Falls are the leading cause of preventable death and lost day injuries in the workplace. While most falls are from a higher to lower level, the majority of fatalities occur from heights of between 11 ft. and 20 ft., and most ladder fatalities occur from heights of 10 ft. or less.
Knowing these statistics, having a managed fall protection program not only helps satisfy relevant laws, but it is the right thing to do to protect yourself, your workforce, property owners and property managers.
Until 1970, all states had their own safety regulations. However, as result of protests for the improvement of worker safety, President Richard M. Nixon signed into law the OSH Act. The Act was the culmination of almost a century of endeavors by the states and the federal government to mitigate the vulnerabilities of employees exposed to the hazards of the Industrial Age. The Occupational Safety and Health Act (OSHA) was officially formed as an agency of the U. S. Department of Labor on April 28, 1972, the date that the OSH Act became effective. Shortly thereafter, thousands of its first consensus standards were published.
The Code of Federal Regulations (CFR) are the published federal laws of the United States. Of the 50 Titles contained within the CFR, Title 29 – Labor includes Part 1900 that deals with OSHA. Part 1910 – General Industry is a catch-all of Occupational Safety and Health Standards that cover all workers unless they are covered by a more specific regulation such as those for Shipyard, Marine Terminal, Long Shoring, Construction, and Agriculture work.
OSHA is charged with assuring safe and healthful conditions for working men and women by setting and enforcing standards, and providing training, outreach, and education and compliance assistance. In addition, the OSH Act’s general duty clause requires every employer to provide every employee with a place of employment free from recognized hazards. Among additional workers’ rights created by the OSH Act, employees are to be kept informed of workplace hazards, be allowed to report hazards to either the employer or OSHA without retaliation, and to receive training to minimize the exposure to known hazards.
To better protect workers from falls, OSHA issued a significant update and clarification to its Walking-Working Surface standards in 2017. This update was based on advances in technology, industry best practices, and national consensus standards from American Society of Safety Engineers (ASSE), American National Standards Institute (ANSI) and International Window Cleaning Association (IWCA).
The primary intent of the update was to provide more flexibility and options for fall protection so there would be no excuse for not using it. Additionally, fall hazard training of all workers exposed to a fall was mandated, and limitations were placed on fixed ladders over 24 ft. tall and use of Rope Decent Systems (RDS) over 300 ft.
Voluntary ANSI/ASSE Z359 Fall Protection Standards help to fill in the gaps within the OSHA regulations. Of the 17 standards, Z359.2 Minimum Requirements for a Comprehensive Managed Fall Protection Program is a good comprehensive aid to developing a Fall Protection Program.
ANSI/ASSE Z359.2 requires a policy and commitment set by top management to provide a safe work environment for all employees working at height in any situation. OSHA Regulations are minimum requirements, and it will not take long for a managed fall protection program to far exceed the safeguards provided by OSHA.
The roles outlined by the ANSI/ASSE standard include the following:
Prior to assigning workers (Authorized Person) to a particular assignment, a Hazard Survey should be conducted by the Foremen or Supervisor (Competent Person) to look for and address fall hazards among others. This survey should include 100% coverage including access and egress from the work area.
Triggers requiring fall protection include:
Maintaining equipment is generally considered to fall under 29 CFR Part 1910 General Industry. Replacement could be considered to fall under 29 CFR Part 1926 Construction. However, it is best to follow the stricter requirements when in doubt.
As you build out your managed fall protection plan, here are a few options from most to least effective for protecting employees from deadly and debilitating falls:
A managed fall protection program is continually updated and will soon far exceed the minimum fall protection requirements of OSHA. Not only does a fall protection program protect yourself, your workforce, property owners, and property managers, it is simply the right thing to do.
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