Fall Protection Program Revised: October, 2015 © 2005 - 2015. University of New Hampshire. The most current version of this document can be found at: http://unh.edu/research/fall-protection Fall Protection Program Table of Contents I. INTRODUCTION………………………………………………….…………………..…………….……...…….3 II. PURPOSE…………………………………….……………………………………………….………………..………3 III. DEFINITINIONS..……………………………………………………………………………………………...……4 IV. REQUIREMENTS………………………………………………………………………………………………...….5 A. Responsibilities ………………………………………………………………………………………..……...5 1. 2. 3. 4. 5. Office of Environmental Health and Safety.......... ........................ ............... ….5 Departments ........................................................... ........................ ................... 5 Supervisors ............................................................. ........................ ................... 6 Employees ............................................................... ........................ ................... 6 Campus Planning/Facilities Project Management ........................ ................... 6 B. Fall Protection Procedures……… ………………………………………………………………….….… 6 1. Guardrails ............. ........................ ........................ ........................ ................... 7 2. Personal Fall Arrest Systems ......... ........................ ........................ ................... 7 3. Scaffolding ............ ........................ ........................ ........................ ................... 7 3.1 Scissor Lifts ................... ........................ ........................ ................... 8 4. Aerial Lifts ............ ........................ ........................ ........................ ................... 8 5. Ladders ................. ........................ ........................ ........................ ................... 9 6. Floor Holes ........... ........................ ........................ ........................ ................... 9 6.1 Skylights ........................ ........................ ........................ ................... 9 C. Rescue Procedure.…………………………………………………………………………………..…... …..9 D. Inspection Procedures ...... ........................ ........................ ........................ ................. 10 V. TRAINING ........ ........................ ........................ ........................ ........................ ................. 11 Appendices Appendix A: Annual PFAS Inspection Forms I. INTRODUCTION Individuals at the University of New Hampshire (UNH) are entitled to a working and learning environment free of unsafe and unhealthy conditions. Working on elevated locations exposes employees to fall hazards that must be addressed through appropriate fall protection measures. Fall protection is best attained through engineering controls - modifying the work environment in order to reduce the risk of falling. Where possible, elevated working surfaces shall be guarded, railings installed, and areas fenced off prior to working. When these types of controls are neither sufficient nor feasible, a personal fall arrest or restrain system will be required. It is the intention of UNH to provide maximum protection for its personnel, students and visitors. Therefore, UNH has used the Occupational Safety and Health Administration (OSHA) standards and the State of New Hampshire Department of Labor Administrative Rules for Employee Safety in the development of the UNH Fall Protection Program. Applicable regulations include: • 29 CFR 1910 Subpart D, Walking and Working Surfaces • 29 CFR 1926 Subpart M, Fall Protection • 29 CFR 1926 Subpart L, Scaffolds • 29 CFR 1926 Subpart X, Stairways and Ladders • New Hampshire Lab 1403.20, Fall Protection Conducting operations where fall hazards are present in accordance with the provisions outlined in the UNH Fall Protection Program and subsequent regulatory standards will assist with preventing falls, one of the leading cause of occupational injuries and fatalities. II. PURPOSE The purpose of the University of New Hampshire's Fall Protection Program is to protect faculty, staff and students from the risks of injuries due to falls when working at elevated heights of four (4) feet or greater. UNH has identified many areas where fall hazards exist that require the need for fall protection. They include, but are not limited to: • • • • • • • • All flat and low slope (4 in 12 pitch or less) roof locations; All steep sloped (greater than 4 in 12 pitch) roofs; Interior and exterior catwalks and platforms; Interior and exterior fixed ladders; Mezzanine and balcony edges; Floor openings, holes, open sided floors, and platforms; Skylights; Pit, trapdoors, access hatches, and manholes (when open); UNH Fall Protection Program 3 • • • • • Open excavations and pits; Use of man lifts that include articulating boom and bucket trucks; Work being conducted on scaffolding to include erection and dismantling and working from scissor lifts; Exposed sides of both the Swazey and exterior pool when drained for servicing and/or maintenance; and Attic areas with unprotected/undecked flooring. *Fall protection is not required while working from a portable ladder however it is advisable, if feasible to have fall protection if the worker does not have at least one hand available to hold onto the ladder. III. DEFINITIONS Anchorage Point: A secure point of attachment for lifelines, lanyards or deceleration devices. Anchorage points must be capable of supporting a minimum of 5,000 pounds per person and be independent of any anchorage used to support or suspend platforms. Body Harness: Straps which are secured around the employee in a manner that will distribute the fall forces over the thighs, pelvis, waist, chest, and shoulders with a means to attach it to other components of a personal fall arrest system. Connector: A device used to couple (connect) parts of the personal fall arrest system together. Deceleration Device: Any mechanism, such as a rope grab, rip-stitch lanyard, specially woven lanyard, tearing or deforming lanyards, automatic self-retracting lifelines/lanyards, etc… which serves to dissipate a substantial amount of energy during a fall arrest, or otherwise limit the energy imposed on an employee during a fall. Deceleration Distance: The additional vertical distance a falling employee travels excluding lifeline elongation and free fall distance, before stopping, from the point at which the deceleration device begins to operate. It is measured as the distance between the location of an employee’s body harness attachment point at the moment of activation of the deceleration device during a fall, and the location of that attachment point after the employee comes to a full stop. Free Fall: The act of falling before a personal fall arrest system begins to apply force to arrest the fall. Free Fall Distance: the vertical displacement of the fall arrest attachment point on the employees body harness between the onset of the fall and just before the system begins to apply force to arrest the fall. Free fall distance must NOT exceed 6 feet (this excludes deceleration distance and lifeline/lanyard elongation distance). Total Fall Distance: The maximum vertical change in distance from the bottom of an individual’s feet at the onset of a fall, to the position of the feet after the fall is arrested. This includes the free fall and deceleration distance. Guardrail System: A barrier erected to prevent employees from falling to lower levels. UNH Fall Protection Program 4 Lanyard: A flexible line that has self-locking snap hook connectors at each end for connecting body harness to deceleration device, lifeline, or anchorage. Lifeline: A component consisting of a flexible line for connection to anchorages either vertically (vertical lifeline) or horizontally (horizontal lifeline) which serves as a means for connecting other components of a personal fall arrest sytem to the anchorage. Low-Sloped Roof: A roof having a slope less than or equal to four in twelve (4:12) vertical to horizontal. Personal Fall Arrest System (PFAS): A system used to arrest (catch) an employee in a fall from a working level. It consists of an anchorage location, connectors, full body harness, and may include a lanyard, deceleration device, lifeline, or suitable combination of the before mentioned items. Steep Roof: A roof having a slope greater than 4:12 (vertical to horizontal). Toe Board: A low protective barrier that will prevent the fall of materials and equipment to lower levels. Warning Line System: A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, which designates an area in which work can be conducted without the use of guardrails or personal fall protection devices. Refer to section IV(B)(2) for details. IV. REQUIRMENTS A. Responsibilities 1. Office of Environmental Health and Safety • • • • Provide or coordinate necessary training to department employees; Coordinate annual inspections of fall protection equipment utilized by UNH personnel; Assist in the evaluation of areas where fall hazards are present; and Assist with the development of applicable engineering controls or personal fall protection systems. 2. Departments • Identify employees who may be exposed to fall hazards including but not limited to: o Facilities Services personnel; o Telecommunications personnel; o Facilities Construction Team members; o Facilities Project Management personnel; o Memorial Union Building Staff; o Campus Recreation; o Athletics; and UNH Fall Protection Program 5 • • • • • o Any full time, part time, or volunteer staff working at four (4) feet or more above a lower level. Ensure the responsible use of primary fall protection systems such as scaffolds, aerial lifts, personnel hoists, personal fall arrest systems, etc; Ensure above systems are equipped with standard guardrails, a safe means of access, and that walking/working surfaces are free of floor openings/holes; Administration of the UNH Fall Protection Program to ensure compliance by all employees under departmental control; Providing the appropriate fall protection devices as required; and Ensuring fall protective devices are inspected as outlined herein. 3. Supervisors • • • • • Attend required fall protection training; Assess and review elevated tasks as to fall protection needs; Ensure adequate fall protection systems are provided and used; and Instruct employees to the specific fall protection measures to be used and the proper use of fall arrest systems. Ensure employees required to utilize fall protection attend fall protection training. 4. Employees • • • • Attend required fall protection training; Visually inspect fall arrest devices prior to every use; Report any defective fall arrest devices to their supervisor; Report any unsafe condition to supervisor. 5. Campus Planning/Facilities Project Management • Where applicable, include the design and installation of fall protection system(s) and accommodations in proposed construction work including but not limited to roof replacements, major renovations, and new building construction. At a minimum, such systems and accommodations shall comply with the following: o 29 CFR 1926 Subpart M, Fall Protection, o 29 CFR 1926 Subpart L, Scaffolding, o 29 CFR 1926 Subpart X, Stairways and Ladders, o 29 CFR 1910 Subpart D, Walking and Working Surfaces, o New Hampshire Lab 1403.20, Fall Protection • Include language in all construction documents that construction safety including, but not limited to, compliance with applicable federal and state laws and regulations is the contractor’s responsibility. B. Fall Protection Procedures All efforts will be made to eliminate hazards through the use of engineering controls. This would involve the design of building systems to eliminate the need to access elevated locations. While this may be applicable for certain applications it is understood that for many locations alternate means UNH Fall Protection Program 6 of fall protection will be necessary. Where alternate fall protection methods are required employees will work in two-person teams. In addition the following options will be available. 1. Guardrails On those projects or for those areas where fall hazards can be eliminated through the use of guardrail systems they will meet the minimum standards for guardrails as established in the OSHA Fall Protection Standards [29 CFR.1926.502(b)]. At a minimum, guardrails will meet the following: • • • • Top rails will be 42 inches above the walking/working surface; Mid rails will be installed between the top rail and walking/working surface; Toe boards will be installed where an overhead hazard of falling objects is present; and Rails will be capable of withstanding a minimum force of 200 pounds when applied in any outward or downward direction. *Employees working in elevated areas protected on all sides by a guardrail system are exempt from the requirement of working in teams of two. 2. Personal Fall Arrest Systems For those projects or areas where a personal fall arrest system (PFAS) will be utilized they will meet the minimum standards as established in the OSHA Fall Protection Standard [29 CFR 1926.502(d)]. At a minimum PFAS will meet the following: • • • • • A full body harness will be utilized; Anchorage points will be rated to withstand a minimum force of 5,000 pounds per employee and will be independent of any anchor used to support platforms or other items; All PFAS components (full body harness, self retracting lanyards, lifelines, shock absorbing lanyards) will be rated for use as a PFAS; All snap hooks associated with PFAS will be self locking; and All PFAS will be inspected in accordance with IV (D) of this program. *A PFAS is not required for those employees engaged in non-roofing work on low pitched roofs where the following conditions are met. 1, A warning line is erected 15 feet or more from the edge; 2, The warning line meets the requirements as established in the OSHA Fall Protection Standard [29 CFR 1926.502(f)]; 3, No work takes place between the warning line and roof edge (for work outside the warning line a PFAS must be used); 4, Employees do not pass beyond the warning line. 3. Scaffolding Employees working on scaffolding greater than four (4) feet above a lower level shall be protected from falling to that lower level through the use of a guardrail system or personal fall arrest system as described above. Areas below the elevated work area will be demarcated to protect employees, students, guests, and/or visitors from falling objects. UNH Fall Protection Program 7 *Exception: For those employees erecting scaffolding for use at UNH, a competent person shall determine the feasibility and safety of providing fall protection. Fall protection will be provided for those erecting scaffolding where the installation and use is feasible and does not create a greater hazard. 3.1 Scissor Lifts Work conducted from scissor lifts will require employees to be protected by the use of a personal fall arrest system anchored to a permanent designed connector on the lift. In addition the following minimum requirements apply for use of scissor lifts: • • • • Only authorized employees shall operate scissor lifts; Lifts will be inspected prior to use which will include the testing of lift controls; Employees will remain within the confines of the platform and will not extend parts of the body outside the guardrails. The use of planks, ladders, or other devices from the lift platform are prohibited; Scissor lifts shall not be moved while elevated in a working position with personnel on the platform. 4. Aerial Lifts Personnel working from within any aerial lift shall wear a PFAS with the lanyard attached to the boom or basket. In addition to the use of the PFAS, the following minimum requirements will apply to the use of aerial lifts; • • • • • • • • • • • Only authorized employees shall operate aerial lifts; Employees will not tie off to an adjacent structure, pole, or equipment while working from an aerial lift; Employees will stand on the floor of the basket and shall not climb on the edge of the basket or use planks, ladders, or other devices for a work position; Areas below the elevated work area will be demarcated to protect employees, students, guests, and/or visitors from falling objects; The lift must be inspected prior to use to include testing the lift controls to ensure they are in safe working condition; Aerial lifts shall not be moved while the boom is elevated or if any employee(s) in the basket, unless designed to do so in the lowered position; Under no circumstance will the lift load limits be exceeded; Lifts may only be used on level ground; Brakes will be set when outriggers are used and they will be positioned on pads or a solid surface; Lower controls shall not be operated unless permission has been obtained from the employee within the basket, except in the case of an emergency; Prior to moving an aerial lift the boom shall be inspected to ensure it is properly cradled and that the outriggers are in a stowed position. UNH Fall Protection Program 8 5. Ladders Employees utilizing portable or fixed ladders to conduct work activities or access elevated locations will ensure their proper use. At a minimum the following requirements will apply to the use of ladders. • All ladders portable or fixed shall meet the requirements as outlined in the OSHA specifications for design and safety, • The appropriate type and size ladder shall be used for the job; • All ladders shall be used only for the purpose for which they were designed; • The maximum intended loads for any ladder shall not be exceeded at any time; • Metal ladders shall not be used in proximity of live electrical lines; • All ladder components shall not be damaged and be in good working condition; • Ladders shall be set up and used properly: o Set up on a flat, solid surface; o Top shall be against a solid surface (exception for step ladders); o Ladder set up at a 4-to-1 ratio (exception for step ladders); o For ladders that extend above an elevated surface they shall extend a minimum of three feet above the point of support; o The top of step ladders shall not be used as a step; o Spreaders for step ladders fully extended. • Where available, ladder safety devices will be used to ascend and descend ladders; • Areas below the elevated work area will be demarcated to protect employees, students, guests, and/or visitors from falling objects. 6. Floor Holes All floor holes which could include any access hatch to lower level, pit, vault, manholes will be protected by a cover of standard strength and construction to prevent access. For areas where the holes must be open for access such as during maintenance and/or construction activities, all holes will be protected by a temporary guardrail that meets the requirements as described above in section (B)(1). 6.1 Skylights Skylights shall be protected by an appropriate cover, skylight screen, or a standard railing as described above in section (B)(1). C. Rescue Procedures Prior to the start of any work activity where fall protection is required, a rescue plan shall be developed and reviewed by those employees involved in work tasks on the procedures to be used in the event of a fall. In the event of a fall the following personnel will be notified as soon as possible: UNH Fall Protection Program 9 • • • Rescue services (Durham Fire Department - 911); Employee manager/supervisor; and Office of Environmental Health and Safety. In the unlikely event that a fall arrest occurs on campus, UNH will contact the Durham Fire Department to assist with rescue operations. Efforts will be made to retrieve the employee from the location where the fall arrest has occurred. To minimize potential risks associated with suspension trauma in the event of a fall arrest, employees will be provided with suspension trauma straps to be attached to the full body harness when a PFAS is used. Any employee involved in a fall arrest will be sent for medical evaluation. D. Inspection Procedures PFAS and associated devices shall be inspected for wear, damage, and other deformations prior to use. This includes full body harnesses, lanyards/shock absorbing lanyards, self-retracting lifelines/lanyards, snap hooks, anchor points, and any other component associated with the PFAS. In addition harnesses, lanyards, and other components excluding the anchor point/system shall be inspected when new and annually thereafter. At a minimum the inspections will check for the following conditions: • • • • • • Cuts and/or abrasions; Burns and signs of discoloration associated with chemical exposures; Excessive wear; Loose splices and damaged stitching; Defective or damaged hardware; Labels and tags are present and legible. Each annual inspection will be documented utilizing the inspection forms located in Appendix A. In addition a tag will be applied to each inspected device documenting the successful inspection. Any device used for fall protection that does not satisfactorily meet the inspection requirements as described above will be immediately removed from service, discarded, and replaced. Under no circumstance will any device not meeting minimum inspection requirements be used for fall protection. Anchor points/systems will be inspected annually and the inspection documented. In addition to the annual visual inspection they will be inspected and certified every five years to ensure they maintain the structural integrity of the initial design and meet the requirements for fall protection. *Should any anchor point/system be stressed due to a fall event the anchor point/system will be tagged out of service until it can be structurally evaluated and re-certified prior to being put back into service. UNH Fall Protection Program 10 V. TRAINING Training will be provided for those employees engaged in activities where they could be exposed to fall hazards. At a minimum employees engaged in fall protection will be trained to understand the following: • • • • • • The recognition of fall hazards in their work areas; The hazards associated with working near fall hazards; The use and operation of fall protection systems to be used; Inspection procedures for fall protection systems required for use; The roles and responsibilities of those employees covered by the UNH Fall Protection Program; and The requirements and procedures outlined in the UNH Fall Protection Program; Retraining will be provided whenever there is belief that employees do not have the understanding and/or skills to safely work in areas where fall hazards exist. This could include conditions that involve: • • • Changes in the workplace that create a new fall hazard not previously addressed; Changes in the type of fall protection system(s) to be used; or Inadequacies are identified in an employee’s knowledge or use of fall protection. UNH Fall Protection Program 11 Appendix A PFAS Inspection Forms Fall Protection Annual Inspection Checklist Full Body Harness Harness Make/Model: Serial Number: Lot Number: Date of Manufacture: Date of Purchase: Comments: General Factors Hardware: D-rings, buckles, keepers and back pads. Inspect for damage, distortion, sharp edges, burrs, cracks, and corrosion Webbing: Inspect for cuts, burns, tears, abrasions, frays, excessive soiling, and discoloration. Stitching: Inspect for pulled or cut stitches. Labels: Inspect making sure all labels are securely held in place and that they are legible. Other: Other: Acceptable/Not Acceptable Supportive Details/Comments Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Inspected By: Pass: Date tag applied: Fail: Date removed from service Date: Fall Protection Annual Inspection Checklist Lanyards Lanyard Make/Model: Serial Number: Lot Number: Date of Manufacture: Date of Purchase: Comments: General Factors Hardware: (Include snaphooks, carabiners, adjusters, keepers, thimbles, and D-rings). Inspect for damage, distortion, sharp edges, burrs, cracks, corrosion, and proper operation. Webbing: Inspect for cuts, burns, tears, abrasions, frays, excessive soiling, and discoloration. Stitching: Inspect for pulled or cut stitches. Synthetic Rope: Inspect for pulled or cut yarns, burns, abrasions, knots, excessive soiling, and discoloration. Energy Absorbing Component: Inspect for elongation, tears, and excessive soiling. Labels: Inspect making sure all labels are securely held in place and that they are legible. Inspected By: Pass: Date tag applied: Fail: Date removed from service Acceptable/Not Acceptable Supportive Details/Comments Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Date: Fall Protection Annual Inspection Checklist Snaphooks & Carabiners Hook/Carabiner Make/Model: Serial Number: Lot Number: Date of Manufacture: Date of Purchase: Comments: General Factors Physical Damage: Inspect for cracks, sharp edges, burrs, deformities and proper locking operations. Excessive Corrosion: Inspect for corrosion, which affects the operations and/or strength. Markings: Inspect and make sure markings are legible. Other: Other: Acceptable/Not Acceptable Supportive Details/Comments Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Labels: Inspect making sure all labels are securely held in place and that they are legible. Inspected By: Pass: Date tag applied: Fail: Date removed from service Acceptable Not Acceptable Date: Fall Protection Annual Inspection Checklist Self-Retracting Lanyards/Lifelines Lanyard/Lifeline Make/Model: Serial Number: Lot Number: Date of Manufacture: Date of Purchase: Comments: General Factors Impact Indicator: Inspect indicator for activation (rupture of red stitching, elongation indicator, etc.). Screws/Fasteners: Inspect for damage and make certain all screws and fasteners are tight. Housing: Inspect for distortion, cracks, and other damage. Inspect anchoring loop for distortion and damage. Lanyard/Lifeline: Inspect for cuts, burns, tears, abrasions, frays, excessive soiling, and discoloration. (See impact indicator section) Locking Action: Inspect for proper lock-up of brake mechanism. Retraction/Extension: Inspect spring tension by pulling lanyard out fully and allowing to retract fully (must remain taut with no slack). Hooks/Carabiners: Inspect for physical damage, corrosion, proper orientation, and markings. Labels: Inspect making sure all labels are securely held in place and that they are legible. Inspected By: Pass: Date tag applied: Fail: Date removed from service Acceptable/Not Acceptable Supportive Details/Comments Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Acceptable Not Acceptable Date: