Elements of a Comprehensive Managed Fall Protection Program

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Elements of a Comprehensive Managed Fall
Protection Program Patrick Furr
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Introduction

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

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Introduction

• Diligence
• Persistent and hard working effort
• The care or attention expected by the law
• Synonyms Conscientiousness, Thoroughness,
  Attentiveness

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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

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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

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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

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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

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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

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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

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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

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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

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Duties and Responsibilities

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

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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

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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

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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

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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

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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

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Duties and Responsibilities

• Authorized Person
• Understands and follows the employers 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

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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

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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.

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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

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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

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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)

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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

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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

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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 manufacturers online
  catalogs can be a valuable exercise in seeking
  solutions to those tough nuts to crack

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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

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Equipment Selection and Inspection

• Some examples of modern equipment and systems
  that may provide solutions
• Modern anchor connectors
• Wrap back type lanyards

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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)

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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

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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

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Summary

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

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Summary

• Questions?

Pat Furr, Chief Instructor Roco Rescue, Inc.