What are Your Options for Fall Protection?

The fall protection plan is a rarely noticed option that can be utilized by employers when other fall protection measures aren't considered feasible.

Protecting employees from falls is a major concern for responsible employers in all types of work settings. From general industry to construction, falls account for a large number of injuries and deaths. In private industry in 2001, out of 5,270 fatalities, 14.6 percent were fall-related, according to the U.S. Bureau of Labor Statistics. The safety profession recognizes the obvious hazards associated with falls as does the Occupational Safety and Health Administration (OSHA). Several portions of the 1910 general industry standards, along with Subpart M of the construction safety standards, address the requirements of protecting employees from the hazards associated with falls.

Fall hazards include falling from elevated working surfaces, falls on the same elevation and falls onto objects that can create injuries. Probably the most obvious concern on many jobsites is falls from elevated surfaces, of which falls of a relatively short distance can be as disastrous as higher falls.

For the safety professional, problems encountered on jobsites usually revolve around the fact that employees aren't trained and the proper fall protection system is not available. Another area of concern is providing fall protection when the methods mentioned in the standard (personal fall arrest, guardrails, safety nets) aren't feasible. It is this area of fall protection where I personally have encountered the greatest confusion, along with the general requirements of fall protection.

To put it simply, employers are required to protect employees from falling from heights in excess of 4 feet within the industry standards and 6 feet in the construction standards. Exceptions to the 4- foot and 6-foot heights are falls from scaffolds, steel that is being erected, and falls where impalement hazards or machinery is being run directly underneath employees. Impalement hazards and machinery require employers to guard the entire area or prevent employees from coming into contact with those hazards. Employers have options within the standards to protect their employees. Options mentioned include guardrail systems, personal fall arrest systems (safety harnesses) and safety net systems. These are addressed in the particular standard and are pretty much straightforward.

But what options does the safety professional have when a job does not lend itself to providing the conventional means of fall protection? Does the safety professional have an obligation to provide fall protection even when the options listed in the standards are not feasible? Who determines if the options are feasible?

Alternatives Available

As a former OSHA compliance officer specializing in construction, I have observed situations when conventional fall protection (guardrails, safety nets, safety harnesses) may not be feasible. Subpart M of the construction standards specifically mentions three areas where an alternative to conventional fall protection may be utilized:

  • Leading edge work (where the edge changes locations when additional material is installed such as metal decking),
  • Pre-cast concrete erection work
  • Residential construction work

A specific example that I encountered recently in South Carolina was the installation of the ridge cap on a metal roof. The ridge cap is a piece of metal that is installed as an employee slides along the top ridge of a roof after the metal decking of the roof has been installed. At times there may not be an adequate anchor point for a fall arrest system to be installed when ridge cap work is to take place. Placing guardrails on a metal roof may not be feasible because of the nature of working with metal and the lack of an adequate way to secure a guardrail system. Safety nets also may be considered infeasible by many safety professionals when the building being constructed is a one- or two-story structure and the hazards of installing the net are greater than the hazards associated with the actual work. If these options are not feasible, what can be done to protect employees? Who makes that determination?

The fall protection standard located within the 1926 construction standards provides for the option of a fall protection plan. This rarely noticed option can be utilized by employees when other options aren't considered feasible. Infeasibility may be determined by an onsite safety official, a management official or employees. However, it is important to note that OSHA will generally consider conventional fall protection feasible unless onsite officials can prove infeasibility by explaining and detailing the nature of the work and their attempts at compliance via conventional fall protection. Is it infeasible because it is tough to erect the required anchor point? The harnesses aren't on the jobsite and it would take an extra day to retrieve them? What legitimate factors can an employer use to argue to a compliance officer that conventional fall protection is not possible? The best way is the only way; the written fall protection plan.

Oregon's state OSHA program provides an outstanding sample fall protection plan for employers to use via their Web site (www.cbs.state.or.us/external/osha/standards/fallplan.htm). The sample Oregon plan clearly states that employers have the responsibility to be specific about why conventional fall protection can't be used. Would installing the conventional protection create a greater hazard? Would installing the protection take three times longer than the actual job? Would four employees be required to install the guardrail system while one employee could complete the actual job in approximately 5 minutes? Would installing the guardrails damage the roof of the building and anger the customer? Have non-traditional fall protection methods such as catch platforms or working out of aerial lifts been considered? These situations have all been presented to any experienced OSHA official and they are worthy of being considered. These options must be taken into account by the employer and, in an ideal scenario, an employee familiar with the fall protection standard. Rest assured the OSHA official will want to know you have considered these questions and have answered them, in writing, if you are following a fall protection plan.

When implementing a fall protection plan, it is useful to follow the written guidelines in the OSHA standard or to simply follow a plan such as Oregon OSHA's written plan. According to the OSHA standards (1926.502(k)), the written plan must be in writing, site specific, prepared by a qualified person, available at the jobsite and address why conventional means of fall protection could not be utilized. Appendix E to Subpart M contains a sample fall protection plan that can be used by employers but should be site specific.

OSHA officials will ask to see such written plans if it becomes evident that conventional fall protection is not being implemented to protect workers. If conventional means are not used for protection and no fall protection plan is used and available at the site, an employer has just provided good documentation for serious violations to be issued. If conventional fall protection is being provided, the OSHA official will inspect those systems for compliance with other appropriate parts of Subpart M. Subpart M also covers personal protective equipment and criteria for guardrail systems. These issues will be addressed by any OSHA official during the inspection and should be discussed thoroughly within a fall protection plan, if used.

The fall protection plan does not provide for the misuse of personal protective gear or redefining the criteria for guardrail systems. In South Carolina, I have observed deficient fall protection plans that included changing the heights of mid rails and top rails within a guardrail system. The written fall protection plan described in Subpart M does not afford an employer the opportunity to change the height requirements or minimums for a guardrail system, or the strength requirements for a personal fall arrest system and anchorage. The private sector safety professional should realize that the fall protection plan should follow the spirit of the fall protection standard as set forth in Subpart M of the standard.

The OSHA standard states that the written plan should be "prepared" by a qualified person. A qualified person is defined as someone who has a recognized degree or through extensive knowledge, experience and training demonstrated his/her ability in a subject matter. Any employee may be a qualified person if they meet the criteria stated in the definition of qualified person that is found in the scaffold standards under Subpart L. The employee may be a foreperson, management official, engineer or someone from outside the company. The only real consideration is that they truly be qualified to prepare the fall protection plan. Simply being a foreperson doesn't qualify an employee as a qualified person. I have met line employees who had much more knowledge of the fall protection standard than the foreperson on the jobsite. Rest assured that an OSHA inspector will expect the qualified person to demonstrate their knowledge of fall protection during any inspection.

Frequently Cited Hazards

So far I have discussed the option available when conventional fall protection is not used to protect employees. I also want to discuss the hazards that are most frequently cited within Subpart M and training issues with respect to fall protection. In order to illustrate some of these hazards, I have included several pictures of actual hazards I have observed.

For fiscal year 1999, falls from unprotected sides and edges was the seventh most cited serious violation. Unprotected sides and edges are those areas where no fall protection is afforded. Sides and edges where the fall protection is inadequate also is a problem observed on jobsites. Guardrails that are improperly installed or that sag can create additional hazards for employees such as a false sense of security. Roof areas also present various hazards and guardrails or controlled access areas should be clearly identified with flagging tape, so as to be visible.

However, keeping employees safe from fall hazards is not as simple as erecting a guardrail system and letting the employees work. There are instances where a permanent guardrail system may not afford much protection and personal protective equipment such as safety harnesses must be used. The criteria for personal fall arrest equipment are discussed in Subpart M of the construction standards and employers with employees exposed to fall hazards should be knowledgeable of the requirements and make appropriate selections.

Taking shortcuts with personal fall arrest systems and proper employee training on how to use those systems will, more than likely, lead to serious injuries. In 1996, OSHA cited a New York-based painting contractor for violations arising out of an accident where employees were securing their safety harnesses to an inadequate lifeline and anchor point that was not of a sufficient material and strength to protect employees. Tragically, this inspection by OSHA was not routine, but due to an accident that killed a worker. Knowing what type of fall protection to use and the proper use of that equipment is vital to providing a safe worksite.

In those instances where a guardrail system will provide adequate fall protection without the need for a personal fall arrest system, it is imperative that the guardrail system be installed correctly. As Photo A shows, sagging guardrails don't offer much protection for employees.

Installing only one guardrail poses problems also. In April 1999, OSHA lowered the boom on New Jersey construction company Avcon Inc for a lack of fall protection on a 16-story building under construction. OSHA received complaints and conducted an inspection that discovered one single guardrail installed 24 inches above the working surface on the highest working surface. A cursory reading of Subpart M reveals that a guardrail system which contains a top and mid rail is required for fall protection. Avcon received willful citations. There was no attempt to follow the requirements or even a fall protection plan. It was simple disregard for providing fall protection for its employees. Was it a lack of training? Who provides the necessary training for employees?

In my experience and in talking with OSHA officials within the South Carolina office, effective fall protection training is rarely observed in the field. Despite Subpart M's clear requirement for fall protection training, confusion seems to reign in the area of training employees concerning fall hazards. These problems exist despite the numerous training programs available from OSHA itself and the private sector. In South Carolina, for example, this program is called the Office of Voluntary Programs. Most state OSHA programs have similar departments to assist and train companies. Are these programs effective? Do employers take advantage of these programs? Anne Peterson, safety director of Stueken in Fountain Inn, S.C., stated: "By forming a proactive partnership with OSHA Voluntary Programs, we were able to understand compliance and make it practical for us. Our consultations with S.C. OVP enabled us to interpret and apply the standards in an efficient and practical manner."

Training programs such as OSHA offers are valuable tools for employers to embrace. Some companies may not be comfortable, for whatever reason, in directly working with an OSHA program. Those employers need to search out the many various private sector training programs that are available in all types of industry. Gravitec Systems (www.gravitec.com) and Miller Fall Protection (www.216.23.83.154/miller/millertrolltraining/trolltraining.html) are just two of the fall protection businesses that train employers on the requirements of fall protection, personal fall arrest guidelines and options, and even help develop fall protection plans. I personally used a Miller workbook when discussing fall protection requirements and options with employers in the field. However, employers, if they choose, should search out companies they will be comfortable working with to protect their employees. It is obvious that there is no excuse acceptable for not providing effective fall protection to workers when there are so many resources available.

Providing fall protection to employees along with utilizing the options available under a fall protection plan should provide a measure of relief to employers who have to expose their employees to possible falls. When conventional fall protection is not feasible or creates a greater hazard, there are provisions within Subpart M that allow an employer to utilize a fall protection plan. However, there is a specific criterion for the fall protection plan that must be followed and it should be available at the jobsite for inspection and as resource material for management and employees. Fall protection is not an option. The law is clear that employees must be provided with fall protection and the options I have discussed should be implemented to provide for a safe workplace.

Barry Loudermilk is a loss control consultant with Summit Consulting Inc., a provider of workers' compensation insurance and comprehensive loss control management.

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