Prevention Through Design standard puts safety first

When LJB first got into the fall protection business almost 20 years ago, we focused our efforts—and even our business name—around the concept of Safety by Design.  Specifically, we challenged organizations to incorporate safety early in the design of new structures and processes. 

We are excited to see that the American National Standards Institute has validated our efforts—and those of many other safety organizations—with the implementation of a Prevention Through Design (PtD) standard.  This week, the ANSI /ASSE Z590.3 standard became effective, essentially guiding organizations through the process of applying PtD concepts to minimize occupational risks.

We have seen our Safety by Design concept deliver impressive results for clients like Chevron, the Architect of the Capitol and General Motors.  I am confident that this Prevention through Design standard will make a significant impact on reducing risk for workers.

To learn more about how to apply this concept to your organization, LJB project manager, Craig Galecka P.E., C.S.P., will be co-presenting on Prevention Through Design at the ASSE 2012 conference in Denver on June 5.

Airbags for fall protection?

One of our colleagues was recently asked about the idea of using airbags for fall protection.  The question was framed with the idea that if stunt people use them in the movies, maybe they could be a solution for other professions.

The idea of using airbags for fall protection has not been directly addressed by OSHA regulations or ANSI standards.  While I can’t speak for their reasons not to address this concept, I have my own opinion of why this may not be a feasible solution for fall protection.  First, these personal airbags are designed for the person falling in a controlled manner.  Commonly, the person falling has some acrobatic or gymnastic training and a significant amount of practice in falling the “correct” way.  Unfortunately, workplace falls are typically not planned and there is rarely sufficient time to orient your body in the proper manner.  Falling onto an airbag in the wrong orientation (i.e., head first) could cause significant injury. 

I have recently contacted a manufacturer of these devices to find out about their use and limitations and how they could be arranged for a sample fall protection scenario.  While this technology may advance in the coming years, I think there are currently too many limitations to apply it to occupational fall protection.

GIVE YOUR OPINION ON THE NEXT LJB FALL PROTECTION WEBINAR

Earlier this year, we opened a poll to allow readers to vote on the next LJB fall protection webinar.  We had great response and hosted two webinars based on your feedback:  Addressing Unexpected Fall Protection Needs and Fall Protection Rescue Plans.

Now you have a chance to provide your opinion again.  Please vote for the topic that you would most like to see as an upcoming LJB fall protection webinar. 

RECALL ON SELF-RECTRACTING LANYARDS

LJB would like to thank Michael Schwartzmiller (aka “Rocket” due to his pitching abilities) of GE Aviation for passing along this important fall protection product recall.  3M recently completed an analysis of GW-7 and GW-11 Series Self-Retracting Lanyards for quality purposes. The company identified a limited number of these units that do not properly achieve lock up during the user pre-inspection pull test on the webbing lifeline (as required by the User Instructions and OSHA regulations).

As a result, 3M requests that you immediately remove from service and quarantine all models of G-Series Self-Retracting Lanyards within your inventory. G-Series model numbers are provided below for reference.

We commend 3M for its commitment to providing quality products and services. Contact Ray Mann, 3M Fall Protection Technical Service, at 704-743-2406 for product return information.

3M™ G-Series Retractable Lanyard Models:
GW-7, GW-11, GW-7-0241A, GW-7-0241H, GW-11-0241A, GW-11-0241H, GW-11NS, DLGW-7, DLGW-7-0241A and DLGW-11-0241A

FALL PROTECTION ANCHORAGES

Fall protection anchorages are a hotly debated topic, and one that I am personally passionate about.  A poll question from a recent webinar on fall protection system certification has sparked some healthy debate on anchorages once again.

The question:   True or false – By law, all anchorages must be designed by a qualified person.

The answer I gave during the webinar was false—that anchorages do not have to be designed by a qualified person.  That answer was not technically correct, and I appreciate our attendees for listening so closely and pointing out how the nuance of wording is incredibly importance in this instance. 

According to OSHA, anchorages must be designed under the supervision of a qualified person OR support 5,000 pounds.  My point with the poll question was that OSHA requires that a qualified person design anchorages, but also technically says that anyone can designate what anchorages can support 5,000 pounds. 

There is truly an important distinction between design and designate. Essentially, anyone can designate what serves as a fall protection anchorage, despite the specific and critical engineering and safety variables that must be accounted for.  Even though the law technically allows others (non-qualified persons) to designate an anchorage, please be extremely cautious using this practice.  Appropriate anchorages are critical to proper function of fall protection solutions—this function definitely shouldn’t be left in untrained hands.

Risk Assessment: Win-win for safety

As we have all experienced, just because you prioritize one thing, doesn’t mean everything else goes away.  Safety professionals are all juggling different priorities in an effort to reduce risk and create a safer environment for workers.  Because LJB is solely focused on fall protection, we don’t always remember that fall protection isn’t always top of mind.

But, we are glad to hear when a client tells us that the work we do to improve fall protection makes a positive impact on their ability to do their jobs.

Luke Mazur, from Marathon Petroleum Company Detroit Refinery recently said this:  “LJB’s risk assessment provided us with a tool that made it easy for us to prioritize work associated with fall protection, while managing all the other work going on around us.”

We’re glad to help make workers safer from falls, but it’s even better when what we provide also improves the ability to deliver overall safety for workers.  I can’t think of a better win-win.

Weekly death toll provides motivation

We can look at fall protection statistics and realize that we still don’t have a handle on properly protecting workers at heights.  But, when you see the faces and read the stories of those who have lost their lives due to falls, the problem really hits home. 

The United Support and Memorial for Workplace Fatalities (USMWF) organization publishes a weekly toll of all those who have lost their lives while working.  The organization’s message—“Going to work shouldn’t be a grave mistake”—resonates with me and our firm’s commitment to protect workers at heights.  Although all fatalities are recorded—not just falls—there seems to be at least one fall fatality every week.

If you ever lose motivation to give your best in your role of improving workplace safety, take a look at the weekly toll.  When you personalize the losses, it’s easy to see how important our jobs are—not just to our employees, but to their families as well.

Fall Protection Answers May Be Closer Than You Think

Some attendees at our recent webinar on unexpected fall protection needs were looking for suggestions on engaging individual workers to contribute to the creation of a safe and compliant work environment.  In my opinion, the best way to do that is to engage them in developing safety solutions.  I once heard it called the 20-foot principle:  those that work within 20 feet of the hazard are likely to have ideas on how to solve it.  You may still need to work through some details to create a compliant, functional solution.  But, by seeking input, you can make sure that you aren’t forcing workers to use a system that is not conducive to the tasks they need to perform.

Think about this too: one way to get workers to use equipment in a safer manner is to make them use it less.  It seems that the more they use it, the more desensitized they may become to proper usage.  It’s best to develop solutions that minimize the need for PPE at all.

What Is The Safe Distance to an Unprotected Roof Edge?

Safe distance to an unprotected roof edge is a common area of misunderstanding when discussing fall protection.  To put it plainly—there isn’t a safe distance.  In principal, I agree with those who say that as you increase the distance to an unprotected edge, you decrease the probability of a fall.  However, it’s important to remember that this is not supported by OSHA 29 CFR 1910 or 1926 (see note below). 

The proposed OSHA 1910 regulation specifically addresses this issue: “This proposed standard does not specify a distance from the edge that is considered safe, (i.e., a distance at which fall protection is not required.) Instead, it allows the employer to designate an area in which employees can work without fall protection.” 

I believe the misconception of a specific safe distance has surfaced since warning line rules require setbacks from the edge at 6, 10, or 15 feet depending on the circumstances.   Also, OSHA compliance officers often do not cite a circumstance unless the worker is reasonably close to an unprotected edge. As you can imagine, this can be very subjective as to the distance that is too close to the edge.  Especially considering the clarity provided in the proposed OSHA standards, it is critical to provide fall protection anytime workers are near any unprotected edge.

Most people know that these warning lines are not required to have the same strength as guardrail.  However, some people don’t realize that OSHA still considers it a physical barrier, albeit one that will only warn you when you are too close to the edge.  And, since some of you may be thinking about this, OSHA does not recognize painting a line on the roof as sufficient fall protection.

Note: 29 CFR 1926 does allow for a safety monitor system for specific tasks although there are additional requirements beyond just using a safe distance to an unprotected edge.  Actually, you can have no distance to the unprotected edge and still use the monitor system.  If you have ever talked with me about this, you know that I am not in favor of using monitor systems.  Contact me if you want to discuss.

Addressing Unexpected Fall Protection Needs

During our recent webinar, Addressing Unexpected Fall Protection Needs, we had some great questions from the audience.  We have listed the questions and answers here for others to learn from.

Q1:  Can you discuss the use of anchorages and lanyards in aerial lifts?

A1:  This is a common question, and we see people improperly to attached to aerial lifts very often.  There are two common issues with anchorages in aerial lifts: location and configuration.  The location is important since you want the anchorage to be located to prevent the worker from climbing out or being catapulted out of the lift. The configuration of the anchorage is important since you need to make sure that anchorage is compatible with the connector on the end of the lanyard you are using. You can also learn more about this from a previous blog post.

Q2:  Are procedures available for how/when to use a crane as an anchorage?

A2:  Currently, there are no procedures available through OSHA or ANSI to use a crane as an anchorage for an active fall protection system.  This question can break down into two general types of cranes: overhead cranes within industrial facilities and mobile cranes on construction/industrial sites.  For the latter, there is a reference in 29 CFR 1926 that discusses the use of a crane to support a suspended man basket.  This section contains some specific requirements that can give you things to consider if this is something you need to do at your job site.  Additionally, the ANSI Z359.6 standard committee is considering incorporating general procedures for both types of cranes into the standard.  I foresee attachment location and details, pre-lift procedures, lockout-tagout requirements and capacity requirements being part of this section of the standard. 

Of course, what you need to consider before using a crane as an anchorage is that if something happens to the hook, you are going down with it.