Getting Started with Managed Fall Protection
Since the late1980s, when OSHA and ANSI introduced standards for fall protection, companies have been tackling the issue of fall hazards. Initially, companies thought fall protection equipment was the sole method to protect their workers against injuries and fatalities resulting from working at heights. But given the high number of fatalities that continued to occur both in general industry and construction, the sole use of fall protection equipment was being reevaluated.
Emerging through this time period was an awareness of the need to use an integrated approach of engineering and safety. Gradually, companies realized this approach would help them to protect lives, but there wasn't a single standard centered on this integrated approach that addressed and structured all the issues associated with fall protection. This void motivated the ANSI Z359.1 committee to put together a document that outlined a standardized approach to make it easier to develop and implement a fall protection program. The ANSI standard should be finalized this winter.
Calling the managed fall protection program a "milestone in the maturity of the practice of fall protection," Dr. Frank Weisgerber, structural engineering professor at the University of Cincinnati and committee member, noted that up until this effort, fall protection programs were not fully developed. "Now," he says, "there is a standardized approach that helps individuals and their companies to develop a program that is more appropriate and efficient, therefore more effective, than a patchwork approach."
Getting Started. The cornerstone of the managed fall protection program is the process of pre-planning, which includes identifying the people, items and issues involved. It is important to make certain that all the factors have been identified and considered while you are developing your program. Since new terms have been added and responsibilities expanded, the best place to begin is with the definitions. As you review the definitions, you will begin to understand what is involved with this program and why training plays such a critical role. You could even begin to consider who in your staff could fulfill these responsibilities.
A key individual in the managed fall protection program is the program administrator. This role should be filled by someone with the ability to communicate well with both staff and management. He must also be able to help the company's financial team to understand the value of good versus cheap equipment. He should possess a general safety background and have completed the competent person training (we recommend a 40-plus hour course).
The next pivotal player is the competent person, usually a foreman, supervisor or safety person. This person needs to have strong communication skills and be willing to learn new ways. He can't have the "we've never done it this way before" attitude or your program will have problems getting off the ground. Your core competent persons should make up the fall protection committee.
The qualified person should be a structural or civil engineer with advanced training, knowledge and experience in fall protection. This person must know how to develop fall protection abatement procedures and understand that different abatement solutions have different required anchorage strengths. In addition, he or she needs to be able to design fall protection systems based on the fall protection equipment that will be used. While other roles aren't insignificant, these three play critical roles in the success of your managed fall protection program.
Next, you can assess the current condition of your fall protection program. This is the point where you identify members of the fall protection committee and begin to develop your approach to addressing fall hazards. Since people are less likely to argue with their own data, begin the process by collecting information that will be used for directing your program. This data includes:
- Fall injuries and fatalities
- Level of management support
- Worker safety behaviors and attitudes
- Design and renovation projects
- Machinery and process installations and removals
- Fall protection training programs
- Level of commitment to additional fall protection training
- Candidates for the fall protection committee, program administrator and competent person
- Budget figures
- Program expectations for workers and the company
- Obstacles to address
Discussing this information will assist your team in understanding the areas of your program that require improvements and help to develop an action plan. Elements of the plan can include: issues to be addressed, priorities, resources needed (people, financial, training), targeted completion dates and how you are going to measure the success of actions taken (see chart).
Training. A critical decision will be to determine the type of training needed and identify the persons who need to be trained. One of the first groups you will want to train is the fall protection committee. This group should be made up of representatives of the company pipe fitters, electricians, millwrights, safety, purchasing and plant engineering so that all work activities are considered and understood. We recommend that members of the committee be trained together to the competent person level. This will forge stronger working relationships, better understanding of other's work responsibilities, and facilitate a networking relationship among committee members so they feel comfortable asking for help outside their work activity knowledge. We recommend that the committee complete at least a 40-plus hour competent person training course to help them to appreciate each other's skills and to develop a cohesive team. When they return to their peers, each individual member can positively influence their team's ability to understand and respond to the safety changes.
Once the fall protection committee has been trained to the level of competent person, they can begin the audit survey process. Start by selecting a small area of the facility and using two to three committee members to perform the audit together. One member should be familiar with that area and the other two from different backgrounds. Although it is important to have a good understanding of the workplace activities involved, seeing things day after day (year after year) can cause us to overlook the hazards that are present. A fresh set of eyes will generate a different perspective.
Hazard Ranking. The committee should use a fall hazard ranking system while auditing the area. Keep it simple by using a scale of 0 to 10, with 10 being the highest and the sum of 1,000 indicating the worst. Your team can use these three factors to assist in ranking hazards:
- Probability that an injury or fatality will happen
- Severity of the potential injury
- Frequency of the exposure
Once the hazards are ranked, calculate the sum by multiplying the probability by the severity and by the frequency. This product will help you to prioritize which hazard to address first. Please keep in mind that this system is not complete in and of itself. If the frequency (exposure) to a hazard is low, let's say once a year, you can still have a serious problem if the probability and severity numbers are high. This highlights the benefits of using a consultant with advanced knowledge of fall protection to make the audit more comprehensive.
Abatement. After the hazards have been identified and ranked, the committee can identify methods of abatement. This is where they will get their first real-life taste of applying the Hierarchy of Fall Protection. First they must consider if the hazard can be eliminated by changing the way the work is performed. This is where the "we've always done it this way" attitude gets in the way. Typically, people have great difficulty accepting a new or different way of performing work. Although it is often the most argued point of this process, more often than not, the machinery or process can be redesigned to eliminate the hazard.
If the hazard cannot be eliminated, then engineering controls can be applied. This can be as simple as adding a platform with guardrails or attaching guardrails to an existing machine to produce a safe working surface. Next, as you work down the Hierarchy of Fall Protection, consider providing fall restraint where the authorized person is not exposed to the fall hazard in such a way that they would free fall.
If restraint is not possible and fall arrest equipment is selected, the first issue to consider is the need for a rescue plan as required by OSHA. Rescue is typically the most forgotten, neglected and misunderstood element of a fall protection program. It is necessary to pre-plan this activity before work at height happens. It can involve a buddy system, radio equipment or other acceptable procedures to ensure prompt rescue of the fallen authorized person. You should not wait until a fall occurs to think of rescue.
Implementing a new program takes hard work and effort. The challenges involve changing old habits and behaviors, adjusting to new work practices and re-thinking how you approach design, construction and maintenance. However, the benefits of developing a new, safer work culture is a great legacy to leave and the competitive edge it will provide is a sound business practice.
Michael C. Wright is president of Safety through Engineering Inc. He serves as sub-committee co-chair for ANSI Z359.1. Moniqua Suits is director of training for Safety through Engineering Inc. Both are nationally recognized authors, presenters and trainers. They started Safety through Engineering Inc., an engineering and safety consulting firm with full safety and design/build services.