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www.asse.org NOVEMBER 2010 PROFESSIONAL SAFETY 47

Best Practices in Fall Protection By Kevin Denis

One of the best fall protection practicesan employer can implement is a for- mal managed fall protection program. Adhering to minimum OSHA require- ments is beneficial, but consistency suffers and OSHA regulations simply cannot address specific fall protection issues that every employer has. Developing a fall protection program can be a daunting task since it is often performed retroac- tively, after personnel have been working at height for years without the benefit of a formal fall protection program.

Most employers that have fall hazards present in the workplace have a policy already in place. Most programs involve issuing personal fall protection equipment to each worker and providing some level of training so workers can solve fall haz- ards as they are encountered. Best prac- tices dictate that employers do more than procure PPE and provide training. Issuing PPE for either a fall arrest or fall restraint system may not be the best solution to address a fall hazard. The best solution may be elimination or substitution of the task where fall protection is required. The use of passive fall protection systems, such as guardrails or covers, may also provide a more appropriate solution.

ANSI/ASSE Z359.2-2007, Minimum Requirements for a Comprehensive Managed Fall Protection Program, describes several key pro- gram elements (learn more at https://www.asse.org/ cartpage.php?link=Z359-2 -2007). This standard, and the process it prescribes, can be applied to any fall hazard in any industry. It is a methodical, logical way to identify fall hazards, cre- ate solutions and develop a program.

Management Commitment & Policy

Resources are required to develop a fall protection pro- gram. Management must be aware of the fall hazards employees encounter during the course of the workday so manage- ment can provide guidance and resources to address these hazards.

Development & Education of Key Personnel

Regardless of the company’s size, key personnel must be identified to manage the fall protection program. Larger com- panies often develop a steering commit- tee that is made up of a cross-section of

workers. Smaller companies may only have one or two key people. Either way, the group is responsible for the pro- gram’s success, including identifying and categorizing fall hazards, determin- ing solutions, writing procedures and developing training.

Fall Hazard Assessment An assessment of individual fall haz-

ards provides valuable information. Often, the fall hazard assessment consid- ers the height of a fall and/or a legislated

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48 PROFESSIONAL SAFETY NOVEMBER 2010 www.asse.org

Standards Developments

duty to provide fall protection. An assess- ment that considers only these two fac- tors rarely provides enough information to develop adequate solutions. Task fre- quency and duration, similar work areas, area obstructions, environmental condi- tions and the reason for the exposure also should be investigated. The most feasible solution is easily recognized when good information is gathered.

Hierarchy of Fall Protection After the assessment, fall protection

solutions can be identified and devel- oped based on the employer’s policies and budget. The program administrator or steering committee can use the hierar- chy of fall protection to address specific hazards (or groups of hazards).

The hierarchy is the preferred order of control to eliminate or reduce fall haz- ards. This methodology mirrors com- mon safety practices for hazard abatement beginning with elimination and ending with administrative controls. Using the data collected from the fall hazard assessments, each solution in the hierarchy can be applied to each hazard.

The preferred solution to all fall haz- ards is elimination. The reason for expo- sure to the fall hazard is challenged and evaluated to determine whether a change in the procedure, practice, loca- tion or equipment will eliminate expo- sure to the fall hazard. Specifying that HVAC equipment be located on the ground or in an equipment room rather than by the edge of the roof is an exam- ple of hazard elimination.

Using passive methods of fall protec- tion is the next best solution. Physical barriers such as guardrails around unprotected edges and covers over holes are examples of passive fall protection. One can find many situations in which an employer did not consider guardrails around the perimeter of a building because of initial higher capital costs.

Yet, the cost of the PPE may be higher in the long term. PPE requires worker training, inspection and replacement, along with the identification of (or lack of) anchorages. Rescue planning also must be included. Passive protection is generally considered to provide a higher level of safety since the opportunity for error is lower than using PPE to accom- plish the work. However, passive protec- tion may not be warranted if the frequency and duration of exposure to the fall hazard is limited. An exhaustive

hazard assessment provides the informa- tion needed to make these kinds of deci- sions to maximize cost-effectiveness.

Fall restraint is the next method of fall protection in the hierarchy of controls. Fall restraint systems are erected in such a manner that a fall cannot occur. Fall restraint systems use PPE to restrict workers’ range of movement so they cannot physically travel to the fall haz- ard. Fall restraint systems are often underutilized because they are not specifically mentioned in many regula- tions, but they are preferred over fall arrest systems. Free fall distance is not an issue for fall restraint systems, so arresting forces, clearance requirements, secondary injuries and rescue issues are virtually eliminated.

If fall restraint is infeasible, fall arrest is the next preferred method of fall pro- tection. Fall arrest systems are erected in such a manner that a fall can occur but the fall is arrested within acceptable force and clearance margins. Fall arrest systems have a higher risk since the falling worker must be stopped within an acceptable level of force to prevent him/her from contacting the surround- ing structure (or the ground).

Workers who use fall restraint and fall arrest systems must be trained so they understand the difference and how to assemble the systems. ANSI/ASSE Z359.2 includes a significant amount of informa- tion about fall protection training for authorized persons, competent persons, qualified persons, rescuers and trainers.

The last control method in the hierar- chy is implementation of administrative controls. Administrative controls are work practices or procedures that increase a worker’s awareness of a fall hazard. Such controls are the least preferred method of protection because they do not provide a physical or positive means of protection. They are preventive measures taken to reduce the likelihood of a fall.

These methods include safety moni-

tors, warning lines, warning horns, des- ignated areas or control lines. It also must be noted that OSHA regulates the use of many administrative controls, and the fall protection program administra- tor must understand the jurisdictions and regulations that apply.

Program Implementation & Maintenance

Many components of the fall protection program come together after solutions are determined. PPE can be sourced and pur- chased, and training can be developed. As noted, ANSI/ASSE Z359.2 provides direc- tion for authorized, competent, qualified persons and program administrator train- ing (as well as others). Much like a fall hazard assessment, a training assessment helps ensure that training includes writ- ten objectives and observations.

Other requirements of the fall protec- tion program are identified after fall haz- ard solutions are determined. Engineering for permanent solutions may be needed or it may be necessary to design horizon- tal lifelines or certify anchorages. The number of unique fall hazards may reveal that written procedures are necessary for each area. Those procedures should be included in the training program or mate- rials for the worker.

After solutions are determined, PPE is in place, workers are trained and engi- neering controls are in place, the program only needs to be maintained to include investigations and training updates. As new work is encountered or the worksite conditions change, the whole process starts over with a fall hazard survey.

Best practices for fall protection dic- tate that each area where workers are exposed to fall hazards is addressed. It is also necessary to determine feasible solutions, implement and document the controls, train employees and maintain the program. This methodology pro- vides the highest level of protection for both the employer and employee.

An unprecedented amount of fall pro- tection information is available to employers. The ANSI/ASSE Z359 Fall Protection Code, which includes the Z359.2 standard, has more than 400 pages of information that provides guid- ance for employers who wish to develop an industry-best fall protection program.

Kevin Denis is the training manager for Gravitec Systems Inc., which specializes in fall protection engineering, consulting, training, testing and technical equipment. For the past 15 years, Denis has been involved in the estab- lishment of successful fall protection programs and audits for dozens of companies throughout Canada and the U.S. He manages a training department that averages more than 50,000 stu- dent-training-hours per year and has authored nationally recognized training standards for many different industries.

A tower climber uses a positioning device and fall arrest system to protect him while performing work on a microwave tower near Mount Rainier in Washington State.