Keeping Pace with Fall Protection
We all know that initial safety training is a crucial element of our programs that aim to keep our employees protected from harm at work. For any and all hazards (or potential hazards} to which we expose our workers, we must ensure they understand the nature of the hazards and how to protect themselves.
Initial safety training and proper safety equipment, combined with good old-fashioned experience, goes a long way in ensuring a safe work environment. But, at times, we must provide re-training for our employees – and there are many reasons for this.
For example, if our employees demonstrate a lack of knowledge or acceptable performance in regards to any particular hazard, we must provide re-training. If the process or equipment changes, we must provide re-training. If new safety equipment (includes systems as well) is brought into the program, we must re-train our employees on its proper use. And, finally, if there are changes to safety legislation or best-known practices, we need to re-train.
It seems that every week a new piece of fall protection equipment is brought to market – and for the most part, these emerging technologies make work-at-height safer than ever before. Additionally, these newer fall protection items tend to be lighter, more comfortable, easier to operate, and can even perform multiple safety functions. This is all great news, but not every item/system is right for the varied situations encountered at our workplaces. But when we do introduce a new piece of fall protection equipment to our workforce, it nearly universally calls for some degree of re-training. The manufacturer’s instructions for use may be a great starting point to satisfy this training, but it is always a good idea to provide some degree of formal training on the equipment, and then document that training.
The extent of this re-training is dependent on the complexity of the new equipment and the authorized person’s general knowledge base. Sometimes the user manual does not cover all the points that the re-training should convey. For example, harness-mounted self-retracting lifelines are becoming more and more prevalent in the work-at-height environment. In addition to the standard training for pre-use and periodic inspections, proper mounting, operating capabilities and limitations, at least one other point of training seems to be required. The worker cannot walk too quickly away from their anchorage lest they engage the arresting mechanism which abruptly stops the worker in their tracks. This may at times create a new hazard by jerking the worker off balance or causing them to drop objects they may have been carrying. I have even heard some tales of individuals suffering minor injuries due to the sudden stop. So, even though you may not find this point of training in the user’s manual, it comes with experience and should be included in the re-training for this type of new equipment.
Another reason to provide re-training for fall protection has to do with an observed deficiency in an authorized person’s knowledge or performance regarding fall protection. Now this can become a little tricky to find the root cause of the deficiency. Is it truly a lack of knowledge on the authorized person’s part, or is it a disregard for required procedures? Sometimes it's a mix of both. No matter the primary cause of the deficiency, if that authorized person is to remain on that job, it is incumbent on the employer to provide proper re-training. And I will say it again, document that re-training!
We have recently had a significant legislative change to the general industry standard for fall protection. On Nov. 18, 2016, OSHA 1910 Subpart D “Walking-Working Surfaces” was published and became effective on Jan 18, 2017. The major changes to this final rule have to do with physical changes to existing and future structures regarding the phase-in of ladder safety systems, eliminating the outdated general industry requirements for scaffolds and adopting the construction industry’s scaffold standards' guidance on the use of rope descent systems and qualified climbers, as well as some other changes. But the most significant changes that will drive training and re-training requirements is the added flexibility of using personal fall protection systems for authorized persons. These personal fall protection systems include fall restraint, work positioning, and personal fall arrest systems (PFAS). OSHA has eliminated the mandate to use guardrail systems as the primary fall protection method and now allows the general industry employer to determine the fall protection method that they feel is best suited for the nature of the work at height. And this now includes personal fall protection which was not addressed prior.
For general industry employers, who prior to the new Subpart D did not allow their employees to use personal fall protection systems other than in accordance with 1910.66, the option to do so now will be deemed compliant. And, of course, this will require initial training and re-training for the use of personal fall protection equipment and systems. Additionally, employers that introduce the authorized use of work positioning and personal fall arrest systems to their workplace will also have to provide training on rescue of these workers if they are relying on an in-house rescue capability.
In the years I have been involved with safety and rescue training, one subtlety that I observe is this:
Oftentimes an employer or their employees do not realize they have a training deficiency until after they've gone through the training.
This is certainly true when it comes to rescue training. At the conclusion of nearly every rescue class I teach, at least one of the students says they never realized what all was involved in rescue and what the limitations of certain rescue systems were. And this is consistent with my interviews and reviews of rescue programs when I am asked to perform needs assessments at various facilities. Unless you have a background in technical rescue, it is very difficult to visualize the systems, skills, and equipment required to safely access and rescue a fallen/suspended victim.
Both OSHA and ANSI require employers to provide "prompt rescue" of employees they authorize to work at height while using personal fall arrest systems. OSHA has published a Safety and Health Information Bulletin recognizing suspension trauma as a workplace hazard affecting workers that use personal fall arrest systems. Many employers address rescue of fallen/suspended workers in their fall protection programs, but stop at merely developing written policies that may fall well short of the requirements needed at the time of an incident. This falls back to my earlier point that an employer that has a limited background and understanding of the complexities of performing rope rescue, especially if it requires technical skills beyond the simplest rescue, may not understand what the true requirements are for their facility. Sort of like that general saying last year that “We don’t know what we don’t know.” So, training for rescue is a subcategory of fall protection training that does not have as much easily accessed guidance and resources to rely on as a guide.
Quality training will include several of the points that I have detailed so far. The training will be pretty specific to the job with very little time spent on irrelevant material. The training will be of the type that best transfers the information in either a vocational or academic manner. The training will close the gaps that have been identified and arm the employer and the students with a better understanding of what is truly required to perform the job, which is especially true for rescue. But finally, the training should be delivered in such a manner that it captures the students’ interest. The best outcome of training, the classes where the student finishes with the highest level of retention, understanding and performance, are the classes that compel the students to engage in the learning.
I think it is a safe assumption to say that we have all sat through classes wondering when and hoping for the class to end. Looking at our watch is one thing, but when we are tapping it to see if it is even still working is a really bad sign. I am not suggesting that educators have to provide entertainment, but there is a demonstrated positive difference in classes delivered by an engaging trainer as compared to a very dull, monotonous trainer.
In addition to seeking an engaging trainer, it is important for the trainee to take some ownership in the learning process as well. This is where the adult learner has an advantage over younger learners. We as adults generally understand that the training will result in a better understanding of the job requirements and in many cases is a factor in career progression.
I encourage you to seek out the training that your employees need. Or, as an employee yourself, seek out quality, applicable training. Review the course syllabi and determine if it will close those knowledge and skills gaps that you have identified. Always back up those fancy sales brochures by reaching out to others to get their opinion on their experiences with the training in the past. Also, remember to consider re-training as needed and always document. These things are important for the overall quality and credibility of your safety training programs.
Article by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.