Falls remain the number one killer of workers in the construction industry and the number two killer of workers in private industry, according to the Bureau of Labor Statistics. One would think, given the numerous fall protection equipment manufacturers and consultants, that fall hazards would be extinct or at least significantly diminished. Unfortunately, statistics and client experiences indicate otherwise.
Initially, companies turned to fall protection equipment to correct the fall hazards, but soon acknowledged there were structural engineering issues involved that significantly impacted the level of safety.
For example, the day before his retirement, a man fell through the roof to his death because black visqueen covering the hole was unsecured and unmarked. An untrained construction worker left his body's imprint in concrete after a 15-foot fall, and a young man in his mid-twenties was left a paraplegic after experiencing a 15-foot fall because he was willing to take the risk of not wearing his fall protection equipment.
These are all tragic and preventable incidents. During training programs, we hear stories of companies that have fall protection programs in place but do not realize they keep bringing additional fall hazards into their facilities via insufficient building and machine design. We discover there are companies still willing to bank on Lady Luck versus taking a proactive stance against fall hazards. These statistics, experiences and stories are strong indicators that the issues impacting the fall protection process are alive and deadly. Fall-related injuries and deaths have not declined to a level where safety professionals can breathe a sigh of relief.
Fortunately, many employers are beginning to realize that the level of training their teams receive iimpacts how successful work-at-height activities are. Rescue, often thought of as a 9-1-1 response, has to redefined and moved to the pre-planning process. Complex issues have to be addressed in order to increase the safety of people working at heights. In short, a comprehensive standard is needed that addresses the entire scope of fall protection.
Why a Standard is Needed
Developing an effective managed fall protection program is not a simple task and appears even more complex given the myriad of OSHA regulations, ANSI standards, design requirements and equipment product lines. The number of injuries and fatalities occurring as a result of falls are both high and frequent. The across-the-board misconception is that one neat, tidy and perfect solution exists fall protection equipment. Selecting fall protection equipment appears to be quick and easy and gives the illusion of low maintenance. However, the purchase of this equipment introduces some very relevant issues: training, clear height distance and swing fall calculations, and anchorage requirements.
In addition, companies have to convince their work force that not only is it necessary to wear the equipment, but that it needs to be worn correctly and every time they work at heights. We have observed authorized persons wearing full-body harnesses without the leg straps being secured and anchored to wheelbarrows, vent pipes, gutters, sprinklers or nothing at all. We have observed authorized persons wearing full-body harnesses correctly but connected to a system that would allow them to hit the ground before it deployed. Frequently, companies purchase several different lines of fall protection equipment and their authorized persons mix and match the different product lines without considering performance or compatibility issues.
Lack of training left many competent persons unaware of: inspection, use and maintenance requirements and procedures; the need for re-training and re-purchasing of equipment when processes or workplace activities changed; third-party testing recommendations for all components in a system; the need for training facilities equipped for classroom and hands-on activities; and that prompt rescue was not a call to 9-1-1.
It wasn't just inadequate training that impeded change, but a very strong mindset, defense and ownership of existing methods, policies and procedures. Consistently and across the board, our trainers noted that students were reluctant or unwilling to challenge their fall protection methods until the second half of the second day of training, or sometimes until the third day. The process of being open and aware of the need for change required a thorough introduction of statistics, regulations, standards and equipment. Until this happened, many students remained closed-minded to accepting a managed fall protection program approach. Many companies were operating in the "just get it done" and "time is money" mentality, whether from the economy, lack of training or corporate culture. This approach cost companies time, money and lives.
What had once appealed to management as the one perfect, neat and tidy solution was becoming more and more complex. And since adequate training criteria was not established, they were slow to recognize the power of integrating engineering and safety methods as a best-practice approach to protecting lives, saving money and increasing the efficiency of authorized persons and their companies.
So, how is it possible to develop a proactive fall protection program? The ANSI Z359.1 committee thinks it has found a way to help employers and workers improve fall protection and reduce preventable fall-related injuries and fatalities.
What is a Managed Fall Protection Program?
"The Managed Fall Protection Program" (MFPP) standard combines both safety and structural engineering in an effort to assist companies and their teams in the development of a safe, effective, ongoing program. The term "managed" is important as it calls attention to the issues people "don't know that they don't know," and the standard clearly lays out the responsibilities of workers and management.
Developed to cover all industries with the exception of construction (currently being addressed by ANSI A10.32) and mountain climbing the ANSI Z359.1 committee has raised the bar on the development of the MFPP standard by including engineers, safety professionals, trainers, testing laboratories, end users, military personnel, OSHA, fall protection equipment and component manufacturers, and rope rescue and rope access specialists as members of the committee. The expertise, talent and passion of this team are creating greater value for this program. They have connected the elements of existing fall protection standards to a universal format and provided tools for employers to develop a comprehensive program.
The scope of the standard is comprehensive and outlines fall protection policy guidelines and requirements; duties and responsibilities; fall hazard survey reports; fall protection procedures; training; elimination or control of hazards; rescue and evacuation plans; accident investigation; and program evaluations. One of the most important aspects of the standard are the definitions for:
- Authorized Person
- Authorized Rescuer
- Competent Person
- Competent Fall Protection Trainer
- Competent Rescuer
- Competent Rescue Trainer
- Continuous Fall Protection
- Fall Protection Procedures
- Program Administrator
- Qualified Person
- Qualified Person Trainer
- Rope Access
The definitions have been influenced by safety, engineering and training disciplines to clear up the gray areas and provide a clearer direction. They expand and re-direct the activities of the Competent and Qualified Persons. This should help to eliminate some of the gaps that currently exist and clarify their roles and responsibilities.
New and Expanded Procedures
Stakeholders decided it was time to raise fall protection up a notch by re-visiting and improving the requirements for issues such as pre-planning, rescue and design. The MFPP standard also provides the details of the Qualified Person's responsibilities to the MFPP. The MFPP requires that:
- Fall protection procedures, not the OSHA Fall Protection Plan, should be used at every location of an active fall protection system used to control a fall hazard. These procedures require pre-planning before work-at-height occurs.
- Design of fall protection systems and their anchorages are to be based on accepted engineering methods or testing protocols.
- The burden of safe design is to be placed back on the designers and owners.
- Design criteria for the Qualified Person (QP) is to be provided and the differences between a QP and an engineer are to be outlined.
- The Hierarchy of Control (HOC) is to be used for identification, elimination or control of fall hazards.
- Rope access must be used by workers whose training has been confirmed with independent assessment and certification. The training for rope access in rescue is different than that for mountain climbing, which is not covered by ANSI.
- Management should designate a Program Administrator (PA) who is committed to the process and implementation of the MFPP. Due to the knowledge and experience of the PA, it is more likely that the fall protection program will work and be more financially efficient.
- Rescues are to be pre-planned. In addition, rescue equipment might be required to be installed before work-at-height occurs, which will increase the possibility of prompt rescue.
In addition, the standard makes all divisions of the company responsible for their portion of fall protection knowledge. It also expands and more clearly defines the responsibilities of the Qualified and Competent Person for rescue, anchorages and calculations. It also expands and redefines the term "worker" to be the Authorized Person (AP).
Finally, OSHA warning lines, controlled access zones and monitors are not accepted by the ANSI Z359.1 standard.
In the past, employers have unknowingly passed their roles and responsibilities on to inadequately trained CPs and APs. Many managers believed they were working from a complete program but were not. This standard clearly identifies this criteria and requires employers to:
- Develop and implement a fall protection policy.
- Provide adequate fall hazard abatement before employees can perform workplace activities.
- Provide and verify continuous fall protection is available for their employees for all workplace activities.
- Have a Competent Person to supervise all work activities performed above 4 feet.
Training programs for fall protection have been inconsistent with the number of hours required, desired skill sets and how to implement fall protection on the job. The criteria of the new standard introduces new requirements and clarifies the items that should be included for fall protection and rescue training. It:
- Establishes skill sets to be learned.
- Allows firms to accurately evaluate the qualifications of their personnel.
- Verifies employees are receiving the same level of training.
- Verifies employees are receiving appropriate levels of training.
- Outlines frequency of training and accountability of all parties.
- Includes rescue.
Fall Protection Procedures
Elements that had not existed before the new standard and items that were missing from old standards have been identified and are represented in common terms. The MFPP standard requires 100 percent continuous fall protection, with pre-planned procedures developed before work-at-height occurs. Employers are required to prepare fall hazard survey reports for each fall hazard that identifies current and predictable work paths and their fall hazards and the locations and distances of all obstructions. In addition, a fall hazard analysis must be performed for each workplace activity.
The advantage of the MFPP is that it is as easy for a small business as a corporation. It provides a structured A-B-C approach to the development of a fall protection program and eliminates the possibility of missing components in a program. Implementing this program should create a positive, improved culture change. The MFPP includes elements of fall protection programs that historically have been missing. This will provide stability and consistency to your fall protection program.
Michael C. Wright, PE, CSP, CPE is president of Safety through Engineering Inc., an engineering, safety and expert witness consulting firm. Moniqua Suits is the director of training for Safety through Engineering Inc. Safety through Engineering Inc.is a nationally recognized consulting and expert witness firm providing litigation support services for defense, plaintiff and OSHA clients.