Fall Prevention and Protection Disclaimer and Copyright Through the OSHA and AWEA Alliance, AWEA developed this training module for informational purposes only. It does not necessarily reflect the official views of OSHA or the U.S. Department of Labor. 7/13 © 2013 American Wind Energy Association. All rights reserved. You may download, reproduce and print this Fall Prevention and Protection training module, and any portion hereof (the “Document”) for internal use only (which use may include internal use by employees of your company), and, by downloading or accessing the Document, you agree: (i) that you shall not sell or otherwise engage in any distribution of this Document; (ii) that you shall not make any alterations, modifications, deletions or other changes to this Document without the express written consent of American Wind Energy Association (“AWEA”); and (iii) to indemnify and hold AWEA harmless for any loss or damage, including reasonable attorney's fees, that the AWEA may incur, directly or indirectly, as a result of your use of this Document. AWEA assumes no liability for reliance on the contents of this document. AWEA is providing this document for reference only in furtherance of AWEA’s nonprofit and tax-exempt mission. AWEA makes no representation or warranty about the information contained in this document, including, without limitation, the suitability of the information contained in this document for any purpose. It is offered only as general guidance and does not constitute legal, medical, or professional advice. This document is not intended to, nor does it, include information regarding safe operations and maintenance practices. Any recommended practices, guidance, or standards contained in this document should be considered on a case by case basis and used in accordance with your company's internal safety and other operating requirements as well as all applicable laws, regulations and recommended practices addressing safety and regulatory compliance (such as OSHA and ANSI requirements). You should consider seeking legal or professional advice on all matters concerning safety and regulatory compliance. Lesson Overview Purpose: To provide guidance for • Understanding various fall hazards at a Wind Turbine Generator • Training employees on how to protect themselves for fall hazards. • Correctly applying fall protection equipment. • Understanding regulatory requirements. Lesson Overview Objectives • Understand the many applications for fall protection • Be able to apply specific OSHA Regulations • Review Best Industry Practices for Safe Access and Rescue • Appreciate the consequences of fall related injuries Common Fall Hazards in the Wind Energy Industry • Struck by falling objects inside the towers and outside near the base of the towers • Falls that happen… • from fixed ladders • through platform hatchways • inside the nacelle on uneven surfaces • off the top of the nacelle and hub • while moving to the hub and back • into the hub enclosure Consequences when falls occur… • • • • Serious injuries or possibly death Difficulty getting to the fallen worker Long lowering distances to get the victim to safety Limited resources to care for the victim… Only work partners are immediately available Rescue assistance is typically at a distance Medical responders are frequently unfamiliar with techniques for rescuing at extreme heights Human Factors that have contributed to Injuries and Deaths in the Wind Energy Industry • • • • • Lack of awareness (or failure to report) that problems or hazards exist Inadequate training on hazard recognition and effective control methods Failure of employers to provide sufficient or proper safety equipment Failure to train employees to correctly use all required safety equipment. Failure to ensure employees correctly use all required safety equipment. OSHA Requirements • 29 CFR 1910 Subpart D – Walking Working Surfaces • 29 CFR 1910 Subpart I – Personal Protective Equipment • 29 CFR 1910.269(g) – Fall Protection for Power Generation Industry • 29 CFR 1926 Subpart E – Personal Protective and Life Saving Equipment • 29 CFR 1926 Subpart M – Fall Protection Walking Working Surfaces • Fall protection or guarding is required while working at 4’ or higher if a fall hazard is present • Every hatchway or floor opening must be protected • 1910.27 - Fixed Ladders • 1926.1053 - Ladders Personal Protective Equipment • §1910.132 Subpart I • Hazard Assessment and Equipment selection must be performed and documented by each employer whose workers are exposed. • Employers must ensure that each affected employee understand how to use the specified PPE and be properly fitted for the equipment they are required to use. • Employers must ensure employees properly use and maintain PPE. PPE Training Essentials Per OSHA 29 CFR1910.132 Each employee shall demonstrate an understanding of the specified training …and the ability to use PPE properly, before being allowed to perform work requiring use of PPE. This includes: •when PPE/fall protection is necessary •what PPE/system is necessary •how to properly put on, take off, adjust and wear PPE •limitations of PPE/the system •proper care, maintenance, useful life and disposal of the PPE PPE Training Essentials When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required. The employer shall retrain all affected employees. Retraining may also include: • Workplace changes that render previous training obsolete • Changes in type of PPE • Inadequacies demonstrated by the employee’s performance Fall Protection PPE Types • Personal Fall Arrest Systems – system used to arrest an employee in a fall from a working level. Consists of an anchorage, connectors and a body harness. • Positioning Device Systems – body belt or harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning. Personal Fall Arrest Systems Components: • • Body Harnesses – Thigh strap – Chest straps – Shoulder strap – Adjusting buckles – D-ring(s) Connecting Devices – Lanyards with shock absorbers – Retractable lanyards – Climbing devices – Work positioning devices Personal Fall Arrest Systems • Although applicable directly to Construction under 1926.502, paragraph (d) lists the requirements and expectations for personal fall arrest systems including: • • • Design of system components System performance criteria Care and use of personal fall arrest systems ANSI Z359 Fall Protection Code The American National Standards Institute first published specifications for Personal Fall Arrest Systems, Subsystems and Components” in 1992 as a non regulatory consensus standard and revised them to their current form beginning in 2007. • The purpose of ANSI Z359 was to address the variety of equipment being developed in the rapidly growing field of Fall Protection. • Z359 is an umbrella for a series of eight published fall protection-related Standards and 9 additional proposed standards currently being developed. Five additional Standards were approved as of November 24, 2007: • • • • • ANSI Z359.0 – Definitions and Nomenclature Used for Fall Protection and Fall Arrest ANSI Z359.1 – Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components ANSI Z359.2 – Minimum Requirements for a Comprehensive Managed Fall Protection Program ANSI Z359.3 – Safety Requirements for Positioning and Travel Restraint Systems ANSI Z359.4 – Safety Requirements for Assisted Rescue and SelfRescue Systems, Subsystems and Components An additional three Standards were approved November 16, 2009: • • • ANSI Z359.6 – Specifications and Design Requirements for Active Fall Protection Systems ANSI Z359.12 – Connecting Components for Personal Fall Arrest Systems ANSI Z359.13 – Personal Energy Absorbers and Energy Absorbing Lanyards General Duty Clause In the absence of specific regulatory compliance requirements, OSHA will apply Section 5(a)(1) The General Duty Clause: “Each employer shall furnish to each of his employees employment and place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm…” Controlling Falling Objects Be aware of people working beneath you. Clear the area below due to the great velocity that can be generated from a dropped tool or other item. To additionally assure safety… • Tether your tools • Cover any opening that materials or parts could drop through • Helmet/hardhat protection and safety glasses must be worn when personnel are overhead Safe Ladder Climbing Practices • Know your ladder safety system by practicing with it at safe heights before climbing long distances. • Use three points of contact with the ladder at all times • Do not carry anything in your hands or in a way that your climbing could be affected – Instead, use a hoisting bag with a secure cover, a rated hauling rope, or an elevator or installed lifting device Safe Ladder Climbing Practices • If stopping to work or rest, tie off with additional fall protection to the beam of the ladder above you. • NEVER hang from the ladder safety system as your sole support. • A good rule is allowing only one climber per ladder section between platforms • Step off the ladder and securely onto the platform before disconnecting your ladder safety system Hatches • Once you reach the platform, close the hatchway cover (if so equipped) • If the hatchway remains open for the next climber or for hauling work, tie off with your lanyard to an anchor point or part of the turbine structure • A good rule is to shout out “hatch open” and “hatch closed” to notify other climbers of your activity and position above or below them • If you hear a warning or noise that indicates something has been dropped - COVER UP to minimize the chances of being hit DO NOT LOOK UP TO SEE WHAT IS FALLING! Personal Fall Arrest Systems PFAS consist of: • An anchor point • A means of connecting the climber to the anchor • A full body harness Anchor Points Two Types: • Rated (Engineered) • Structural Attachment Rated Anchor Point: • • • • Rated Anchors commonly have a 5000 lb. static capacity per employee attached OR: Is designed, installed and used as part of a system that maintains a safety factor of at least two and is under the supervision of a qualified person. Should be labeled and or color coded Only one climber per rated anchor point – (Unless labeled otherwise) • DO NOT USE The Anchor point it if damaged, corroded or compromised in any way Structural Anchor Points • • • Tie off only to structure you can trust to be a minimum 5000 pound static capacity One climber per anchor point Created on structural steel from fall rated webbed straps, slings, ropes, and connectors (snap hooks or carabineers) • • DO NOT USE if the strap, sling or rope is damaged, or the connecting devices are defective in any way A qualified person shall determine appropriate anchorage points. PFAS When stopping a fall, a PFAS must: • Limit the impact to less than 1800 pounds of arresting force on the body • Prevent a person from contacting a lower level • Bring the person to a complete stop and limit the maximum deceleration distance of a shock absorber to 3.5 additional feet • Have the strength to withstand at least twice the potential impact force of a worker falling the full 6 foot length of their protective connection lanyard (the maximum permitted PFAS fall distance) Positioning Device Systems These allow workers to do hands-free work from vertical ladders or the tower/turbine structure: • Positioning devices are not a fall arrest system. Additional tie off must be used for personal fall protection • Must limit free fall to no more than 2 feet • The anchorage point must be capable of withstanding twice the potential impact of a worker’s fall or 3000 pounds whichever is greater. Inspection Before you climb – EVERY TIME: • HARNESS – Cuts, tears, chemical stains, heat damage or burns, torn stitching, extreme fading, lack of labeling, excessive age Check all D ring(s) and connecting hardware for damage, such as stretching, narrowing, bending, cracks, etc. Make sure the fall indicator is not deployed • LANYARD(s) – Same checks as for harnesses Snap hook connectors show no damage and operate correctly and also need to be inspected for throat damage and damage to the keeper Always follow the Manufacturer’s Recommended Inspection Procedure Snap hooks must be of a locking type. Inspection Before you climb – EVERY TIME • Ladder Safety Device: Condition of the steel cable Appearance and mechanical action of the cable grab device The device is properly oriented on the cable Smooth non-binding passage of the grab device over the cable Device properly engages on the cable when quickly loaded Measuring Total Fall Distance Fall Arrest Equipment: • 6 foot lanyard with shock absorbing lanyard measuring 3.5 feet fully elongated 4.0 Ft. 6.0 Ft. Free Fall 3.5 Ft. Shock Absorption (9.5 Ft. Lanyard Fall Distance) 15.5 Ft. Minimum Clearance 6.0 Ft. Height (D-ring to worker’s feet) Add another 2 feet as a safety margin to allow for harness stretch Projecting obstructions may affect the Total Fall Distance. Actual distance from D-ring to workers’ feet may vary. Swing Falls When moving vertically and/or horizontally away from an anchor point, the climber must consider both the mechanics and consequences of a swing fall. Has the best anchor been chosen for the work to be completed? • In a swing fall, sufficient force to deploy shock absorbers in the fall system may not occur • The impact against surfaces can result in fractures, lacerations and internal bleeding. • These injuries can complicate the already difficult job of rescuing the fallen worker Best Practices for Tying Off • Pick an Anchor point that will not fail • Tie off directly overhead whenever possible • Calculate the fall distance and set your protection to avoid hitting lower levels • Maintain your stability and footing at all times Always use caution … Climb as if you had no fall protection to save you Suspension Trauma After a fall, if a person is stranded in their harness the weight of their body on the leg straps cuts off blood flow returning to the torso. Blood pools in the legs severely limiting flow to their upper body and head. • Unconsciousness overcomes the victim followed shortly after by respiratory arrest in as little as 10 -15 minutes after suspension begins • Once the victim is lowered to the ground and tension is released, a large volume of poorly oxygenated blood will flow back to the heart, lungs and brain from the legs. • This complicates their rescue, compromises resuscitation efforts and ultimately threatens their survival... • Detailed FIRST AID TRAINING should be provided to anyone who may have to treat a victim of Suspension Trauma Suspension Trauma • Uninjured climbers can quickly deploy support straps or use their tensioned positioning lanyard beneath their feet to lessen harness pressure and activate leg muscles, effectively limiting or delaying the effects of suspension trauma • Even with this emergency support, a plan to promptly reach the victim and get them safely down for medical care must be in place to have the best chance for a successful rescue Safe Access and Rescue Training It is very common for Wind Energy facilities to require their employees and contractors to complete competency training in: • The safe use of all required fall protection equipment • The ability to perform rescue of injured personnel • The ability to make a rapid emergency evacuation from a tower, turbine nacelle or hub • Recertification training is often required every one to two years Rescue Considerations • Preplan rescues and provide training so that everyone is familiar with how to carry out a rescue, what equipment is needed and how to contact municipal responders and get them to the turbine site • Rescues are high intensity and high stakes. Be prepared by practicing at least twice a year with your equipment and personnel to be ready if an emergency occurs Conclusions • • • • • Know the rules - OSHA’s and your worksite Understand how to use your equipment and inspect it before each use Watch for hazards and apply control measures to eliminate your exposure to falls and other dangers Expect your partner(s) to work as professionally as you do. Set them straight if they jeopardize their safety or yours Know the rescue plan and how to respond if an emergency occurs