Elements of a Comprehensive Managed Fall Protection Program Patrick Furr

1. Elements of a Comprehensive Managed Fall Protection Program Patrick Furr

2. Introduction • OSHA and ANSI guidance to include • Policy Statements • Roles and Responsibilities • Fall Hazard Survey Report • Procedures • Equipment Selection • Investigations • Program evaluation

3. Introduction • Diligence • “Persistent and hard working effort” • “The care or attention expected by the law” • Synonyms: Conscientiousness, Thoroughness, Attentiveness

4. Introduction • An effective fall protection program recognizes Suspension Trauma as a hazard to the fallen worker using PFAS and includes a prompt rescue capability in the program

5. Introduction • OSHA Duty To Have Fall Protection • 29 CFR 1926 Subparts L Scaffolds and M Fall Protection • 29 CFR Subparts D Walking/Working Surfaces and F Powered Platforms, Manlifts, and Vehicle Mounted Work Platforms • ANSI Z359.2 Minimum Requirements for a Comprehensive Managed Fall Protection Program

6. OSHA • OSHA Fall Protection Regulations • Construction Industry: Employees working 6 feet or more above lower levels or above dangerous equipment shall be protected from falling • General Industry: Employees working 4 feet or more above lower levels or above dangerous equipment shall be protected from falling

7. ANSI • OSHA Fall Protection Regulations are the minimum requirements • ANSI is a valuable resourse that may assist the employer striving to exceed OSHA minimums • ANSI Z359.2 Minimum Requirements for a Comprehensive Managed Fall Protection Program is an excellent tool to use in this effort

8. Policy Statements • The Policy Statement sets the tone for the Managed Fall Protection Program • A general statement that emphasizes the employer's commitment to safety • Provides general goals, guidance, and expectations • Depending on the workforce, general guidance and expectations may be of a collaborative nature or may be stated in a directive tone

9. Duties and Responsibilities • Employers • Provide adequate and timely resources • Appoint a Program Administrator • Identify fall hazards and eliminate or control the hazards • Develop written fall protection and rescue procedures • Train and inform Authorized persons • Provide continuous fall protection to Authorized Persons • Appoint a Competent Person to supervise Authorized Persons

10. Duties and Responsibilities • Program Administrator • Develops, implements, monitors and evaluates the fall protection program • This role may fulfilled by a Qualified/Competent Person or other designee • Well versed in fall protection regulations as well as fall protection equipment and systems • Works with other departments – Purchasing, HR, Engineering, etc.- and employees regarding the fall protection program

11. Duties and Responsibilities • Program Administrator (Continued) • Establishes and assigns duties to subordinate personnel • Establishes procedures to identify, eliminate or control new or existing fall hazards • Develops fall protection and rescue procedures for locations where an active fall protection system is used • Consider workers isolated at height while protected by passive systems

12. Duties and Responsibilities • Program Administrator (Continued) • Provide training for subordinate personnel • Participate in incident investigations • Evaluate the effectiveness of the fall protection program

13. Duties and Responsibilities • Qualified Person • Well versed in fall protection regulations as well as fall protection equipment and systems • Knowledgeable of physical sciences and engineering principles • Calculates impact forces and clearance requirements • Supervises the design, selection, installation and inspection of certified anchorages and horizontal lifelines • Meets the qualifications of a Competent Person

14. Duties and Responsibilities • Competent Person (typically the “key” to a successful/comprehensive program) • Well versed in fall protection regulations as well as fall protection equipment and systems • Provides immediate supervision, implementation, and monitoring of the fall protection program • Conducts a Fall Hazard Survey Report • Identifies, evaluates, and imposes limits on work activities to control fall hazard and swing falls • Has authority to stop work immediately • Prepares and updates written fall protection procedures

15. Duties and Responsibilities • Competent Person (continued) • Prepares written rescue plans or ensures they are prepared by designated rescue assets ensuring prompt rescue of fallen authorized persons • Specifies in writing fall protection procedures, systems, non-certified anchorage locations and/or general guidence, connecting means, body support, and other fall protection equipment that Authorized Persons may be required to use • Verifies that fall protection systems are installed and inspected in compliance with applicable regulations and IAW any manufacturer instructions • Establishes clearance requirements for any fall protection system and provides solutions for any unique situation that may require additional provisions

16. Duties and Responsibilities • Competent Person (continued) • Participates in the investigation of fall from height incidents • Performs periodic inspections on fall protection equipment as required by the manufacturer and applicable regulations • Immediately removes from service any fall protection equipment that fails a pre-use or periodic inspection, or that has been damaged or subjected to the forces of arresting a fall

17. Duties and Responsibilities • Role of the Competent Person “According to Pat” • Very knowledgeable of the OSHA fall protection regulations • Identifies and understands all the areas where work is performed at height and provides solutions adhering to the hierarchy of fall protection (thorough and honest Fall Hazard Survey Report) • Has a finger on the pulse of traditional and emerging technologies for fall protection equipment. Provides solutions to the Authorized Persons that are comfortable, convenient, and may be safer than what is currently being used • Understands the capabilities and limitations of rescue systems

18. Duties and Responsibilities • Authorized Person • Understands and follows the employer’s policies and procedures and the instructions of the Competent Person regarding the use of fall protection and rescue systems • Brings unsafe or hazardous conditions to the attention of the Competent Person • Shall perform a pre-use inspection of fall protection systems and equipment

19. Training Program • The employer shall provide a training program for each employee who might be exposed to fall hazards • The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards • The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: • The nature of fall hazards in the work area • The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used • The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used • The role of each employee in the safety monitoring system when this system is used

20. Training Program • The employer shall provide a written certification of training • The written certification record shall contain the name or of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer. • If the employer relies on training conducted by another employer or completed prior to the effective date of this section, the certification record shall indicate the date the employer determined the prior training was adequate rather than the date of actual training.

21. Training Program • Retraining When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required, the employer shall retrain each such employee. • Circumstances where retraining is required include, but are not limited to, situations where: • Changes in the workplace render previous training obsolete • Changes in the types of fall protection systems or equipment to be used render previous training obsolete • Inadequacies in an affected employee's knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill

22. Fall Hazard Survey Report • Per ANSI Z359.2 • Conducted by a Competent or Qualified Person • IDs fall hazards by type • IDs one or more methods to eliminate or control the fall hazard • Establishes risk factors such as, but not limited to: • Frequency, duration, occurrence of the task • Severity of the fall • Obstructions in the fall path • Other hazards • History of accidents/incidents related to the task or structure

23. Fall Hazard Survey Report • Any environmental conditions that may effect the performance of the active fall protection systems must be identified • Hot objects, sparks, or flame • Abrasive surfaces • Chemicals that may degrade or damage the fall protection equipment (wire rope vs. nylon lanyards) • UV radiation • Energized electrical equipment • Moving equipment, or unguarded gears and drive shafts • Unstable or uneven work surfaces • Materials or conditions that may adversely affect the performance of the fall protection system (example: the use of a self retracting lifeline while working on loose grain or other similar substances)

24. Fall Hazard Survey Report • The completed Fall Hazard Survey Report should become part of the comprehensive fall protection program • The program administrator should indicate frequency of, and any other triggers for review/updates • Periodic review/update (annually/bi-annually) • Changes in the configuration of the facility • Changes to the work process • Changes to legislation or BKP • Evolving fall protection equipment technologies

25. Equipment Selection and Inspection • Fall protection equipment and systems should always be selected using the “Hierarchy of Fall Protection” as the guide • Example: Consider using fall restraint systems before considering fall arrest systems • The types of equipment fall into several general categories • Connectors: Snap hooks and carabiners • Body Support: Body belts and full body harnesses • Lanyards • Anchor Connectors • Specialized Equipment • Vertical and horizontal lifelines • Rope grabs • Rescue Systems

26. Equipment Selection and Inspection • Modern materials, manufacturing processes, and equipment designs have allowed an explosion in emerging fall protection equipment and systems • The comfort, versatility, and convenience of modern fall protection equipment has virtually eliminated any feasibility issues or reasons for Authorized Persons to balk at using appropriate protective measures • An important role of the Competent Person is to stay abreast of the evolving technologies that are commercially available • A quick visit to the major manufacturer’s online catalogs can be a valuable exercise in seeking solutions to those tough nuts to crack

27. Equipment Selection and Inspection • Some examples of modern equipment and systems that may provide solutions • Temporary portable non-penetrating anchors • Temporary horizontal lifelines • Harness mounted SRLs

28. Equipment Selection and Inspection • Some examples of modern equipment and systems that may provide solutions • Modern anchor connectors • Wrap back type lanyards

29. Incident Investigations • All fall related incidents shall be reported to the Program Administrator and the Competent Person and investigated promptly • All contributing factors should be considered including but not limited to: • Policies • Procedures • Training • The Fall Hazard Survey • Equipment/Systems (any equipment or system that is suspected or proven to be deficient will be suspended from further use until deemed safe)

30. Incident Investigations • Any equipment subjected to the impact forces of a fall shall be removed from service and inspected by a Competent Person • A team approach for incident investigations should be considered and focus on any one root cause should be avoided. Incidents often are the results of multiple causitive factors • The incident investigation shall be retained on file for a time mandated by any legislated requirement

31. Program Evaluation • Continuous evaluation of the fall protection program is essential in monitoring the effectiveness of the program and to identify areas that may present opportunities for increased safety • Some but not all areas to be reviewed: • Written Policies • Current and appropriate training of personnel • Fall Hazard Survey Reports • Current equipment and system selection and inventory • Anchorage guidance • Equipment inspections • Interviews of Authorized persons and crew members • Incident investigation if applicable • Rescue Procedures

32. Summary • Roles and Responsibilities • Program Administrator • Competent/Qualified Person (MVP) • Authorized Person • Training • Fall Hazard Survey • Equipment Selection • Investigations • Program Evaluation

33. Summary Questions? Pat Furr, Chief Instructor Roco Rescue, Inc.