Every organization strives to have a cohesive safety culture that is understood by employees, effective in keeping employees safe from hazards, and agile enough to respond to emergencies. A comprehensive written fall protection program can be one of the cornerstones of building a robust safety culture at your organization.
First, it is important to know that everyone in the organization is responsible for creating a safer workplace. Also, while developing a fall protection program can be a lengthy process where attention to detail is paramount, the process is systematic and straightforward. There are also many resources available from the Occupational Safety and Health Administration (OSHA) and industry partners that can assist anyone with developing a program that will keep their workers safe while performing their jobs.
Leading from the top
Every employee has a role in their organization’s safety programs. A comprehensive fall protection program requires everyone to be vigilant about fall hazards and ensure best practices are being followed. Employees who see company leadership making safety a top priority are more empowered to follow their organization’s written policies and notify management if hazardous conditions are found.
ANSI Z359.2 further explains the specific roles, responsibilities, and training criteria of Authorized Users and the Competent Person concerning the fall protection program. Authorized User is a self-explanatory designation given once the employer properly trains selected employees. The Competent Person is the primary facilitator or administrator of the fall protection program. Their primary responsibilities are establishing the program, identifying hazards and solutions, training users, documenting equipment inspections, and evaluating the effectiveness of the program. The Competent Person must undergo refresher training every two years to keep their certification valid with their employer.
Identifying hazards and implementing solutions
Conducting a fall protection assessment of your facility should be one of the first steps in building or revitalizing your written program. According to OSHA 1910.28(b)(1)(i), employers must ensure “that each employee on a walking-working surface with an unprotected side or edge that is 4 feet or more above a lower level is protected from falling.” While an initial assessment may seem daunting, this process identifies all existing hazards in your facility and keeps your organization proactive in preventing potential incidents. A proactive safety team can empower workers to stay vigilant around the facility and will be more effective in preventing falls.
This assessment can be performed internally with safety leadership, maintenance managers, and the end users involved with each hazard, but it is recommended to include trusted vendor partners that can promptly recommend solutions to address any identified hazards. Upon completion of the assessment, you can begin identifying solutions necessary to mitigate each hazard. Per the hierarchy of safety controls, the main goal during an assessment should be to eliminate all fall hazards in the facility. For example, a worker who was once subject to a fall from changing a light bulb while standing on an A-frame ladder could work from the ground if provided an extension pole device to help change the light bulb from the ground.
However, for more complicated tasks where the work procedure cannot be altered, fall protection equipment must be used. There is a tendency for folks to immediately consider a personal fall arrest system but fall arrest equipment does not necessarily prevent a fall—it can only reduce the forces that will impact the fallen victim and prevent them from contacting the lower level. Methods of fall prevention (guardrail, barricades, etc.) or fall restraint (fixed-length lanyards that restrict user movement) are more effective in removing the hazard from the worker, but sometimes those methods prove to be infeasible and fall arrest equipment must be used. Keep in mind that each option subsequently exposes the worker to a greater risk of injury. While fiscal constraints and project timelines must be considered, safety leadership should always advocate for solutions that provide the greatest protection factor for an employee.
Training and continuing education
Regular training is essential for the vitality and success of your fall protection program. First, understand that OSHA requires employers to train their users annually at a minimum. Training must also occur if a significant change occurs to the written fall protection program or when new equipment is used. A robust training program should include equipment inspection, best-use practices, an overview of the hazards present at your facility, and ensure that employees understand their role in your organization’s fall protection program. While OSHA only requires annual fall protection training for Authorized Users, it is recommended for employers to host training sessions more often, perhaps when they purchase new equipment or to simply keep the topic top of mind.
Annual inspection and maintenance of equipment
When inspecting fall protection equipment, industry professionals refer to two types of inspections. First is the pre-use inspection that users must conduct every time they use their fall protection equipment. This inspection must include the user’s anchorage, body harness, connection device, and any other equipment or accessories that make up their Personal Fall Arrest System (PFAS). If a piece of equipment fails inspection, the user must immediately notify their organization’s Competent Person to remove the equipment from service and identify an alternative solution before they can safely perform their task.
OSHA also mandates that all fall protection equipment is to be inspected by their organization’s Competent Person on an annual basis. (For construction companies, equipment inspections must occur every six months, per OSHA.) In contrast to the pre-use inspection by the user, these annual inspections must produce documentation and be filed for recordkeeping. For equipment exposed to harsh conditions or extremely frequent use, a more regular inspection schedule might be appropriate, if determined necessary by the Competent Person’s best discretion. In a perfect world, these formal equipment inspections would reveal no failures or issues, since users should be performing pre-use inspections every day they work at height. However, the formal inspection is a good opportunity to confirm the thoroughness of the user’s pre-use inspections and ensure equipment is being used & stored properly.
Emergency rescue planning
Your fall protection plan must include protocols for emergency response whenever fall arrest equipment is utilized, should a user succumb to a fall and require medical attention. In addition to calling emergency services, employers must make provisions to self-rescue fall victims within their facility. For all fall hazards identified within the facility, there must be a documented plan for rescuing a fallen worker before issuing their fall arrest equipment. Rescue methods should be as prompt as possible to reduce the effects of orthostatic intolerance (aka suspension trauma). Emergency response protocols should be reviewed in the worker’s pre-task assessment before beginning work and roles in the rescue plan should be clearly defined.
Ongoing efforts and program evaluation
Documenting your fall protection program is one matter while ensuring user compliance is another. There is no way to guarantee employees will follow written procedures, however positive reinforcement and encouragement from safety leadership will increase your program’s chances of success. Successful organizations strive for perfection by regularly communicating policies to their workforce, utilizing vendor-provided training & education resources, and promptly resolving safety concerns as they are identified. It is the employer’s responsibility to ensure all employees understand the organization’s safety program policies, and each employee has the responsibility of notifying their leadership of hazardous conditions or practices that could cause damage to personnel or equipment.
Philip Jacklin is Continuing Education Program Manager for Diversified Fall Protection. He is an AIA continuing education provider, QSSP & OSHA-30 certified, and has been a partner to the fall protection industry since 2018. Jacklin has a background in customer advocacy, team leadership, and fostering camaraderie among peers.