LJB Fall Protection Blog

During our recent webinars on the proposed changes to OSHA’s 29 CFR 1910 regulations, we engaged in meaningful dialogue with other safety professionals on the potential impacts of these changes.  Many different issues were discussed, and we will continue to comment on relevant topics through the blog.  Following is a quick list of the results of the poll questions posed during the webinars.  I have found some of these results very interesting, and I’m interested in your thoughts about these items. 

1.  Have you read the entire OSHA proposed document?

Yes = 4%
Just the regulatory text = 3%
Portions of it = 17%
Not yet = 31%
No, that’s why I’m attending this webinar = 45%

2.  Do you plan to submit comments to OSHA?

Yes = 9%
No = 33%
Not sure yet = 58%

3.  Word association:  What is the first word you think of when I say fall protection?

Harness, lanyard or other PPE = 75%
Serious injury or fatality = 14%
Expensive = 3%
Confusing = 1%
Other = 7%

4.  Are you familiar with the ANSI Z359 family of standards?

Yes = 47%
No = 23%
Somewhat = 30%

5.  Have you read the ANSI Z359.2 standard?

Yes = 20%
No = 33%
Parts of it = 47%

6.  Have you read any of the ANSI Z359 standards that were published at the end of 2009?

Yes = 17%
No = 59%
Some of them = 24%

7.  Which of the following areas would you like to learn more about?

Anchorages = 29%
Fall hazard surveys = 44%
Training = 20%
Other = 7%

Anyone that knows me, knows that I am passionate about fall protection.  I have special concern over fall protection anchorages, since they are the last link to a successful active fall protection system, and often, there is no redundancy.   

It troubles me that when OSHA mentions identifying a 5,000 pound anchorage, they do not state who needs to identify the anchorage.  As a professional engineer, I am prohibited by law from designing a certified anchorage without proving that the existing structure is adequate. While I can use previous work on a structure as reference, I need to perform the required calculations. 

Why do OSHA and ANSI allow someone who is not a professional engineer to do something that a professional engineer trained in the analysis of structures cannot do?

In May, OSHA released proposed changes to the 29 CFR 1910 general industry regulation, which would revise the existing walking-working surfaces and personal protective equipment standards.  The proposed rules more directly recognize that personal fall protection systems can provide an effective means of employee protection.  The proposal also adds new specific performance and use requirements for PPE. 

I am thrilled to see these potential changes, which are long overdue to accurately reflect the state of today’s fall protection industry.  However, OSHA’s stated goal with the proposed regulations is to prevent 20 workplace fatalities per year.  When you look at the data on fall fatalities, this represents less than 10% of the total per year.

I would like to see this number increased significantly, based on the content of the proposed regulations.  I believe that enforcing compliance with the updated standards can have a much larger impact on worker safety.  OSHA needs to explain in more detail why this standard addresses such a small percentage of total fatalities.

To read the entire OSHA proposed regulation, please click this link to the file on the OSHA website.  (Please note: this is a large file and may take a few moments to open.)

OSHA regulations say that: “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.”

While I certainly believe that employers have a responsibility to provide for prompt rescue, I have a hard time with the second half of that statement.  How can you completely assure self rescue?

In a fall arrest situation, it is not unlikely that the fallen worker will undergo some kind of medical problem—either causing the fall or due to something that happens during the fall.  Even if a worker would be able to rescue themselves under ideal conditions, I don’t think you can rely on ideal conditions after a fall.  We have even worked with one client whose original written rescue plan (before we started working with them) was for fallen workers to reach their mobile phones and call for help.  As someone working at heights, would you want to rely on having the ability and wherewithal to locate, reach and accurately call for help after experiencing a fall?  I wouldn’t. Next time you see me, ask to see my phone and all of its scratches.  I drop it all the time while simply walking around on the ground.

As you are planning for fall protection rescue, I encourage you to consider rescue to involve a minimum of two people – the fallen worker and at least one another who can properly execute a safe and effective rescue plan.

Imagine that your job requires you to work at heights, and your employer recently installed new, effective fall protection systems to protect you from a fall.  You have received thorough general and system-specific training and written use procedures are in place for the systems.  It’s a great day.  Shortly after the system is put into use, you personally go through a fall in the system. 

“Whew!”  The system functioned properly and arrested your fall.  You feel relieved and thankful for the new fall protection systems.

But, now what?  Now that your fall is arrested, do you and the workers around you know what to do to perform a rescue?  According to OSHA, if a fallen worker’s feet are not on the ground within 30 minutes, you risk serious injury or even a fatality.

In all my work with fall protection, I have observed that rescue is one of the most overlooked aspects of the subject.  Many companies rely on employee self rescue, or assume that their local emergency services, such as the fire department, will be able to handle any rescue situation.  These are risky assumptions to make.

In addition to OSHA guidance on the 30-minute threshold, the ANSI Z359.2 standard provides rescue requirements, which state that specific training, equipment and personnel should be prepared for rescue and that a written rescue plan should be prepared for each situation.  It also states that the plan should be prepared to contact the fallen victim within 6 minutes.

Your fall arrest systems may be in place to save a fallen worker, but are your rescue plans also up to the task?

In the last post, I asserted that in many examples related to fall protection PPE, less is more.  But, when managing a fall protection program, there are also times when more is less.  

In our personal lives, we can look at the example of buying a new home as a time when more is less.  More up-front assessment of needs and evaluation of choices equals less heartburn and headaches from making a bad decision on a critical purchase.

The same concept applies when evaluating your fall hazards and their respective abatement options.  Sometimes the choice is obvious, but sometimes it is not, especially considering the cost of hazard abatement. What to do?

Just like the variables of cost, location, size, and style that are considered when purchasing a home, evaluating fall protection abatement options requires the same discipline.  You must still consider budget, as well as variables like productivity, ease of use, life-cycle costs, and sometimes even aesthetics. 

In life, some purchases are simple to make—like a gallon of milk or a movie ticket. But, there are decisions where it pays to do more analysis to make sure you make the right decision the first time.

More is less when you spend more time making sure you have the right solution. More evaluation that results in greater productivity for employees and more savings associated with the recurring costs of training, inspection and maintenance. More effort in the initial stages reduces risk for workers at heights. More planning is lower cost.

The paradox “less is more” is often associated with items in our personal lives, like a best man’s toast at a wedding or details about your in-laws’ vacation.  But, can this phrase also hold true when it comes to fall protection equipment?

To illustrate, let me share an example from a client.  You are working on an assembly line where a robot swings a part into position.  If a motor on that robot breaks, you must get up ten feet into the air to fix it.  For this task, you have two options – first, a platform with guardrail and ladder access. Or, second, a portable ladder while using a harness and a lanyard. 

As you work, you hear the whine of the motor and the crack of the gears failing.  The assembly line shuts down, at a cost of $30,000 a minute.  For your first option with the platform, you scurry up the ladder, replace the motor, carefully go down the ladder and restart the assembly line. With your second option involving the harness and lanyard, you go to the storage cabinet and remove your harness and lanyard.  Because safety is the first priority at your company, you perform a thorough pre-use inspect of the equipment.  Then, you slide over to the storage rack and get your ladder.  Next, you find a co-worker to watch over you in case you fall.  You finally go up the ladder, tie off to the appropriate anchorage, replace the motor, go down the ladder and restart the assembly line. 

It is clear that the first example would take less time.  Although PPE is a common solution for fall protection, in this case, it increased the downtime and decreased the productivity of workers – costly valuable time and money.  The only benefit of using a harness and lanyard was that the work could be done safely.  So, if safety can be achieved and likely improved in other ways, such as engineering controls, you will see benefit in a variety of ways.