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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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Confined Space Attendants Play a Crucial Role

Tuesday, July 08, 2014

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

Have you ever wondered who that person is who hovers around the portal of a permit space while workers are in the space? What does a Confined Space Attendant (often referred to as the “Hole Watch”) do anyway? What may seem like a cushy job is actually a critical safety responsibility. Here’s why:

First, OSHA instituted regulations regarding Permit-Required Confined Spaces (1910.146) due to the high number of serious injuries and deaths in confined spaces. Entering these spaces is dangerous business, and the attendant serves as the “safety watchman” for entrants as well as those who may casually try to enter. This also applies in an emergency situation when others may be tempted (but unqualified) to enter the space to rescue a co-worker.

OSHA requires that the attendant be able to safely and effectively perform the duties required in Section (i) of 1910.146. (See “Duties of the Confined Space Attendant”) Once a permit is issued and work begins, the attendant needs to be aware of his or her surroundings and be diligent in monitoring the space and entrants at all times. This individual is not there to be a “gofer” for workers inside the space.

Get real

If entrants need assistance or an emergency situation develops inside (or outside) the space that requires entrants to be evacuated, the attendant is the “vital link”. Unfortunately, it is common practice to fill the Hole Watch position with the least experienced or greenest person on the crew. Many times, this person has no idea what is expected of them. They also may not be aware of potential hazards inside the space or hazards that may be introduced as work is performed. Often, these individuals are not experienced in industrial environments and are not properly trained in the OSHA-required duties. And, in most cases, they don’t realize how critical their duties could become in an emergency when split-second decisions are required.

Train your attendants

It is unrealistic to expect a new employee to perform these duties without receiving appropriate training and being granted the authority to take action as needed. In 1910.146(d)(8), OSHA is specific in its requirements for the various roles involved in conducting safe permit entry operations. Employers are required to provide adequate training and ensure that personnel are capable of performing their duties. At minimum, the regulation requires employers to ensure that each Hole Watch/Attendant knows and understands the following safety precautions:

(1) Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure to those hazards;

(2) Possible behavioral effects of hazard exposure for the authorized entrants.

Additional duties and responsibilities include:

(1) Continuously maintaining an accurate count of entrants in the permit space.

(2) Performing non-entry rescues as specified by the employer’s rescue procedure.

One of the most critical duties of the attendant is to be able to effectively communicate with entrants and take appropriate actions in an emergency. Communications are required to monitor the status of the entrants and to ensure that there are no signs of exposure to hazards. The attendant must recognize this need and be able to order evacuation of the space. Most importantly, the confined space attendant can perform NO duties that might interfere with their primary duty to monitor and protect the entrants.

Prevent fatalities

Employers must ask themselves, “Will the person designated as the “Hole Watch” be able to react in an effective manner when the pressure is on? Will they be able to initiate a non-entry rescue in an emergency situation?” Again, we witness too many instances where the “Hole Watch” has little or no knowledge of the responsibilities assigned, while some have had virtually no training whatsoever. Sometimes it seems they are there for no other reason than to fill a square to meet an OSHA requirement.

Many times the lack of understanding regarding confined space hazards, combined with the lack of a clear understanding of emergency actions to be taken (as well as actions to avoid) can lead to confined space fatalities, both for the entrants as well as the attendant.

We urge employers to take a serious look at the selection and training of confined space attendants. These individuals must be capable, responsible and properly trained as spelled out in the OSHA standard. When things go wrong in a confined space, the actions (or inaction) of the attendant can be the difference between life and death for the entrants. They must have the knowledge, the tools and the experience to function as an effective, and ultimately safe, “Hole Watch.”


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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