Fall Protection Training Introduction Falls represent one of the leading killers in Construction and General Industry. Falls frequently top the most cited violations lists and cost employers billions in claims. Developing and implementing a fall protection program can prevent many, if not all, of these injuries and fatalities. In 2013 there were 294 fall related deaths out of the 796 worker fatalities in construction alone. That is more than one-third! Because the hazards of working at heights are so highly recognized, governing bodies and standards associations have created stringent requirements for fall protection. Everyone is familiar with the Occupational Safety and Health Administration (OSHA), but may not realize the roll a standards organization such as the American National Standards Institute (ANSI) plays. As of January 1, 2015, OSHA Standard, 29 CFR Subpart 1904.39, Reporting Fatality, Injury and Illness Information to the Government requires covered employers to report work-related fatalities to OSHA within eight hours of learning of the event, and report all work-related in-patient hospitalizations, amputations and losses of an eye to OSHA within 24 hours of learning of the event. OSHA In the United States, OSHA creates and enforces laws in construction and general industry. OSHA was created to protect the worker from unsafe working conditions. Their primary focus is employee safety, often citing owners and businesses for creating or allowing unsafe work practices. Additionally, OSHA can work as consultants when an employer proactively seeks out help. OSHA plays a key role in accident investigation. ANSI Within North America, ANSI holds the greatest influence on fall protection. While ANSI is a voluntary compliance board, it is generally enforced by legislative bodies through reference. You will find them referenced by OSHA, and complied with by manufacturers. In order to include an ANSI stamp on a piece of equipment, manufacturers must put their products through a series of tests to meet previously established requirements. Note: Keep in mind that OSHA sets a minimum standard and local city and state agencies may enforce stricter regulations. You will also find OSHA enforcing ANSI standards, often incorporating them by reference. OSHA has the power and enforcement ability to issue stop work orders and substantial fines for noncompliance. FALL PROTECTION PROGRAMS A comprehensive fall protection program will successfully protect workers, as well as the management designing and implementing it. Programs will include the following: Identification of fall hazards encountered on the job site Development of detailed procedural guidelines developed Selection and use of appropriate equipment and systems Inspection, care and replacement of fall protection equipment, systems and identified anchorages at regular intervals Fall Protection Programs (continued) Implementation of a company policy supporting the new fall protection program Adoption of a comprehensive training and educational program. ANSI Z359.1 – Changes and Who it Affects Since 2007 many people have been calling their safety resources talking about the “new” rules now in effect. Even now, in 2015, some companies are still trying to make sense of the changes and trying to determine whether they apply to their scope of work. In the specification it clearly states that it does not address the construction industry, window cleaning belts, and sports-related activities. One would assume it applies to general industry alone, yet multiple companies and industries (including mining operations and military establishments) are putting and enforcing ANSI Z359.1 in their safety programs. So why the inclusion when it is not specified? Again, ANSI is a voluntary board, so it is up to the end users and governing bodies to determine the level of enforcement. Because it has become enforceable in most areas, here are the changes to be aware of. Gate strengths must meet a 3600 lbs. side and front load, and be clearly stamped o Formerly 350 lbs. side load & 220 lbs. front, or face load Front D-rings may now be used for fall arrest, but must be limited to a two foot (2’ – 0”) free fall and subjected to a maximum 900 lbs. arresting force o Formerly front D-rings were restraint only Twin-Leg lanyards have been added, including proper use and connection Definitions from “user” have been expanded to include “competent person,” “authorized person,” and “qualified person.” Inclusion for a Comprehensive Managed Fall Protection Program o Identify, evaluate and eliminate fall hazards o Ensure proper training of personnel exposed to fall hazards o Ensure proper installation and use of fall protection & rescue systems o Implement safe fall protection & rescue systems DEFINITIONS (Referenced from OSHA 1926.500(b) Subpart M) Anchorage means a secure point of attachment for lifelines, lanyards or deceleration devices. Body belt (safety belt) means a strap with means both for securing it about the waist and for attaching it to a lanyard, lifeline, or deceleration device. Body harness means straps which may be secured about the employee in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a personal fall arrest system. Buckle means any device for holding the body belt or body harness closed around the employee's body. Connector means a device which is used to couple (connect) parts of the personal fall arrest system and positioning device systems together. It may be an independent component of the system, such as a carabiner, or it may be an integral component of part of the system (such as a buckle or dee-ring sewn into a body belt or body harness, or a snap-hook spliced or sewn to a lanyard or self-retracting lanyard). Controlled access zone (CAZ) means an area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled. Dangerous equipment means equipment (such as pickling or galvanizing tanks, degreasing units, machinery, electrical equipment, and other units) which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment. Deceleration device means 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 fall arrest. Deceleration distance means 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 belt or body harness attachment point at the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location of that attachment point after the employee comes to a full stop. Equivalent means alternative designs, materials, or methods to protect against a hazard which the employer can demonstrate will provide an equal or greater degree of safety for employees than the methods, materials or designs specified in the standard. Failure means load refusal, breakage, or separation of component parts. Load refusal is the point where the ultimate strength is exceeded. Free fall means the act of falling before a personal fall arrest system begins to apply force to arrest the fall. Free fall distance means the vertical displacement of the fall arrest attachment point on the employee's body belt or body harness between onset of the fall and just before the system begins to apply force to arrest the fall. This distance excludes deceleration distance, and lifeline/lanyard elongation, but includes any deceleration device slide distance or self-retracting lifeline/lanyard extension before they operate and fall arrest forces occur. Guardrail system means a barrier erected to prevent employees from falling to lower levels. Hole means a gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other walking/working surface. Infeasible means that it is impossible to perform the construction work using a conventional fall protection system (i.e., guardrail system, safety net system, or personal fall arrest system) or that it is technologically impossible to use any one of these systems to provide fall protection. Lanyard means a flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. Leading edge means the edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered to be an "unprotected side and edge" during periods when it is not actively and continuously under construction. Lifeline means a component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), and which serves as a means for connecting other components of a personal fall arrest system to the anchorage. Low-slope roof means a roof having a slope less than or equal to 4 in 12 (vertical to horizontal). Lower levels means those areas or surfaces to which an employee can fall. Such areas or surfaces include, but are not limited to, ground levels, floors, platforms, ramps, runways, excavations, pits, tanks, material, water, equipment, structures, or portions thereof. Mechanical equipment means all motor or human propelled wheeled equipment used for roofing work, except wheelbarrows and mopcarts. Opening means a gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide, in a wall or partition, through which employees can fall to a lower level. Overhand bricklaying and related work means the process of laying bricks and masonry units such that the surface of the wall to be jointed is on the opposite side of the wall from the mason, requiring the mason to lean over the wall to complete the work. Related work includes mason tending and electrical installation incorporated into the brick wall during the overhand bricklaying process. Personal fall arrest system means a system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body belt or body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these. As of January 1, 1998, the use of a body belt for fall arrest is prohibited. Positioning device system means a body belt or body 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. Rope grab means a deceleration device which travels on a lifeline and automatically, by friction, engages the lifeline and locks so as to arrest the fall of an employee. A rope grab usually employs the principle of inertial locking, cam/level locking, or both. Roof means the exterior surface on the top of a building. This does not include floors or formwork which, because a building has not been completed, temporarily become the top surface of a building. Roofing work means the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. Safety-monitoring system means a safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. Self-retracting lifeline/lanyard means a deceleration device containing a drum-wound line which can be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement, and which, after onset of a fall, automatically locks the drum and arrests the fall. Snaphook means a connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object. Snaphooks are generally one of two types: 1926.500(b)(1) The locking type with a self-closing, self-locking keeper which remains closed and locked until unlocked and pressed open for connection or disconnection; or 1926.500(b)(2) The non-locking type with a self-closing keeper which remains closed until pressed open for connection or disconnection. As of January 1, 1998, the use of a non-locking snaphook as part of personal fall arrest systems and positioning device systems is prohibited. Steep roof means a roof having a slope greater than 4 in 12 (vertical to horizontal). Toeboard means a low protective barrier that will prevent the fall of materials and equipment to lower levels and provide protection from falls for personnel. Unprotected sides and edges means any side or edge (except at entrances to points of access) of a walking/working surface, e.g., floor, roof, ramp, or runway where there is no wall or guardrail system at least 39 inches (1.0 m) high. Walking/working surface means any surface, whether horizontal or vertical on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties. Warning line system means a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. Work area means that portion of a walking/working surface where job duties are being performed General Industry: OSHA 29 CFR Part 1910 Competent person is defined as “a person who is capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as in their application and use with related equipment.” Qualified person is defined as “one with a recognized degree or professional certificate and extensive knowledge and experience in the subject field who is capable of design, analysis, evaluation and specifications in the subject work, project, or product.” Construction: OSHA 29 CFR Part 1926 Competent person is defined as “one who is capable of identifying existing and predictable hazards in the surrounding or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” Qualified person is defined as “one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project.” The person in this role should meet these minimum qualifications: Be able to identify existing or predictable hazardous or dangerous conditions related to the workplace, work processes and the safety at heights program Be able to establish controls on identified existing or predictable fall hazards according to the hierarchy of controls Understand how to select, inspect, use, store and maintain personal equipment for fall protection Be able to identify existing or predictable hazardous or dangerous conditions in a personal fall arrest system, and any component thereof Have the authority to take prompt corrective measures to control existing or predictable fall hazards and unsafe fall protection equipment conditions Be able to train workers at risk of falling from heights in accordance with standards and regulations Apply a working knowledge of applicable standards and regulations HIERARCHY FOR FALL PROTECTION Although this training is intended to teach and promote working safely at heights utilizing fall protection equipment, initial steps in all situations should be taken to eliminate the hazard or hazards. You will hear the steps referred to as Engineering and Administrative Controls. Whenever you do your job hazard analysis (JHA or a CRM) and identify known hazards, you should ask yourself if simply changing the process with eliminate the hazard. And we joke that having someone else do it does not count! ENGINEERING CONTROLS There are two types of engineering controls, substitution and elimination, that should be considered. An example of eliminating a fall hazard would be performing the work on the ground prior placing something at heights. An example of substitution would be using an aerial lift rather than climbing and positioning. Another form of engineering out the hazard is the use of “passive” systems, such as hand rails. A guardrail system is defined as a barrier installed to prevent personnel from falling to lower levels while working or traveling on elevated working or walking surfaces. Governing bodies and standard setting agencies dictate the requirements for the installation, testing, and use of all barrier type systems. Guardrails are one of the most common and often overlooked forms of fall prevention. Where suitable, they protect the greatest number of employees with little or no training and no special maintenance. Guardrails shall be built to 42” with a tolerance of +/- 3” (39” – 45”) with a mid-rail at 21”. They will also be able to withstand a pull test of 200 lbs. on the top rail. Safety tip: if you see employees leaning on the rail systems, remind them they are there for warning barriers, not personnel support. Incidents have been recorded where people fell to their death after putting their full weight on a guardrail to “rest.” ADMINISTRATIVE CONTROLS This typically refers to training or scheduling. While it is difficult to use administrative controls to eliminate fall hazards, it is critical to add training to prevent injuries. Administrative Controls can also refer to job rotation to eliminate fatigue, or alarms placed to alert employees of hazards. PERSONAL PROTECTIVE EQUIPMENT The final step in the hierarchy is PPE. When you are unable to eliminate the hazard, substitute a process or change an environment you will engage the proper equipment and training to eliminate the risk. Before we go in to details for fall protection, we must first discuss the culture and attitude of those that will be involved. ALL accidents are avoidable. If you read this statement and do not believe it, you should retrain your way of looking at safety. An accident can be defined as an unsafe situation followed by an unsafe act. In this definition, the verb act is a human control. It is always choice, not chance, that puts someone in danger on the job. When accident investigations occur there is always that single instance that a decision was made putting things in motion. By properly training employees to understand and recognize hazards, along with the repercussions of their decisions, we can eliminate all accidents. Zero Accidents should be the standard, not the goal. FALL PROTECTION BASICS Commonly referred to as the ABCs of Fall Protection, the entire system can be broken down into simple components: Anchor Point Body Harness Connector We also add: Decent & Rescue Anchor Point An anchorage, as defined by OSHA, is a secure point of attachment for lifelines, lanyards or deceleration devices. ANSI Z359 defines anchorage as a fixed structural component such as a beam, girder, column or floor that can support the forces exerted in arresting a fall, and introduces the term “anchorage connector” to refer to the component by which the connecting device is coupled to the anchorage. It may be a beam anchor, cross-arm strap, D-bolt, hook anchor, tripod, davit or other secure device that serves as a point of attachment for lifelines, lanyards or deceleration devices. Anchorages and anchorage connectors must be independent and capable of supporting 5,000 lbs. per employee attached, or designed, installed and used under the supervision of a qualified person as part of a complete personal fall arrest system (PFAS) which maintains a safety factor of at least two (2:1). They must also be located high enough for a worker to avoid contact with a lower level should a fall occur. Body Harness A full body harness is a body support device that distributes fall arrest forces across the shoulders, thighs and pelvis. Full body harnesses have a center back fall arrest attachment for connection to the fall arrest connecting device and may have other D-rings for use in worker positioning, fall prevention by restraint, suspension or ladder climbing. Please note the Full Body Harness is the only legal and acceptable means for fall arrest. Body Belts are no longer recognized as fall arrest devices and should be avoided. Selection of the body harness will depend on the scope of work to be performed. For example, someone doing roof work with a rope system would not need shoulder D-rings for retrieval or a center D-ring for ladder climbing. The back D-ring is the ONLY attachment point for fall arrest (exception being a 2’ controlled device on the front D-ring – see ANSI update at beginning). Connector The connection device is one of the most critical pieces in the PFAS. Things that need to be considered include, but are not limited to: Clearance from the anchor point to the lower level Work zone that needs to be traveled Swing radius in the event of a fall Rescue options Type of work to be done (welding, painting, etc.) Connector types can include energy-absorbing lanyards, positioning lanyards, fall limiters, self-retracting lifelines, rope grabs, or retrieval devices. When choosing a connecting device for fall arrest, one must limit the free fall distance to no more than six feet (6’ – 0”). Devices used for positioning must limit the free fall distance to no more than two feet (2’ – 0”). Decent and Rescue Whenever you work at heights you must include a plan for descending safely to the lower level, or rescuing the employee from the upper level. During a fall, the human body will be subjected to unusual forces and out of the ordinary mental taxation. For these reasons the plan needs to be swift and organized to safely rescue the person within fifteen minutes. Rescue Basics Even though rescue is a key component in a fall protection program, it is often the most overlooked. Plans should be kept simple, but they need to be in place. OSHA 1926.502(d)(20) & OSHA 1910.66, subpart F, Section 1(e)(8) dictates that “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.” In the event of a fall, potential rescuers have been found to panic and overlook critic steps of their training. The plan should be as simple as possible, putting the fewest workers at risk. This can be achieved by using the “Hierarchy of a Rescue” Self Rescue (Climbing or pulling yourself to safety) Assisted Self Rescue (Suspension Trauma Safety Straps, Ladders) Mechanically Aided (Lifts) Rescue Pick-off (Almost Never) Types of Rescue In roughly 90 percent of situations the worker will self rescue. A rescuer does not intervene, instead letting the person who fell climb or pull themselves to safety. This may be anywhere from a few inches to a few feet, depending on the equipment. Following the worker’s safe return to the ground, all the equipment involved in the fall must be removed from service. Mechanically aided rescue means a rescuer intervenes to help the worker to the ground. Mechanical aid can come in a number of forms, including rope systems, hoist lines or aerial lifts. A hoist line may be swung over to the suspended worker, who will grab hold of it. The hoist then lifts the worker to the level from which they fell. A pre-engineered rope system also can be set up to lower the worker to the ground. Finally, an aerial lift can be used to rescue a worker. The lift is positioned beneath the suspended worker and raised so the worker lands within the bucket or cage of the lift. A rescuer attaches a restraint lanyard to the worker and, once connected, removes the impacted fall arrest equipment. In each of these cases, the impacted equipment must be removed from service. Part of the rescue plan should include a form of suspension trauma relief, such as straps or steps. The worker, in the event of a fall, can activate them and step into the strap, relieving the pressure on the arteries. If a harness is not equipped with suspension trauma straps, the rescuer needs to be able to advise the suspended worker on the proper steps to prevent or mitigate the effects of suspension trauma. These methods will include keeping the legs moving, pumping the legs and raising the knees to the body. AERIAL LIFTS While utilizing a lift is a great way to mitigate the climbing and positioning hazard, it can also create an additional hazard. Improper use of a lift can lead to serious injury and even death. It is always a best practice that the person intending to use a lift read and be familiar with the instruction manual. Each manufacturer will have a published document outlining instructions for inspection, use and care of the equipment. Your site safety plan should coincide with manufacturer guidelines. Unfortunately most workers are given a basic overview of the equipment and may miss critical steps to assure safe use. Each lift will be equipped with a safety mechanism, such as a kill-switch or override system, which will not only need to be identified by location, but also inspected or tested prior to use. Be sure the worker is trained on the piece of equipment they will be using. Operation manuals should be readily available for reference. Prior to using a lift you should perform an analysis of the area to be worked. Look for holes, changes in elevations, drop-off, etc. Also identify you soil or surface type to be sure you have secure footing for the machine. Those operating lifts should also embrace a “look up and stay alive” mindset: are there overhead power lines or other obstructions? Will you be creating pinch points during your ascent? Again, refer to the manual for a full list of hazards to be avoided. Aerial Lifts (continued) As with any piece of equipment, you should do a pre-operation inspection and function test for the lift and all the components. It is suggested you keep a check list for pre-operation methods. If any of the functions have been disabled or fail the pre-operation check, immediately remove the lift from service and tag the machine. Do not operate the lift until a qualified service technician makes the necessary repairs. Following manufacturer guidelines, always wear the appropriate fall protection when operating an articulating or telescoping boom. There are varying opinions on whether a restraint lanyard, fall arrest lanyard, or retractable are best for this application. Understanding the hazard will help determine (as will the manual) the correct device. The intent of the fall protection is to restrain the worker in the event the lift bounces or suddenly moves contrary to the intent. An example would be the tires dropping over an elevation change that the worker did not anticipate. The lift can “whip” and create the potential of tossing the worker in the air. By having the appropriate style and length of restraint, the worker will stay safely within the cage. Keep in mind the lifts will be designed with proper handrails to keep the worker safely within the basket or cage when the worker stays firmly on the platform floor. This may include an entry mid-rail that should be closed or lowered at all times during operation. Never tape or tie the rail in an up position for easier access. You should never sit, climb or stand on the guardrails for any reason. If your work area exceeds the lift zone, reassess the methods and get the correct equipment for the job. You should never exit an elevated boom or lift platform unless you have had specific training to do so. You will need to maintain a 100% tie-off procedure. This may also require reference to the operation manual, and could even require a letter from the manufacturing approving the methods. Aerial Lifts (continued) Housekeeping is also a critical step in operating a lift. Excess debris can become a trip hazard for the worker. Equipment and tools should be safely secured at all times when operating the lift. Sudden movements could jar materials or tools loose creating additional hazards. Some manufacturers offer approved attachments such as tool caddies. Workers should also refrain from climbing down lifts when they are raised. In the event the auxiliary system fails, workers should have a radio or phone in the basket or cage to call for assistance. Rescue plans should be in place for such events. The plan could include an additional lift nearby, or standby personnel who can operate the lift from the ground controls. ROLLING PLATFORMS / ENGINEERED WORK PLATFORMS Additional equipment options that help eliminate large portions of fall hazards are engineered platforms. Specialty equipment can be utilized for specific repetitive work virtually removing all fall hazards. Versatile – designed for multiple users and various applications Durable – heavy duty materials for various environments Portable – lightweight designs easily moved by minimal personnel When utilizing engineered solutions you will typically have a manufacturer’s agent involved in specific training. Each structure should have a manual as well as posted signage. Signage will include specifications, weight capacities, and product limitations. INSPECTION FORMS FOR FALL PROTECTION