How to Apply the Hierarchy of Fall Protection Controls on Construction Sites
Providing worker safety on the job site can be a difficult task, due to the constant changes and activity occurring on the average job site. However, the importance of protecting construction workers cannot be understated. In 2022, the construction industry more on-the-job fatalities than any other industry, according to the U.S. Bureau of Labor Statistics. Over 1,000 construction workers suffered fatal injuries while working, and nearly 40% of those deaths were attributed to falls from heights. The majority of fall fatalities occur under 20 feet.
Depending on the scenario, some fall protection solutions are more effective than others in protecting the worker. Furthermore, depending on the task being performed or the location of the job site, different fall protection requirements might apply, sometimes varying from state to state. This article offers guidance on better understanding local fall protection requirements and implementing the most effective solutions possible.
Employer’s Duty to Provide Fall Protection
On construction sites in most states, employers must provide fall protection for workers exposed to falls of 6 feet or greater, per federal OSHA 1926. However, some tasks, such as erecting rebar columns, have different trigger heights for when fall protection is required. Additionally, some states, like California, have their own safety and labor enforcement agencies (Cal/OSHA, in this case) with different fall protection requirements than federal OSHA.
Employers are ultimately responsible for determining their local OSHA jurisdiction and ensuring they have verified fall protection requirements for all tasks being performed on the job site. Many OSHA programs offer free consultation services for companies that want to confirm compliance.
Hierarchy of Fall Protection Controls
When fall protection is legally required, OSHA deems “safety netting, guardrail, and personal fall protection systems” as acceptable means of fall protection. However, that language can justify hundreds of various solutions, so it is essential for employers to understand that not all fall protection solutions are created equal, nor offer the same level of protection for workers.
Those in charge of providing fall protection to workers should fully understand the concept behind the Hierarchy of Fall Protection Controls (Figure 1) and realize that some forms of fall protection are more effective at protecting workers than others. Succinctly, the Hierarchy encourages us to pursue more effective methods of fall protection before resorting to less effective ones.
Hazard Elimination is at the top of the Hierarchy because it completely eliminates the chance of the fall occurring, thus being the most effective way of protecting the worker. Administrative Controls are at the very bottom of the Hierarchy because the worker is still exposed to the fall hazard, but with no means of preventing the fall or mitigating the fall injury; thus, the least effective way of protecting the worker.
As hazards are identified throughout the job site and solutions are suggested, it is essential to always consider Hazard Elimination techniques first before moving down the Hierarchy, and only letting infeasibility be the reason why less-effective solutions are considered.
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Applying the Hierarchy of Fall Protection Controls
Once the employer has a clear understanding of their fall protection requirements, the next step is to assess the job site for any existing fall hazards and identify solutions to mitigate them.
Unprotected edges are an extremely common fall hazard on job sites, simply due to the very nature of construction. Federal OSHA 1926 requires employers to provide fall protection when workers are within 6 feet of an unprotected edge that could lead to a fall of 6 feet or greater to the next lower level. Many construction companies utilize guardrails as their means of fall protection in this scenario because of their simplicity and effectiveness. However, many scenarios exist when workers must perform work on the very edge of their walking-working surface and guardrails cannot be used to protect them. In these cases, infeasibility is determined due to the physical impossibility of installing guardrails around the worker. The employer should then attempt to provide an active travel restraint system to the worker, per the next level of the Hierarchy.
Travel restraint systems are a last-ditch effort to prevent exposing the user to a fall by restraining them with a fixed-length lanyard that is not long enough for them to fall off their work area. However, these solutions can limit mobility and may not be robust enough to protect the worker in all work environments. When it is discovered travel restraint is too cumbersome or even impossible to accomplish, many employers then decide to provide fall arrest equipment to the worker.
Whenever a fall can occur, even when using fall arrest equipment, the risk of injury still exists. Fall arrest equipment can be effective in decreasing the severity of fall injuries, but it does not prevent the fall from occurring. However, providing fall protection equipment and ensuring it is being used properly are two different tasks. Since a fall can still occur, it is imperative that the worker is fully trained on how to properly use their equipment to ensure it works properly. A 2021 study by the Center for Construction Research & Training (CPWR) estimated that nearly 60% of fatal falls occurred while the worker was using fall protection equipment!
For each fall hazard identified on the job site, employers should repeat this process by trying to supply the most effective solutions first before resorting to less effective solutions. This process may initially sound tedious, but it ensures that the site-specific fall protection program is as proactive, comprehensive and effective as possible. Hopefully, many lives can be saved and countless injuries prevented. The value of saving at least one life is certainly worth the effort.
Remain Vigilant
While construction work can be inherently dangerous, it does not mean that workers must constantly work in dangerous conditions. All injuries and fatalities from falls can be prevented with the proper planning, equipment and training. Companies must be vigilant in educating themselves on their local and task-specific fall protection requirements, applying the most effective methods possible, and training their employees to uphold the programs that can protect them from harm.
Adhering to fall protection legal requirements and protecting workers from falls is difficult for many companies. Each year, fall protection violations are OSHA’s most cited violation, and hundreds of workers die every year from falling. However, companies are not alone in combating this issue. They can partner with fall protection manufacturers to assist in assessing their job sites, providing turnkey fall protection solutions, and training their employees. Until people stop being killed from falls at work, we all must work as a team to provide more fall protection to more job sites. Together, we can protect workers and save lives.
