A Focus on Fall Protection

Workplaces have undergone significant transformations in the 21st century. But you wouldn’t know if you looked at the violations the Occupational Safety and Health Administration (OSHA) issues.

In late September, OSHA announced its annual report of their top 10 most cited violations for fiscal year 2024 at the National Safety Congress (NSC)’s Safety Conference & Expo.

What exactly do the OSHA violations tell us about workplace safety?

It is difficult to draw concrete conclusions from this data for a couple important reasons:

Cited violations only indicate unsafe practices occurring in workplaces and do not reflect how many injuries or fatalities are actually occurring from said unsafe work practices.
OSHA’s Top 10 report only reflects cited violations in states that abide by federal OSHA, not the 27 states with their own OSHA programs, such as California, Washington or Virginia, to name a few.

To complete this data and give us a clearer picture of the current state of worker safety, the U.S. Bureau of Labor Statistics (BLS) releases annual reports of workplace injuries and fatalities. However, their data typically lags one to two years, so acquiring year-by-year data to understand the correlation between cited violations and injuries in the field is like chasing a moving target.

What are the common violations leading to citations?

It’s one thing to see what OSHA regulations are being violated regularly; it’s another to recognize what unsafe practices lead to OSHA citations. Let’s take a look at each of the four fall-related violations.

General fall protection requirements

Regarding general fall protection requirements, OSHA agents can issue citations for simply observing at-height workers without any means of fall protection or improperly using fall protection equipment. OSHA mandates that employers provide some means of fall protection to general industry workers performing tasks at risk of falling over 4 feet to the next lower level or over 6 feet for construction workers. That could be a guardrail, a personal fall protection system or safety netting; regardless, some form of fall protection must be used above those height thresholds.

Ladders

Regarding ladders, one of the most common violations is workers failing to maintain three points of contact when using a ladder. This can prove challenging for workers when they’re using both hands to perform their tasks while standing on the ladder. Imagine the difficulty in trying to change an overhead light bulb while always keeping one hand on the ladder! Nonetheless, OSHA requires workers to constantly maintain three points of contact when using a ladder. Many ladder manufacturers now offer platform ladders with integrated safety railings around the top of the ladder to decrease the worker's chance of falling. Those integrated railings can be considered a guardrail and allow workers to use both hands for their tasks without violating OSHA code.

Another common ladder violation regards proper setup. OSHA requires a 4:1 ratio when using extension ladders; in other words, for every four 4 feet the ladder extends vertically, it must extend 1 foot away from the structure. For example, the base of a 12-foot ladder should be placed 3 feet away from the structure for optimal stabilization.

Fall protection training

Fall protection training comes in many forms but must be a documented part of every organization’s fall protection program. For example, OSHA requires employers to designate Authorized Users before employees are permitted to perform work at-heights. This type of initial fall protection training must (at minimum) educate the designated employees on the specific fall hazards present at their work site, how to identify them, and how to use their equipment properly.

Further, employers must retrain employees after any of the following:

a change to the work environment occurs,
new equipment/systems are being utilized, or
an employee displays a gap of understanding that prevents them from working safely.

Employers must document when training sessions occur and the employees who are permitted to use fall protection equipment.

Scaffolding

Lastly, many components are involved in proper scaffold erection and operation, but one common violation seen in the field is failure to provide fall protection to employees. Per OSHA, employers must provide fall protection to scaffold workers who are 10 feet or more above the ground. Many scaffold manufacturers offer integrated anchorages in the scaffold assembly or can integrate horizontal lifelines for workers to tie-off.

close up of fall protection tethering, workers' legs and sunset in the background

What can be done to improve worker safety?

There are many ways to increase the effectiveness of safety and fall protection programs immediately.

One of the best strategies for employers is to bolster their training program. Training programs educate workers on how to use their equipment properly and reinforce the importance of using fall protection consistently.A 2021 study conducted by the Center for Construction Research & Training (CPWR) found that employees were eight times more likely to use fall protection equipment if they believed their company required its use.

Training programs also help address concerns from frontline workers that may not be obvious to safety leadership. Too often, safety managers can become overwhelmed by administrative tasks, responding to violations or investigating past incidents. And unfortunately, that means they cannot devote the time and attention to proactively making their facilities or job sites safer. Training sessions offer a unique opportunity for employees to ask questions, advocate for their needs and propose solutions that could protect them from everyday hazards.

Another way to immediately improve fall protection programs is to perform routine fall hazard surveys of the facility or jobsite. Some organizations utilize OSHA consultation programs, which are available in most states for companies that want to ensure their facilities meet minimum regulatory compliance standards. Others choose to invite their safety equipment suppliers or fall protection manufacturers to their facility to perform assessments and provide options for solutions. Manufacturer partners can help organizations meet minimum OSHA standards as well as suggest solutions to exceed compliance.

Exceeding minimum compliance is likely the only way true progress will be made in the effort to improve worker safety. While adhering to OSHA requirements is a must, being mindful of ANSI/ASSP Z359 guidelines and other consensus standards will help bolster corporate safety policies by aligning with the manufacturers of the fall protection equipment workers utilize.

How do I use OSHA data to make my workplace safer?

While the decrease in overall fall protection OSHA citations is encouraging, falls remain one of the leading causes of workplace injuries and fatalities. A slight decline in reported violations is simply not enough to drive the meaningful change desperately needed to improve worker safety.

This data shows that many organizations still struggle to meet minimum OSHA requirements for workers who must use fall protection. The first step to preventing fall injuries and fatalities is to focus on bolstering the equipment, training and culture so that fall protection is taken seriously.

Companies that have already done so will be the future leaders of their industries; they have demonstrated that they prioritize worker safety by integrating proactive fall protection methods into their standard operating procedures. Investing in fall protection programs is a sign that a company is committed to investing in a its most important asset: its people.