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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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Quick-Connect Harness Buckle Safety

Wednesday, July 02, 2014

Recently, we noticed a story in a leading safety and health magazine that questions the “two-piece, pass-through buckle” that is commonly used on many harnesses. The author, in fact, referred to it as a design flaw. However, we consider it more a matter of improper use than a design flaw. While he does identify some potential user failures, we feel his terming is not quite accurate. Here’s why...

As with any life support equipment, it is imperative to use the equipment in accordance with the manufacturer’s instructions for use and receive the appropriate training as required. The author cites instances where he has observed the mating plate of the two-piece, pass-through buckle being improperly oriented which can lead to the buckle loosening and potentially disconnecting. He also suggests that the pass-through plate have some type of “visual indicator” to warn the user when the buckle is improperly connected. Of course, we’re always in favor of additional safety features!

While this may be viewed as a matter of semantics, consider the following analogy… almost every outboard motorboat has one or sometimes multiple drain plugs in the transom well to provide drainage once the boat is pulled out of the water. If the skipper forgets to re-install the drain plugs the next time the boat is launched, the transom well will fill with water, which could lead to swamping. So, is this a design flaw, or improper use? From an equipment designer/manufacturer’s point of view, the use of this terminology could be very significant.

With the many advances in life safety equipment, we have seen harnesses and other rescue/safety equipment become more convenient, lighter, multifunctional, and overall safer than earlier generations. As with many product advances and improvements, there may be compromise in one area but advances in many others. In this case, the speed and ease of donning and doffing a Class III rescue or fall protection harness by using some type of quick-connect buckle. Of course, the user must ensure that the buckle is used correctly.

The pass-through buckle has been around a very long time. In fact, a Croll sport climbing sit harness that I bought in 1981 had this type buckle. These buckles were also used in the past on the leg loops on Roco harnesses. There are minor variations on the design of the buckle with some having slots to ease the pass-through of the top plate, while others do not have this slot.

There are important requirements for the safe use of these buckles, which include:

1.  Make sure the buckle is adjusted tightly enough to ensure constant tension is applied to the top plate against the fixed plate.

2.  Be sure that the top plate is not inverted.

3.  Double check that the tail end of the webbing does not pass through the “fixed plate” but instead lays parallel with the anchored section of the webbing.

These three user points of performance are easily completed. Our extensive experience with this type of buckle tells us that it’s a convenient and safe buckle when used as it was designed. As always, carefully check and re-check your gear before life-loading!

Information from article by Robert Peterson published by OH&S Online - www.ohsonline.com.


 

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New “No-Step” Work-Rescue Harness from Roco & CMC


Tuesday, April 29, 2014

Imagine donning a Class III harness in as little as 8 seconds!
That’s just one of the many features of the new CMC/Roco Work-Rescue Harness.


Because of its innovative “no-step” donning, comfort fit and lightweight design, this new harness will appeal to rescuers, rope access technicians, tower climbers, and other professionals working in the vertical environment.

Our design team (aka Roco instructors) joined up with CMC’s engineering and fabrication team to create this new Class III harness with a “no-step-through” design. The harness literally wraps around your body as you don it. After the initial webbing adjustment, it is then fitted to the user with no need to re-adjust the various straps when you re-don the harness. This unique feature allows a user to don the harness and be ready to go in as little as 8 seconds. Compare this to donning a standard Class III where the user has to step through the waist and leg loops, then tighten the buckles and stow the straps. Not to mention when a “dreaded half twist” is discovered in one of the straps requiring the wearer to start all over again.

The CMC/Roco Work-Rescue Harness features comfortable wear especially while suspended. The lightweight proprietary CMC alloy D-Rings reduce the overall weight of the harness, while the addition of a rated attachment point at the back of the waist belt allows for a convenient connection to a fall restraint lanyard.

The harness has many advantages for work-at-height professionals. For rope access technicians, the top of the A-Frame lift is designed to accept a variety of connectors for anchoring chest ascenders. It also includes a closed loop on the chest H-Frame to mount a chest ascender adjustable tow strap.

Tower climbers will benefit from the vertical orientation of the sternal D-Ring, which eliminates binding of ladder safety system cable grabs during down climbs. The sternal D-Ring has a quick release stowage strap that keeps the ring tucked neatly against the chest when not in use.

The harness features ergonomic curves and pre-formed moldings for user comfort and durability while maintaining a modern look. It also incorporates breathable padding on the interior surfaces to reduce heat retention. The dorsal and shoulder pads are a one-piece design created by a vacuum molding process, making it comfortable without sacrificing form for ease of donning.

The Fall Arrest Indicator is another great safety feature available on this harness. The visual on the tag alerts the user if the harness has had a previous fall. 






"Creating a harness that is easier and quicker to don provides a great advantage for rope professionals. The new CMC/Roco Work-Rescue Harness literally wraps around the user's body…once donned and adjusted, it’s then ‘custom fit’ to your body,” according to Chief Instructor Pat Furr, who led Roco’s design team. 

For more information on the CMC/Roco Work-Rescue Harness, or to place your order now, click here.

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NEW Fall Protection Courses from Roco

Wednesday, October 02, 2013

• Are you concerned about potential falls from height at your workplace?

• Do your workers need more training in recognizing fall hazards?

• Does your fall protection program consider all the angles when evaluating these hazards?

Roco’s new Fall Protection courses can help create a safer workplace by equipping employees with the knowledge to better assess the dangers and take protective steps to abate common fall hazards. Participants will practice Fall Hazard Assessments and will be able to look at their worksite with new eyes concerning fall protection safety.


Click below to learn more about these courses or contact us at 800-647-7626.

Suspended Worker Rescue

Suspended Worker Rescue Using Pre-Engineered Rescue Systems

Competent Person for Fall Protection

Competent Person for Fall Protection Train the Trainer
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New Hierarchy of Fall Protection Safety Poster from Roco

Wednesday, October 02, 2013

Roco’s new Hierarchy of Fall Protection Safety Poster provides guidance on how to protect your workers from fall hazards by illustrating a series of steps in making safer choices as job duties are approached. It clearly explains the need for employers to make every attempt to abate fall hazards at their work sites by starting with the most protective level of fall protection. OSHA and ANSI references are used to emphasize the need for proper training and “fallen or isolated worker-at-height” rescue pre-plans when appropriate.

This safety poster will provide a quick reminder that oftentimes working at height is more hazardous simply because more “protective steps” in the hierarchy were never considered.

By displaying this poster in strategic areas, we hope it will encourage all workers to take every opportunity to make work-at-height even safer. After all, for those of you who know Roco…there’s a safe way, and a SAFER way!



Click the picture to download the PDF version of the NEW Hierarchy of Fall Protection Safety Poster.

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Hierarchy of Fall Protection

Tuesday, August 27, 2013

Roco Rescue Releases Two New Fall Protection Programs for OSHA Compliant Workplaces
Are you concerned about the potential for falls from height at your workplace?

Do you feel that your workers are not adequately trained in recognizing fall hazards, or do not have the proper training in the inspection and use of their fall protection equipment?

Does your fall protection program consider all the angles regarding work at height and fall protection?


Click on the graphic to the left to download our free Roco safety poster on the Hierarchy of Fall Protection.

 

New Roco Fall Pro Course: Competent Person for Fall Protection

Roco Rescue is proud to announce the addition of a comprehensive Competent Person for Fall Protection course as an addition to our already extensive catalog of Technical Rescue, Compliance, and Safety courses.

The two day (16 hour) Competent Person course focuses on OSHA and ANSI requirements and guidance to provide the Competent Person the knowledge and skills that will enable them to provide their employer a solid foundation for establishing or improving their comprehensive fall protection program

This course emphasizes legislated as well as consensus standard fall protection requirements and guidance for various industries as well as exposing the attendees to a variety of modern fall protection equipment solutions and techniques. The hierarchy of fall protection is used as the building block for the most protective approach for abating fall hazards in the workplace. The attendee will have a solid understanding of how to evaluate fall hazards in the workplace by completing a field exercise using a “Fall Hazard Survey Report Template” that identifies fall hazards and uses the hierarchy of fall protection to provide the most protective and feasible solution to address the identified hazards.

Exposure to modern fall protection equipment and emerging technologies -especially the availability of pre-engineered fall protection solutions- arms the student with an extensive toolkit for addressing existing fall hazards in their workplace. Equipment and equipment systems such as body support, connectors, modern lanyards, self-retracting lanyards, horizontal and vertical lifelines, anchor connectors, as well as other specialty equipment will be covered and examples will be available to employ during the class.

The often overlooked need to understand and provide a rescue capability for fallen/suspended workers and workers isolated at height will be covered. The use of the “Roco Suspended Worker Rescue Pre-plan” will be covered in a live field exercise. Included will be a demonstration and practice rescues utilizing a pre-engineered rescue system that may provide the “prompt rescue capability” of fallen workers for most situations as required by both OSHA and ANSI.

New Roco Fall Pro Course: Competent Person - Train the Trainer:

Upon completion of Roco’s Competent Person for Fall Protection Course we offer the option to stay on for our Competent Person Trainer course. This course includes an additional two days (16 hours) that prepares the Competent Person to train their own employees to the level of Authorized and Competent Persons. The course opens with a thorough lecture/discussion on the adult learner.

Tried and proven steps that are invaluable in providing a systematic workforce education program specific to Competent and Authorized Persons for fall protection are covered. Areas such as gap analysis, instructional triads, three part learning objectives, measurements, dealing with the adult learner and their varied backgrounds are just some of the preparatory lessons. This is followed by a thorough section on preparing and utilizing lesson plans which are then put into practice as the attendees prepare for and deliver actual lessons to their fellow students on the various teaching modules.

The Competent Person for Fall Protection and the Competent Person Trainer Courses are available as private training at Roco Training Center in Baton Rouge, Louisiana or Roco can deliver the course at your facility as a private class. Please call (800) 647-7626 for more details or to schedule.

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Suspension Trauma Explained: Safety Poster from Roco

Monday, April 22, 2013

What exactly is suspension trauma? How does it occur? And what can be done to prevent it?

Suspension Trauma - otherwise known as harness pathology, distributive shock, or orthostatic intolerance - has recently been identified by OSHA as a workplace hazard particular to Authorized Workers using personal fall arrest systems (PFAS). More and more employers are becoming aware of this workplace hazard and are taking appropriate steps to protect their employees. The range of understanding on the cause of the hazard, as well as how to protect against it, is pretty vast.

Our new Suspension Trauma Safety Poster is a tool to raise awareness of this hazard. It illustrates the pathological path that a fallen suspended worker may experience. Please share with colleagues, fellow safety professionals and especially workers that use PFAS. It could save a life.

Just click to download a printable pdf.

The rate at which suspension trauma develops varies from individual to individual and is not reliably predictable. However, there are factors that influence the potential for suspension trauma as well as the speed of onset. Here are a few examples:
  • • Underlying physical condition of worker including any pre-existing respiratory or cardiac conditions;
  • • Worker’s ability to handle stress and anxiety;
  • • Harness selection, fit, and adjustment;
  • • Traumatic injuries that may have occurred during or before the fall; and,
  • • Knowledge and the use of equipment or techniques to delay the onset of suspension trauma such as temporary leg stirrups or simply “bicycling the legs.”

Roco also offers a course called Suspended Worker Rescue to educate rescuers who respond to suspended workers.  

Pathological Effects of a Fallen Worker in Danger of Suspension Trauma


For those of you who prefer a more detailed explanation, here's the narrative from Roco Chief Pat Furr. 

1. Leg Circulation: A fall arrest harness does a great job of dissipating the energies generated during a fall arrest through the long axis of the human body. After all motion has stopped, that same harness – particularly the dorsal attachment configuration – will most likely impose pressure to the femoral vein that is the primary blood vessel that returns blood from the legs towards the heart. In fact, in order to pass certification testing, these harnesses must not allow the test mannequin to assume greater than a 30 degree forward lean upon suspension. Any degree of forward lean will exert leg strap pressure on the femoral vein which impedes blood return. To compound this, the human body relies on what is known as the muscle/venous pump to assist the blood return from the legs to the heart. In suspension, the worker often forgets to bicycle their legs to create this muscle/venous pump. The trapped blood in the legs creates what is known as distributive shock as more and more blood is trapped in the legs; there is less to circulate for the rest of the body (brain, heart, lungs, and kidneys). Additionally this blood becomes highly acidic and toxic with metabolic wastes.

2. Heart Circulation: As the body goes into distributive shock, the heart must increase the rate and strength of its contractions to compensate. To compound this, the suspended worker may be experiencing a high degree of fear and anxiety, which releases adrenalin into the blood stream which also causes the heart to work harder and faster. This places increased demands on the heart, which is receiving less blood flow and thus less oxygen. The heart becomes irritable and is prone to localized tissue damage, dysrhythmias or both. This is especially a concern once the worker is rescued and the toxic blood is allowed to surge from the legs to the irritable heart. This is known as reflow syndrome and has caused several victims to go into sudden cardiac arrest upon rescue.

3. Brain Circulation: As the victim goes into distributive shock, or worst case, suffers cardiac arrest, the brain is deprived of adequate blood supply and this can lead to unconsciousness. If the victim faints the airway can be blocked by the head position or even by a poorly adjusted harness that allows the chest strap to block the airway. That is a difficult statement to write into a fatality report “Cause of Death: Strangulation by Victim’s Own PPE.”  If the victim’s heart stops, we can expect permanent brain damage or death in as little as four minutes.

So it should be obvious that a prompt rescue capability must be ensured by any employer that has Authorized Persons using PFAS. This can be accomplished in many ways. Roco has a variety of training courses that are specifically designed to provide that prompt rescue capability for fallen/suspended workers.

For more information please contact Roco Rescue at 800-647-7626 or submit a question to our Tech Panel.
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Lanyard Safety

Tuesday, December 04, 2012

Here's a question from one of our readers: How can you test a lanyard to determine if it is safe to use? Is there a standard checklist or procedure?

Answer from the Roco Tech Panel: As with all safety and rescue gear, we recommend that you inspect, use and care for it in strict accordance with the manufacturer’s instructions. Of course, all equipment should be carefully inspected before and after each use. And, as we always say, “If there’s any doubt, throw it out!” Sometimes it’s less expensive to simply replace the gear versus going through any elaborate testing process. We did find the following information regarding lanyard inspections in an “OSHA Quick Takes” document. Thank you for your question!

Lanyard Inspection

To maintain their service life and high performance, all belts and harnesses should be inspected frequently. Visual inspection before each use should become routine, and also a routine inspection by a competent person. If any of the conditions listed below are found, the equipment should be replaced before being used.

When inspecting lanyards, begin at one end and work to the opposite end. Slowly rotate the lanyard so that the entire circumference is checked. Spliced ends require particular attention. Hardware should be examined under procedures detailed below.

HARDWARE
Snaps: Inspect closely for hook and eye distortion, cracks, corrosion, or pitted surfaces. The keeper or latch should seat into the nose without binding and should not be distorted or obstructed. The keeper spring should exert sufficient force to firmly close the keeper. Keeper rocks must provide the keeper from opening when the keeper closes.

Thimbles: The thimble (protective plastic sleeve) must be firmly seated in the eye of the splice, and the splice should have no loose or cut strands. The edges of the thimble should be free of sharp edges, distortion, or cracks.

LANYARDS
Steel Lanyard:
While rotating a steel lanyard, watch for cuts, frayed areas, or unusual wear patterns on the wire. The use of steel lanyards for fall protection without a shock-absorbing device is not recommended.

Web Lanyard: While bending webbing over a piece of pipe, observe each side of the webbed lanyard. This will reveal any cuts or breaks. Due to the limited elasticity of the web lanyard, fall protection without the use of a shock absorber is not recommended.

Rope Lanyard: Rotation of the rope lanyard while inspecting from end to end will bring to light any fuzzy, worn, broken or cut fibers. Weakened areas from extreme loads will appear as a noticeable change in original diameter. The rope diameter should be uniform throughout, following a short break-in period. When a rope lanyard is used for fall protection, a shock-absorbing system should be included.

Shock-Absorbing Packs
The outer portion of the shock-absorbing pack should be examined for burn holes and tears. Stitching on areas where the pack is sewn to the D-ring, belt or lanyard should be examined for loose strands, rips and deterioration.

VISUAL INDICATIONS OF DAMAGE

Heat
In excessive heat, nylon becomes brittle and has a shriveled brownish appearance. Fibers will break when flexed and should not be used above 180 degrees Fahrenheit.

Chemical
Change in color usually appears as a brownish smear or smudge. Transverse cracks appear when belt is bent over tight. This causes a loss of elasticity in the belt.

Ultraviolet Rays
Do not store webbing and rope lanyards in direct sunlight, because ultraviolet rays can reduce the strength of some material.

Molten Metal or Flame
Webbing and rope strands may be fused together by molten metal or flame. Watch for hard, shiny spots or a hard and brittle feel. Webbing will not support combustion, nylon will.

Paint and Solvents
Paint will penetrate and dry, restricting movements of fibers. Drying agents and solvents in some paints will appear as chemical damage.

CLEANING FOR SAFETY AND FUNCTION

Basic care for fall protection safety equipment will prolong and endure the life of the equipment and contribute toward the performance of its vital safety function. Proper storage and maintenance after use is as important as cleaning the equipment of dirt, corrosives or contaminants. The storage area should be clean, dry and free of exposure to fumes or corrosive elements.

Nylon and Polyester
Wipe off all surface dirt with a sponge dampened in plain water. Squeeze the sponge dry. Dip the sponge in a mild solution of water and commercial soap or detergent. Work up a thick lather with a vigorous back and forth motion. Then wipe the belt dry with a clean cloth. Hang freely to dry but away from excessive heat.

Drying
Harness, belts and other equipment should be dried thoroughly without exposure to heat, steam or long periods of sunlight.

For the complete OSHA Quick Takes document, click here.

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Fall Protection Essentials: Follow-up from Roco

Thursday, February 09, 2012

Pat Furr reviews the importance of following OSHA safety standards for fall protection, and the steps an employer can take to ensure a safe work environment by providing high quality training. In the recent article by Mark Stromme, published in ISHN and on this blog, he addresses several myths regarding compliance with OSHA Fall Protection in the construction industry. Fact is, this wisdom applies to industry across the board.

OSHA Fall Protection Standards for Industry

It does not take long for an employer to realize that understanding the OSHA 29 CFR 1926 Subpart M standard is no quick and easy task. Fully adhering to this standard requires employers to complete a number of assessments, including the following:

    •    Evaluating areas that workers are exposed to fall hazards
    •    Developing work practices that eliminate or reduce the exposure to those fall hazards
    •    Selecting and installing suitable fall protection equipment
    •    Training employees on proper use of the equipment
    •    Inspecting and maintaining the equipment
    •    Developing rescue plans
    •    Re-evaluating the entire program on a regular basis

There’s no doubt, this can be a very daunting task – especially with all the other safety responsibilities we must deal with on a daily basis. But, I wanted to demonstrate that there is much more to providing a safe work environment for employees than handing them a harness and an energy absorbing lanyard.

Fall Protection Competent Person Essentials

One of the most important steps an employer can take towards developing an effective comprehensive fall protection program is to provide top quality training to their selected fall protection competent persons. By selecting the right person(s) for this position, the employer is assigning a degree of authority and expectations that the competent person will be very well versed in all there is to know about fall protection.

A common question we get from our former Competent Person students has to do with proper use of fall protection equipment. This is a critical function of the Competent Person, to provide the authorized persons training on the proper use of the selected fall protection equipment. As good as the equipment has become with modern materials, increased strength requirements, and functionality, we still are seeing equipment failures when subjected to forces they were not designed to see. If the authorized user is using the equipment outside the manufacturers’ instructions for use, that means the training has fallen short. No pun intended.

Roco's Fall Protection protocol challenges employers and current competent persons to ratchet up their diligence in providing high quality training to the folks that are counting on them. Employers must seek out truly effective Competent Person training programs and avoid programs that are more interested in selling product than delivering the instruction that the students need. Once the employer is satisfied that the competent person has the appropriate level of knowledge and experience, they complete written documentation attesting to such as described in the following article.

Now the ball is in the Competent Person’s court. With support from the employer, it is of paramount importance that the competent person continues educating themselves on everything “Fall Protection.”  Divide time between the OSHA and ANSI standards, new product information, fall protection “Walkabouts” at your facility, to include rescue provisions, and continuous monitoring of the work practices of the authorized persons.

There is always the need for continued fall protection training at every level. Make sure your team is properly trained and equipped to avoid injuries, fatalities, penalties or both. Check out Roco courses for Fall Protection/Competent Person by clicking here.

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Five Fall Protection Myths to Counteract

Monday, January 30, 2012

Falls are the leading cause of worker fatalities. According to OSHA, each year more than 100 workers die and thousands are injured as a result of falls at construction sites. The fall protection standard, at 29 CFR 1926 Subpart M, details training and equipment requirements that employers must use to protect workers from falls.

This story is excerpted from an article by Mark Stromme, ISHN. He offers valuable suggestions for increasing safety for workers, and avoiding OSHA fines.


Employers need to:

    •    Select systems and equipment appropriate for the situation;
    •    Properly construct and install safety systems; and

    •    Train workers in the proper selection, use and maintenance of fall protection systems.

Train employees so they don’t fall for these five common myths and misconceptions about fall protection requirements in the construction industry. (Note: The citation amounts listed are related to the specific standard violated.)

Myth #1-“Residential construction has an exemption from the fall protection rules.”

This used to be true. However, in December 2010, OSHA rescinded the directive that allowed for that exception and as of September 15, 2011, all residential construction companies must comply with 1926.501(b)(13). The employer still has the option to develop and implement a fall protection plan that meets the requirements of paragraph (k) of 1926.502 if the employer can demonstrate that fall protection is infeasible or creates a greater hazard.

The new directive STD 03-00-002, Compliance Guidance for Residential Construction, rescinds STD 03-00-001, Interim Fall Protection Compliance Guidelines for Residential Construction, and provides that OSHA will be enforcing 1926.501(b)(13) for all residential construction work.

According to OSHA:

“Prior to the issuance of this new directive, STD 03-00-001 allowed employers engaged in certain residential construction activities to use specified alternative methods of fall protection (e.g., slide guards or safety monitor systems) rather than the conventional fall protection (guardrails, safety nets, or personal fall arrest systems) required by the residential construction fall protection standard (29 CFR 1926.501(b)(13)). Employers could use the alternative measures described in STD 03-00-001 without first proving that the use of conventional fall protection was infeasible or created a greater hazard and without a written fall protection plan. With the issuance of the new directive, all residential construction employers must comply with 29 CFR 1926.501(b)(13).”

When employees say there isn’t a need for fall protection during residential construction work, point out that OSHA says differently. As of September 15, 2011, OSHA compliance officers can enforce STD 03-00-002 for residential construction sites.

Myth #2-“I don’t need any fall protection; it’s only going to take me a couple minutes to install that equipment.”

Fall protection must be provided when employees are performing construction work on a walking/working surface with an unprotected side or edge that is six feet or more above a lower level. (Note: Construction work is “work for construction, alteration, and/or repair, including painting and decorating.”)
The length of time needed to perform that construction work has no bearing on the employer’s duty to provide fall protection. Be it one minute or one hour, OSHA requires fall protection per 1926.501(b)(1).

There is an exception: when employees are making an inspection, investigation or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed, no fall protection is needed.

The following is from an OSHA Letter of Interpretation dated March 2, 2010:

“OSHA has set this exception because employees engaged in inspecting, investigating and assessing workplace conditions before the actual work begins or after work has been completed are exposed to fall hazards for very short durations, if at all, since they most likely would be able to accomplish their work without going near the danger zone... [R]equiring the installation of fall protection systems under such circumstances would expose the employee who installs those systems to falling hazards for a longer time than the person performing an inspection or similar work.”

When employees say they don’t need any fall protection — because the task is going to take them only a few minutes — tell them that in 2010 this misunderstanding cost employers $1,344,612 in OSHA citations.

Myth #3-“Training programs for fall protection aren’t really needed.”

OSHA is clear about requiring training for each employee who might be exposed to fall hazards. For example, employees may be familiar with specific types of fall protection and have had proper training. However, if a different type of fall protection is to be used, employees using it must be trained by a competent person qualified in this area of expertise.
This training must include the following:
  •     •    The nature of fall hazards in the work area;
  •     •    The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used;
  •     •    The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be
  •     •    The role of each employee in the safety monitoring system when this system is used;
  •     •    The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;
  •     •    The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection;
  •     •    The role of employees in fall protection plans; and
  •     •    The standards contained in Subpart M.
To prove this training was done, employers need to have a written certification of training that contains the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer.
If workers scoff and say they don’t need to be specifically trained in fall protection, tell them the OSHA regulations state otherwise. Failure to provide the required fall protection training in 1926.503(a)(1) resulted in $649,006 in OSHA citations in 2010.

Myth #4-“I’m doing roofing on a low-sloped roof so I don’t need any fall protection.”

OSHA requires (per 1926.5010(b)(10)) each employee engaged in roofing activities on low-sloped roofs, with unprotected sides and edges six feet or more above lower levels be protected from falling by:

    •    Guardrail systems,
    •    Safety net systems, or
    •    Personal fall arrest systems

Other options include a combination of:

    •    Warning line system and guardrail system,
    •    Warning line system and safety net system,
    •    Warning line system and personal fall arrest system, or
    •    Warning line system and safety monitoring system.

On roofs 50 feet or less in width, the use of a safety monitoring system alone (i.e., without the warning line system) is permitted.
There is an exception. When the employer is doing leading edge work, precast concrete erection work or residential construction work, and can demonstrate that it is infeasible or creates a greater hazard to use these systems, they must develop and implement a fall protection plan that meets the requirements of 1926.502(k).

Contrary to what workers may think, OSHA does require fall protection on low-sloped roofs. In 2010 they issued $909,442 in citations to enforce that requirement.

Myth #5-“A warning line is all I need for fall protection when working on a steep roof.”

According to 1926.501(b)(11), a warning line is not allowed as a form of fall protection when working on a steeply pitched roof. OSHA requires that each employee on a steep roof with unprotected sides and edges six feet or more above lower levels be protected from falling by guardrail systems with toeboards, safety net systems or personal fall arrest systems.

Training employees on these requirements would have saved employers $447,828 in citations in 2010.

Counteract these myths... Training employees to avoid these five fall protection myths and misconceptions can prevent injuries and fatalities and save your company money.
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