Bob is working 15 feet above ground, changing a filter on a machine with no guardrails. Because his supervisor wants to follow OSHA fall protection regulations, Bob is wearing a full-body harness and a lifeline. To cut costs, the supervisor bought them from two different companies, and had a company subcontractor install the anchorage.
The supervisor insists that Bob regularly check his equipment, but today Bob is wearing an old lifeline that has been hanging in the back of the equipment closet for over a year. The last time it was used was when another employee slipped and fell a few feet while wearing it. Because of the angle and height of the machinery Bob is working on, the anchorage is positioned on a beam behind him and to his right, near a wall. As Bob hunches over the machine, part of his work boot hangs off the ledge. While Bob’s supervisor probably thinks he’s protected his employee, the wall, the questionable state of the lifeline and anchorage and Bob’s wobbly footing all argue otherwise.
According to the Bureau of Labor Statistics, falls remain the No. 1 killer in the construction industry and the No. 2 killer in private industry. Many of those deaths occurred even though the supervisor thought he was doing the best he could to protect his employees.
Until now, employers have been left to solve their fall hazards with requirements scattered throughout OSHA and ANSI. However, a new standard, ANSI/ASSE Z359-2007 Fall Arrest Code, addresses the elements of a Managed Fall Protection Program and provides the guidelines to design or strengthen your program.
Initially introduced as Z359.1 – Managed Fall Protection Program (MFPP) – Z359-2007 received final ANSI approval on May 31, and encompasses five standards within the code:
- Z359.0-2007 – Definitions and Nomenclature Used for Fall Protection and Fall Arrest;
- Z359.1-2007 – Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components;
- Z359.2-2007 – Minimum Requirements for a Comprehensive Managed Fall Protection Program;
- Z359.3-2007 – Safety Requirements for Positioning and Travel Restraint Systems; and
- Z359.4-2007 – Safety Requirements for Assisted-Rescue and Self-Rescue Systems, Subsystems and Components.
These standards are fall protection-specific, and were developed, discussed and fine tuned by a committee that included engineers, end users, military personnel, representatives from OSHA and ANSI, trainers, fall protection equipment manufacturers, fall protection specialists, rescue experts and academics. Comprehensive in nature, specific in direction, Z359-2007 will give you the confidence to address existing hazards, prevent future hazards and contribute to sustainable safety in your workplace.
Understanding ANSI/ASSE Z359-2007
It is important to recognize there are notable differences between this code and previous ANSI/ASSE fall protection standards, both in general and specific terms.
Information in the new standard is provided in specific versus vague language to generate a greater understanding by the employer, employees, owners, consultants and vendors of their fall protection roles and responsibilities. All persons involved in the managed fall protection effort must understand and take responsibility for their roles.
A managed fall protection team was developed to emphasize the employer; add the program administrator, competent rescuer, authorized rescuer, qualified person trainer, competent rescue trainer and train-the-trainer; expand the roles of the competent person and qualified person; and re-name the at-risk worker to the “authorized person.”(See the managed fall protection team chart.)
Employers must be aware of the work-at-height activities (design, supervision, rescue, maintenance, construction, equipment) they require employees to perform and recognize their responsibility to verify if the employee’s current competencies (knowledge and skillsets) match. For example, with the new code, the employer now is aware that when an authorized person if required to work-at-height, training must be provided to give the employee the knowledge and skill sets required to safely perform his or her work. In addition, the code allows the authorized person to fully understand his role and responsibilities in his own fall protection, including: preplanning, fall protection equipment, anchorages, clear height, swing fall, rescue, buddy system and working with the competent person.
The new standard instructs employers not to send workers at height who are not competently trained and for employees not to work-at-heights without proper training. By clarifying the activities, training and guidelines for work-at-height, it will build safer attitudes and behaviors.
The committee worked in conjunction with the guidelines of ANSI Z490.1 - Criteria for Accepted Practices in Safes, Health, and Environmental Training to develop cohesive, stronger training instructions. The information provided by ANSI Z490.1 will assist companies in recognizing the gaps in existing training programs and the need to invest in safety programs that include multiple delivery formats: e-learning, discussion, demonstration, retention activities, practice and testing, versus a sole reliance on one type of instruction to design the knowledge structure. These training standards highlight the need to incorporate adult learning principles into safety training courses.
Building and Work Design
No discussion of fall prevention and protection would be complete without mentioning the design factors that contribute to fall hazards. We are learning how significant the process of safety is to the design of buildings and machines. Z359 -2007 acknowledges two critical issues of fall protection: One, most hazards can be engineered out (prevented) and two, we continue to purchase designs and products which contain hazards (“buying” hazards).
These new standards provide the basis for companies to resolve these issues through the practice of requiring the design community, machine manufacturers and others to provide services and products which do not introduce hazards into the workplace. Employing safety design thinking will achieve better results in worker safety.
Z359–2007 is a comprehensive standard that provides criteria for a program versus an emphasis on one specific element of the managed fall protection process. The overall focus of the standards is not just about fall protection, but is geared toward planning the worker’s safety during design, construction, maintenance, demolition and use activities.
ANSI/ASSE Z359.0-2007 establishes the student’s fall protection foundation using terminology found throughout Z359-2007. This creates an understanding of the issues involved and also provides a structure for companies whose employees posses various levels of knowledge. Also, since new, expanded and updated definitions are part of this code’s terminology, it is a critical standard to understanding how to design and implement the managed fall protection program.
This standard introduces new managed fall protection program team members such as the program administrator and competent rescuer to complete needed roles and responsibilities and provide missing expertise. Expanded definitions for the competent person and qualified person were developed to establish the credentials needed to perform these roles. And updated terms such as the authorized person (formerly known as the at-risk worker) were established to acknowledge the specialized training required to perform the work-at-height required activities required by the employer.
Your fall protection committee can begin or update your fall protection program by selecting a program administrator and identifying the necessary training courses to refresh or initiate the fall protection team. While the committee analyzes the training needs of its team, a list of fall protection safety criteria – included in specifications for the purchase of design, construction, maintenance, training, fall protection equipment and machines – can be developed. The committee also can identify signage and materials for in-house posting, training and visitor safety orientation. Keep a list of questions and follow-up and implementation activities to add to the training your in-house team will receive.
ANSI/ASSE Z359.1-2007 establishes requirements for connectors, full-body harnesses, lanyards, energy absorbers, anchorage connectors, fall arresters, vertical lifelines and self-retracting lanyards used in personal fall arrest systems. The program administrator should work with the employer and fall protection team: fall protection committee, qualified person, competent person, authorized person, competent rescuer and authorized rescuer to identify equipment (fall protection and rescue) and training needs to be purchased or removed.
ANSI/ASSE Z359.2-2007 provides a solid framework for the employer to develop a comprehensive and proactive managed fall protection program. The fall protection hierarchy provides the methodology for companies to use to prevent fall hazards from entering their facilities and also to eliminate or control existing hazards. This standard recognizes the role of design in buildings, machines and equipment. By providing design requirements for fall protection systems in new facilities, this standard addresses the most asked question: “Why do engineers and architects design hazards into facilities and machines?”
Fall protection training has a history of offering programs with undefined content in a variety of lengths from 30 minutes to 40 hours. We believe the workplace statistics associated with fall related injury and fatality point to the inconsistency of training curriculum. Z359.2-2007 notifies the employer to provide training that teaches the fall protection team member how to safely and confidently perform his or her role and responsibilities, whether it is in the design, supervision, preplanning or performance of work-at-height activities. It also identifies fall protection and fall rescue policies, procedures, hazard surveys, equipment, anchorage and rope access requirements.
Implementing this standard requires your fall protection committee to review the in-house policies and procedures and identify the missing elements and determine what needs to be revised. Whether you are performing a job safety analysis, selecting abatement options, choosing a designer, selecting training or preplanning a project, the parameters of this standard will guide your team to safer decisions.
ANSI/ASSE Z359.3-2007 outlines the safety requirements for the lanyards and harnesses that are a part of the personal positioning and travel restraint systems used by authorized persons. This standard addresses such problems as improper use, fit and compatibility as well as anchorage, clearance and swing fall factors that have a significant impact on the user and the reliability of the fall protection and rescue equipment.
ANSI/ASSE Z359.4-2007 examines one of the most overlooked elements of a fall protection program – rescue – and establishes requirements to preplan rescue. It also identifies the criteria for connectors, harnesses, lanyards, anchorage connectors, winches/hoists, descent control devices, rope tackle blocks and self-retracting lanyards for self and assisted rescue.
This standard highlights why 9-1-1 should not be thought of as a primary rescue option and also defines the meaning of second rescue. This standard will help your team deal with critical issues such as prompt rescue time, orthostatic intolerance/suspension trauma and how to select competent trauma care centers.
Pulling it All Together
ANSI/ASSE Z359-2007 identifies missing elements to the fall protection program and fills in the blanks of insufficient practices and procedures. In providing new, updated and expanded definitions, this standard recognizes the need for all members of the fall protection team to understand, accept and implement their roles and responsibilities safely and accurately. Team members – from the employer to the authorized person – can understand what is involved in performing their roles and responsibilities for work-at-height activities. The standard identifies the knowledge and skill sets they must possess and how it correlates to the type of training they have completed or will receive.
In addition, ANSI/ASSE Z359-2007 calls attention to the need for the employer and/or owner to require the design community – engineers, architects, interior designers and contractors – to provide designs for facilities and machines that address safety from start to finish. The design community must expand its definition of safety beyond industry’s traditional sense to design for safety in construction, maintenance, use and demolition activities.
However, it will be the role of general industry to specify these safety requirements in design criteria, bid documents and construction means and methods and enforce their use. The concept of preventing workplace hazards is becoming more widely accepted and the means to achieve prevention more readily available. This standard is an excellent tool to guide your company to preventing workplace hazards.
Keeping it in the Family
ANSI Z359.0-2007 Fall Arrest Code is a family of fall protection and arrest standards with viable criteria for companies to use in developing sustainable safety programs. The decision to implement a new method or program often is more difficult than actually carrying out the program.
Following through with Z359-2007 initially can be daunting. When faced with a list of several hundred workplace hazards, it is easy to become overwhelmed and to fall back on luck and older, more comfortable safety methods. Changing workplace habits, attitudes and behaviors will be a challenge, as is redesigning work practices and areas. This initial investment of time and mental energy, however, will pave the way for a safer, more effective work culture.
The standards contained in the Fall Arrest Code will generate proven and repeatable problem-solving protocol businesses can use to achieve life-saving results. Members of our team have been involved with this standard since its conception. Since 1999, we have realized its potential to impact the design and training programs of general industry in creating safer work environments.
Elements that were missing from fall protection guidelines now are included, companies that experienced difficulty in establishing and maintaining a complete program now have definitions, tools, procedures and policies to implement. It is a standard that can fortify the safety relationship among the end user, owner, consultant and equipment manufacturer; promote safety as a competitive edge in a global market place; and begin to eliminate workplace hazards so employees can focus on doing their jobs and experience the benefits of working safe.
In this millennium, workers’ health and safety cannot be ignored. An effective safety program no longer is just a moral issue; it is a deciding factor in surviving economic conditions and a contributing element to a positive financial statement. The company with fewer worker turnovers, injuries, citations and downtime will be the company with the competitive edge.
Moniqua Suits is director of training for Safety Through Enginerring Inc. She is a nationally recognized author, presenter and trainer.