualified Competent Person to provide training to the Authorized Persons on the types of equipment, systems, selection of anchor points, clearance requirements, swing fall hazards, and pre-use inspections of their equipment. Training may vary depending on the areas that Authorized Persons are assigned duties, but in all cases the type of training, any required re-training, and the criteria that would trigger the need for retraining must be documented.

A Valuable Tool

The fall hazard survey is a valuable tool that provides a thorough assessment of the entire facility to honestly identify fall hazards and determine the most effective means to protect workers from falls. Look at it as an expanded JHA that focuses specifically on areas of work at height.


About the Author: Pat Furr is a chief instructor and technical consultant for Roco Rescue, Inc. Pat teaches a wide variety of technical rescue classes including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. He is also involved in research and development, writing articles and presenting at national conferences. He is a member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard.

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