How to Create an ANSI Z359.2-Compliant Fall-Protection Plan

April 1, 2008
Any company with personnel who work at heights must have a fall protection plan to be in compliance with the new ANSI Z359.2 standard

Any company with personnel who work at heights must have a fall protection plan to be in compliance with the new ANSI Z359.2 standard. The recently approved ANSI Z359.2 standard, “Minimum Requirements for a Comprehensive Managed Fall Protection Program,” requires a written fall protection program whenever one or more person(s) are routinely exposed to fall hazards and need to be protected with a fall protection system.

A well-written and implemented plan not only reduces worker risk and saves lives, it stands as evidence that an employer is making every effort to comply with regulations. It can help prevent the economic consequences of an incident, including fines, liability and increased insurance costs.

Capital Safety has developed a seven-step fall protection plan development guide to assist companies in creating a comprehensive plan. The steps are as follows:

  1. Develop a policy and define the scope of the program.

  2. Identify fall hazards through a well-developed hazard analysis of work area.

  3. Determine appropriate methods of protection, including:

    • Eliminate fall hazards;
    • Prevent fall hazards; and
    • Controlling the fall.
  4. Conduct education and training to ensure effective employee understanding of fall hazards and precautions.

  5. Perform inspection and maintenance of fall arrest equipment.

  6. Administer and audit the program for compliance and continuous improvement.

  7. Develop a specific fall protection work plan for each work site or work project.

Duties and Responsibilities

Before proceeding with further discussion on what the fall protection plan should consist of, it would be wise to discuss who should be responsible for putting the plan together and implementing it. ANSI Z359.2 defines the roles and responsibilities of a program administrator, qualified person, competent person and authorized person.

The program administrator is responsible for all phases of the fall protection plan, including its development, implementation and ongoing monitoring. Additionally, the administrator must have a working knowledge of fall protection regulations, standards, equipment and systems. He or she must provide guidance to all those affected by the fall protection plan including employees and departments such as purchasing, assign all duties and responsibilities, provide training programs, participate in accident investigations and evaluate the effectiveness of the plan. The person who serves as the program administrator may also be the qualified or competent person.

The qualified and competent persons must have knowledge of fall protection regulations, standards, equipment and systems being used at the work place. The qualified person's main responsibilities include supervising the design, selection, installation and inspection of certified anchorages and horizontal lifelines and participating in accident investigations and being a subject matter specialist to the competent person and program administrator.

The competent person is the day-to-day supervisor, ensuring that all personnel required to work at heights are trained, and will implement the proper fall protection procedures. He or she conducts the fall hazard survey and identifies new and existing fall hazards as work progresses and how to protect employees exposed to each hazard.

The competent person also may supervise the selection, installation, use and inspection of non-certified anchorages in jurisdictions where this is permitted and verify that current systems are in compliance with applicable standards. He or she also ensures a rescue plan is in place for a fallen worker, participates in accident investigations, inspects equipment and removes from service damaged or otherwise unusable equipment.

The authorized person is the worker who utilizes fall protection equipment on a regular basis to complete his or her assigned duties. The authorized person should follow the procedures as laid out in the fall protection plan, bring any potential fall hazards to the attention of the competent person and properly inspect, use, maintain and store the equipment he or she has been assigned.

Developing the Plan

A key step in creating a fall protection program requires conducting a hazard analysis or fall hazard survey report, as spelled out in ANSI Z359.2. Each fall hazard at a work site must be analyzed individually and account for the type of hazard, a sketch of the configuration, how much exposure workers have to the hazard, height of a potential fall, suggested control method and the type of rescue equipment to be used, should it become necessary.

Each hazard should be prioritized in terms of highest exposure to lowest exposure. In ranking fall hazards, risk factors that should be considered include reason for exposure, severity of the potential fall, frequency and duration of exposure, obstructions in the fall path, existing fall protection systems, environmental factors and history of accidents at the site. Fall protection must be provided for all hazards, but more resources should be devoted to the most dangerous hazards.

Included in the hazard assessment is an environmental assessment to determine what conditions exist at the site of the hazard that may prevent the proper functioning of a fall protection system. Items to look for include open flames, sparks or hot objects, hazardous chemicals, electrical hazards, environmental contaminants, sharp objects and/or abrasive surfaces, moving objects or equipment, unguarded openings, climatic factors and unstable, uneven or slippery surfaces.

The plan should be modified whenever an existing fall hazard changes or a new hazard arises. Only the competent or qualified person should revise the plan. A copy of the plan must be kept at each site where an active fall protection system is used.

After the hazard survey has been completed, the next steps are to follow the fall protection hierarchy to provide a solution for each fall hazard. The best solution for any fall hazard is to engineer out the hazard wherever possible. This is not always feasible, but another preferred solution would be to change procedures so that workers are not exposed to the fall hazard.

If it is not possible to engineer out the hazard or to prevent employees from being exposed to the hazard, the next step is to install passive fall protection systems, if possible. This includes guardrails, handrails and covers for floor openings. Where this is not possible, a fall restraint system should be implemented. A fall restraint system prevents a worker's center of gravity from reaching the fall hazard. A fall restraint system does not double as a fall arrest system, so extra care should be taken to ensure that the connective device is not long enough to allow a fall.

A fall arrest system should be implemented if none of the above methods will control the fall hazard. A fall arrest system is designed to stop a fall in progress. Finally, administrative controls such as warning signs should be the last resort.

Selecting Fall-Arrest Systems

Appropriate fall arrest equipment will vary by site and work function, but always will consist of an anchorage, body support, connector and rescue plan. Anchorages should be installed under the guidance of the competent person. Anchorages may be temporary or permanent and vary widely depending on location. There are anchorages specific to steel beams, commercial roofing, residential roofing, concrete and leading edge work, scaffolding, ladder/pole climbing, bucket trucks/aerial lifts and many more applications.

In selecting an appropriate harness, items to consider include:

  • The type of work to be performed. Look for harnesses designed with the needs of specific industries in mind such as utilities and oil and gas.

  • How long the worker will be wearing the harness. Look for harnesses with extra padding for added comfort.

  • How often the worker will be wearing the harness and the materials the harness will be exposed to. Extra durable materials will be the key to harness lifespan.

Finally, when selecting a connector, considerations include:

  • The amount of mobility the worker requires. If the worker requires more than 6 feet of mobility, look for a self-retracting lifeline. For less than 6 feet, look for a lanyard or shock-absorbing lanyard.

  • How frequently the worker will need to disconnect and reconnect to another anchorage. Look for twin-leg lanyards and self-retracting lifelines that allow for 100 percent tie-off.

  • Type of work being performed. If the worker will be welding or working near sparks, look for connectors made with Kevlar.

For every fall hazard that is controlled, a rescue plan must be in place. This will address the procedure and equipment to be used to rescue a fallen worker, and must be specific to each hazard identified in the fall hazard survey report.

It is the employer's responsibility to provide comprehensive training programs for all employees exposed to fall hazards, inform all authorized persons of any foreseeable fall hazards prior to exposure and provide authorized persons with fall protection equipment.

To sum everything up, a comprehensive fall protection plan must be developed to include:

  • Statement of policy

  • Results of the fall hazard survey report, including all identified fall hazards, control method for each hazard and rescue method if an active fall arrest system is to be used.

  • Delegation of ongoing responsibilities in the areas of inspection, recordkeeping, maintenance, equipment replacement, incident reporting, enforcement, accident investigation, training and changes to the plan.

Look for Fall Protection Products from ISEA Members

Protection Update readers are encouraged to specify fall protection from the following ISEA members:

  • Aearo Technologies (AO Safety-SafeWaze)
  • Buckingham Manufacturing Co.
  • Bullard
  • Capital Safety (Can-Sling, DBI/SALA, Protecta, Sinco SALA)
  • Draeger Safety
  • Jackson Safety
  • Klein Tools Inc.
  • Magid Glove & Safety Mfg. Col
  • Mine Safety Appliances Co.
  • North Safety Products
  • Scott Health & Safety
  • Sellstrom/RTC
  • Sperian Protection (Miller Fall Protection and Söll Fall Arrest)


Nate Damro is vice president of marketing for Red Wing, Minn.-based Capital Safety, home to the DBI-SALA and Protecta brands of fall protection. The ISEA member company makes confined space equipment, debris nets, emergency descent devices, engineered systems, harnesses, horizontal lifelines, ladder safety devices, energy-absorbing and retractable lanyards, lifelines, rope grabs, saddles, bosun's seats, and work-positioning products. Reach Damro at 651-385-6225 or [email protected].

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