Implementing a Fall Protection System

Words: Kevin OsheaFor the third year in a row, OSHA’s “Stand Down for Fall Protection” campaign has conveyed important safety and compliance messages to employers during a week in May. But fall protection is a vital safety issue all year long, and employers need to be prepared.

It’s a phone call I get every week from a mason somewhere in the U.S. It usually begins, “Can you help me? The general contractor (GC) has stopped me from working because there is a fall hazard.”

This can be for two reasons, usually:
  1. There is a fall protection issue.
  2. The GC has additional fall protection measures that the mason is not complying with.
Whatever the reason, masons then find themselves involved in a situation that is not easy to resolve.

The most common problem is that GCs are, on many occasions, requiring 100% tie-off when working at height, and I’ve had numerous calls from masons who didn’t spot this requirement in the contract they accepted.

Read Your Contract!

A typical and frequent problem arises when the mason is performing “overhand brickwork.” The inside course puts the mason right at the tipping point, and there have been accidents recorded where a mason has overbalanced and fallen forward through the “green” wall into the void behind. There have also been instances where the wall has then partially collapsed and fallen onto the mason, with one such incident resulting in a fatality.

OSHA does not require the use of a front-face guardrail for overhand brickwork, as detailed in 1926.451 (g) (1) (vi). However, if the GC has stipulated a 100% tie-off policy within the supply contract, and a mason accepts the contract, he in turn accepts the policy.

The retrospective application of fall protection is never straightforward and always difficult to achieve.

Aerial Work Platforms (AWPs), like boom lifts and scissor lifts, and Mast Climbing Work Platforms (MCWPs) have primary fall protection systems – the guardrails – which surround the platform. Where necessary, secondary fall protection systems may be required.

OSHA regulation 1926.502d (16) (iii) requires that anchorages “be rigged such that an employee can neither free-fall more than 6 feet, nor contact any lower level.” Some secondary fall protection systems are now mandatory (e.g., restraining harness and lanyard on the boom lift).

Additional fall protection measures, i.e., over and above mandatory requirements, must be assessed and selected by a “qualified” person. Hazards should be identified, and appropriate fall protection equipment should be selected, with the proviso that OSHA regulations shall establish the minimum level of protection.

Implementation of a fall protection system has two components:
  1. Identification of hazards and selection of appropriate fall protection measures.
  2. Implementation of the fall protection measures.
Appropriate fall protection measures should take into account the following:
  • Primary fall protection systems (e.g., guardrails) should be properly installed, and fall arrest should never be used to replace a poorly installed or partially installed primary system.
  • “Fall restraint” should be the primary objective over “fall arrest.”
  • Fall hazards should be identified by a qualified person, and all identified fall hazards shall be abated.
Fall protection measures should be assessed by a qualified person and should take into account jobsite/task-specific hazards, identification of the associated risk, and stipulate adequate control measures. The table below provides examples of this process.

Hazard Risk Control Measure
Boom lift struck by other vehicle Ejection from platform Restrict work area around base
Climbing on platform mid-rail Loss of balance, causing fall Training and fall restraint
Over-reaching Loss of balance, causing fall Training and fall restraint
Uneven ground Ejection from platform Training and fall restraint
Note: This is not an all-inclusive list, but rather it is an example list demonstrating the analysis requirements of job-specific hazard assessment to be carried out by a qualified person.

Here are some of the questions you should ask in selecting an appropriate system:
  • Did you perform a risk/hazard assessment?
  • Are you qualified to perform a risk/hazard assessment?
  • Have you assessed the attachment locations?
  • What is the rescue plan?
  • Have you determined free-fall distance and total fall distance?
  • Are there any additional manufacturer’s requirements or limitations?
  • How do you avoid swing falls?
  • Will there be a change in circumstances that could prompt a review?
Implementation of fall protection measures should take into account the following:
  • What is the fall distance from the anchorage to the next lower level?
  • Who is exposed to the hazard?
  • Is there sufficient anchorage available for all personnel who are exposed?
  • Is the maximum arresting force per person 1,800 lbs. or less?
  • Will the system bring a falling employee to a complete stop and limit maximum deceleration travel to 3 1/2 feet?
  • How will the suspended person be rescued promptly and safely?
  • Is there someone at ground level who can assist in the rescue (e.g., someone who has been trained in how to bring the machine safely to the ground using either the ground controls or the manual descent system)?
  • Has the suspended person been trained in self-rescue techniques, and does he or she have the necessary equipment available for self-rescue?
  • Has the operator been trained in the proper use and inspection of fall protection equipment?
  • Are there circumstances that may prompt a review of the fall protection system?
Fall protection is a vital safety consideration and an extremely difficult problem to adequately overcome when it is an unplanned afterthought.

OSHA’s Stand Down for Fall Protection seeks to focus employer and employee attention on one of the major causes of construction fatality accidents.

Properly planning for fall protection will save time, expense and lives.

For more information about the Stand Down for Fall Protection, visit www.osha.gov/StopFallsStandDown.
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