This week, May 2-6, is OSHA’s National Safety Stand-Down to Prevent Falls in Construction. The reason for this emphasis is the continuing injuries and deaths resulting from workplace falls – especially in construction work. Fall protection was the #1 cited standard by Federal OSHA in 2021, and falls continue to make OSHA’s “Fatal Four” list year after year.

The statistics don’t lie. In 2019, there were 1,102 fatal injuries in the construction industry; according to the US Bureau of Labor Statistics, nearly 38 percent of these fatalities were fall-related. In 2020, employers spent over 16.5 billion dollars combined indirect costs as a result of falls according to Liberty Mutual’s Workplace Safety Index for the construction industry.

In doing our part for National Safety Stand-Down to Prevent Falls, we’ve created a list of Top 5 safety tips to consider before starting work.

1) Implement the Hierarchy of Fall Controls

The most effective method to protect workers against falls is to eliminate the hazards! All too often we see employers and workers simply accepting a hazard without fully attempting to eliminate it first. Admittedly, elimination is not always possible or feasible. In this case, we should make every attempt to use passive fall protection — such as physical barriers, guardrails, or hole covers to prevent falls.  Even this may not always be a practical application in the real world. If we are unable to implement these two methods of control, then (and only then) should it be acceptable to move on to personal protective equipment (PPE) and active measures of control.

2) Develop Effective Training

If there are remaining hazards in the workplace, you must provide workers with the knowledge and skills to be aware of the hazard and their potential effects. Workers should be able to identify when they are at risk for falls and take appropriate and effective measures to protect themselves. Be sure to incorporate hands-on skills into your training with knowledge and competency assessments before allowing workers to work at height. There is no replacement for direct, hands-on learning for this type of skill set. Some examples of this may include appropriate set-up of ladders, harness inspection, maintaining 100% tie-off, and lifeline anchor selection.

3) Provide Proper Personal Protective Equipment (PPE)

As mentioned previously, elimination and passive fall protection should always be our primary and secondary goals for reducing fall-related incidents. When we are unable to implement these methods, we must then rely on PPE to protect workers from the remaining hazard. Ensure that your workers ready have access to adequate PPE for the job; remember, PPE is not a “one size fits all” application. Consider providing different styles of PPE so that workers can choose what is most comfortable or convenient for them.  Workers are a lot more likely to use PPE that they like and are comfortable using.  Also, ensure that workers know how to inspect their PPE and how to wear, use, maintain, and store it appropriately. 

4) Select Appropriate Anchor Points

Fall protection equipment is only as good as the anchor point that it’s tied off to. The ideal anchor point will be located directly above the worker. The further away a worker is from the anchor, the greater potential a worker has to swing into objects during a fall. Additionally, anchor points must be able to withstand at least a 5,000 lb. load per worker. On occasion, workers can be found tying off to electrical conduit, small diameter pipes, or other unacceptable anchor points. Ensure that your workers know and understand how to select appropriate anchor points. As a best practice, consider discussing what anchor points will be used for the job prior to starting work.

5) Accurately Calculate Fall Distances

What good is fall protection if you hit the lower level before it engages? Accurately calculating fall distances can be the difference between life and serious injury or death. The formula used for calculating this is as follows:

Required Distance = Lanyard Length + Deceleration Distance + Height of Worker + Safety Factor

Lanyard Length is exactly that, the length of the lanyard being used. Most lanyards are around 6-ft. in length; be sure to reference the manufacturer’s specifications to determine the exact length of the lanyard.

Deceleration Distance refers to the distance from when the worker falls, to when the fall arrest device activates, and to the final stopping point. Most shock-absorbing lanyards deploy to about 3.5-ft. in length when engaged. Remember that any slack between the anchor point and the worker’s dorsal ring must be added to this distance. For instance, if a worker has a 6-ft. lanyard and connects it 3-ft. above their dorsal ring, that will create an additional 3-ft. fall before the system activates. Additionally, a full-body harness will likely stretch an additional foot during a fall – be sure to include these additional distances in your calculations.

Height of Worker is also self-explanatory, the height of the average worker is about 6-ft.

Safety Factor is an additional amount of space added into the calculation to serve as a buffer. The generally accepted safety factor is 3-ft.

 

Chris McGlynn is the Director of Safety/VPP Coordinator for Roco Rescue. He is a Certified Safety Professional (CSP) through the Board of Certified Safety Professionals as well as a Certified Confined Space and Rope Rescue Technician, and a Nationally Registered Paramedic. As Director of Safety, Chris oversees all corporate safety initiatives, ensuring that employees at Roco have the tools and training that they need to do their work safely and effectively. He is also responsible for managing Roco's Safety Services Division, which provides trained safety professionals for turnarounds and other special projects. Finally, Chris serves as the VPP Coordinator for Roco, continuing Roco’s long-standing commitment to excellence in safety and health. Roco has been an OSHA VPP Star Worksite since 2013.

Follow Chris 

 

Additional Resources

• Fall Hazard Survey (pictured here) 
• Hierarchy of Fall Protection Poster 
• Personal Fall Arrest Systems (PFAS)

 

 

 

We’ve all heard it before, “falls are one of the leading causes of death in the industry.” In fact, falls have been the leading cause of death in the construction industry, year after year, for over a decade now. Additionally, Fall Protection (29 CFR 1926.501) and other related standards continue to land on OSHA’s “Top 10 Most Frequently Cited Standards” list each year.

According to NIOSH, 401 of the 1,102 construction fatalities recorded in 2019 were due to falls. To raise awareness of this hazard, OSHA now conducts a “National Fall Protection Safety Stand-down” to prevent falls in construction and has done so each year since 2014. The 2022 Stand-Down is May 2-6, but OSHA encourages holding your own stand-down any time, year-round.

With all of the emphasis on fatal falls, why are workers continuing to fall to their deaths? More importantly, what can we do to prevent them? Well, I’m glad you asked!

There are many actions that employers can take to prevent fatal falls from occurring in the industry; however, the adage “an ounce of prevention is worth a pound of cure” definitely comes to mind here. The most effective measure that any company can take to prevent fatal falls is to implement proper planning before work begins. An effective fall protection plan is multi-faceted and contains multiple steps, all of which should be given great attention to detail.

What should a fall protection plan include?

1) General Information About the Jobsite

As with any plan, an effective fall protection plan should begin with general information about the task at hand. What type of jobsite or facility is this? Is the job taking place at a residential home, a new construction project, or an industrial manufacturing facility? What type of work is being done? Consider electrical work, roofing, hot work, confined space work, or other tasks that may be a contributing factor in falls. Are there any existing fall protection measures in place? In many cases, permanent ladders and guardrails are in place throughout the jobsite; however, on new construction, there may not be any existing fall protection measures. Are there any work surfaces that could affect the job? Take note of areas that may be slippery, areas that could be abrasive, uneven or unlevel areas or areas with trip hazards. Will the weather impact the safety of the job? Consider how rain, wind, or ice accumulation could impact the jobsite. What is the estimated duration of the job? Long-term jobs may require different solutions from short-term jobs. In some instances, scaffold erection may not be an effective use of time and mobile aerial lifts may be more feasible.

2) Assessment of All Fall Hazards on Site

Once the general information of the jobsite has been documented, a thorough assessment of all fall hazards on the jobsite should be conducted and documented. OSHA has different fall protection requirements for General Industry and Construction. While there are a nearly unlimited number of ways that fall hazards can present on a jobsite, the following are a few examples of the more common situations to look for:

• Open-sided walking/working surfaces
• Open-sided ramps, runways, and platforms
• Floor openings
• Wall openings
• Elevator Shafts
• Stairwells
• Trenches

Do not skimp out on this step of your plan. After all, if you do not identify a fall hazard, you will not be able to protect against it! Consider including workers of all levels in the hazard assessment; every worker has a different perspective and may identify things that are missed by others.

3) Outline of Fall Protection Measures to be Used

Now it’s time to decide how you are going to protect workers from the hazards identified. The hierarch of fall protection is a 5-tiered approach, and the preferred method to eliminate or reduce the risk of falls. The 5 tiers are as follows:

1. 

   Hazard Elimination (best practice)
   The most effective measure of protecting workers from a fall hazard is to eliminate it all together. If possible, relocate the work to ground level or eliminate the exposed edge or opening.
2. Passive Fall Protection
   In many cases, elimination of the hazard is not possible or feasible. The next best measure to implement is to provide passive fall protection which includes things like guardrails or hole covers. Passive fall protection provides a lower possibility of error as it does not rely on the use of personal protective equipment (PPE). 
3. Active Fall Restraint
   In some cases, passive fall protection is not warranted as the duration of exposure may not offset the cost of implementing passive protection or the task being performed may not allow for passive fall protection. Active fall restraint is a type of PPE that limits a worker’s range of movement so that they cannot physically travel to the area of the fall hazard. This method is preferred over fall arrest as it significantly reduces the likelihood of secondary injury due to falls and the need to perform a suspended worker rescue. However, there are many cases where a worker must enter the area of the hazard to perform work.  
4. Active Fall Arrest
   An important note with active fall arrest systems is that they do not prevent a worker from falling but rather prevent the worker from contacting lower levels after the fall has occurred. One important, and often overlooked, element of this is having an effective rescue plan. Be sure to have a plan in place in the event that someone does fall. You must also ensure that workers are trained and understand how to properly use their equipment as well as its limitations. More on that later.
5. Establishing Controlled Access Zones (least effective)
   As a last resort, controlled access zones may be established to limit essential personnel into the area of the fall hazard. These methods generally include safety monitoring systems, warning lines or horns, or control lines. It is important to note that these controls are the least effective as they do not provide any physical means of protection. It is strongly recommended that all efforts have been exhausted to use the previous methods in the hierarchy before settling on controlled access zones.

4) Outline of Use, Maintenance, and Inspection Procedures for Equipment Being Used

Now that the methods of fall protection and prevention for the jobsite have been established, an outline of use, maintenance, and inspection procedures for the equipment used should be documented. Be sure to include proper assembly and disassembly procedures for equipment according to the manufacturer's recommendations. Ensure that a process exists for a competent person to inspect equipment at least annually or as required by manufacturer’s recommendations as well as a process for inspection of safety equipment by the end-user before each use. Any defective equipment must be tagged and removed from service immediately.

5) Outline of the Handling, Storage, and Securing of Tools and Materials on the Jobsite

This section of the fall protection plan goes hand-in-hand with the previous section. Establish a clear outline of how the equipment will be handled and stored on the jobsite. If equipment is not stored properly, it may become contaminated or damaged and render unsafe for use. Storage and handling of equipment vary from jobsite to jobsite but remember to protect equipment against heat, moisture, and chemicals when storing your equipment.

6) Outline of Overhead Protection to be Used

While not directly related to preventing workers themselves from fall hazards, it is important to address how workers in the area of overhead work will be protected. The use of toeboards, debris nets, or other side guards can be effective in preventing tools and material from falling below. Lanyards used to tether tools to the worker are also a great way to avoid dropped objects. Ensure that workers are notified of overhead work in the area with signs and barricades when possible. Consider postponing overhead work in unfavorable weather conditions and secure loose objects whenever possible.

7) Detailed Rescue Plan

Perhaps the most often overlooked item of a fall protection plan is the rescue plan. Many workers in the construction industry know that they must tie-off when working at heights; however, few take the time to think about what happens if/when they fall. Take the time to discuss and document the plan of action to be taken when someone falls. Suspension trauma is a life-threatening condition that can develop when a worker is hanging from their fall arrest system and can be lethal in as little as five minutes. Consider the use of a specialized rescue team for complex scenarios or be sure that you have the proper equipment, training, and proficiency to perform the rescue if needed. Remember, with fall protection – your life is literally on the line!

8) Employee Training and Instructions

Without adequate training, even the most effective plan is worthless. Remember that jobsites are dynamic and that fall hazards that were not present yesterday may be present today. For this reason, ensure that workers are trained to identify fall hazards and how to take measures to reduce or eliminate the hazard. Be sure that workers know when, where, how, and what fall protection equipment is to be used for the task or hazard in question. Also, ensure that workers know how to properly inspect their equipment before use and what to do with equipment that does not pass inspection. Most importantly, ensure that workers are trained on the fall protection plan, have easy access to it, and know how to access it for reference at any time.   

Summary

Despite the increased emphasis placed on falls, they continue to be the number one killer in the construction industry. Unfortunately, the one thing that doesn’t seem to fall is the number of fatalities resulting from it. While there are many actions that employers can take to reduce the likelihood of a fall occurring, the most effective measure is to have an adequate fall protection plan in place. Establish the details of the job, identify the fall hazards, and develop a method to eliminate or reduce the risk associated with the hazard. Establish a guide for proper use, maintenance, inspection, and storage of fall protection equipment and ensure that workers have the training they need to do the job safely. Last but not least, ensure that you have an adequate rescue plan in the event that a fall does occur. Remember, with fall protection – your life is on the line!

 

Chris McGlynn is the Director of Safety/VPP Coordinator for Roco Rescue. He is a Certified Safety Professional (CSP) through the Board of Certified Safety Professionals as well as a Certified Confined Space and Rope Rescue Technician, and a Nationally Registered Paramedic. As Director of Safety, Chris oversees all corporate safety initiatives, ensuring that employees at Roco have the tools and training that they need to do their work safely and effectively. He is also responsible for managing Roco's Safety Services Division, which provides trained safety professionals for turnarounds and other special projects. Finally, Chris serves as the VPP Coordinator for Roco, continuing Roco’s long-standing commitment to excellence in safety and health. Roco has been an OSHA VPP Star Worksite since 2013.

Follow Chris 

 

Additional Resources

• Fall Hazard Survey (pictured here) 
• Hierarchy of Fall Protection Poster 
• Personal Fall Arrest Systems (PFAS)

 

 

Pat Furr (Roco Rescue): Good morning Andy and thanks so much for joining us today.

Andy Speidel (MSA): Oh, it’s my pleasure Pat. Thanks for inviting me.

PF: We’re going to talk about all things Fall Protection. We’ll cover the latest advances in equipment and talk about how they’ve impacted how we work at height. We’ll also touch on some recent and upcoming regulatory changes, get your take on ways readers might be able to improve their fall protection programs, and discuss how to work effectively with a safety equipment rep.

AS: Sounds great, Pat.

The Latest Innovations in Fall Protection Equipment

PF: MSA is a leader in the design and manufacture of fall protection equipment and systems, so tell us about the latest advances in equipment that may just make the end user’s job easier and safer all at once.

AS: The last several years have seen significant advances in the use of modern design and manufacturing techniques as well as the use of lighter and stronger materials such as aircraft aluminum and synthetic fibers. This has allowed manufacturers to innovate and come up with products that are lightweight, easy to employ, multi-functional, and most importantly, these products are appealing to the authorized person, which ultimately encourages them to use it.

Our design team has put a lot of emphasis on making our harnesses more intuitive to don. The new lightweight materials we use make it possible to not only meet all the standards, but also to provide superior comfort, flexibility and adjustability - which ultimately allows the user to more easily don the harness.

PF: Of all the latest and greatest pieces of kit, which ones jump out as the most exciting for you?

AS: We’ve taken a huge step forward with our personal fall limiters (PFLs) through the use of Kevlar and Dyneema rope, which gives them the strength and abrasion resistance to be used in leading edge applications, while at the same time making them much lighter than earlier generations that used wire rope. Additionally, the interface allows the PFL to be used on a variety of harnesses. It’s a simple aluminum pin that slides through a web loop on the harness to make the connection.    

PF:  One of the scariest scenes I encounter when doing site visits are these Frankenstein, cobbled together horizontal lifelines. Some of them would struggle to hold up the laundry, let alone arrest a fallen worker.

AS: Horizontal lifelines must be designed, inspected and installed under the supervision of a qualified person, which I am willing to bet, some of the ones you’ve seen were not. We at MSA, as well as a few other manufacturers, are producing user-installable, pre-engineered temporary horizontal lifeline systems. These systems are typically constructed of wire or synthetic rope. They come in a variety of lengths and are very easy to deploy and recover. We have a unique system where two workers on the same horizontal lifeline can easily bypass each other without having to disconnect. This allows increased mobility and decreases worker interference while still maintaining 100% fall protection.

PF: I would imagine these systems include comprehensive user instructions that mandate the anchor strength requirements and detail clearance requirements?

AS: That is correct. The instructions outline the parameters for use and include calculations for clearance requirements based on the span of the line between anchors, the number of workers on the system, and the type of lanyard they’re using to connect. Our systems have either a turnbuckle or a pulley tensioning system, making it very easy to adjust the sag for the proper tightness of the line.

Equipment Advances Provide New Options For Re-Thinking Work-At-Height With The Hierarchy of Fall Protection In Mind

PF: One of the things that I see with the better fall protection equipment manufacturers is that they truly make an effort to educate the competent and qualified persons as well as the program administrators on their options for not only providing a safe and compliant solution for their employees, but also on appealing to the authorized persons. I think the big three for end users are lightweight, ease of use, and multifunctional. When you make a site visit or a presentation, it must be gratifying to see the light bulbs go on as your attendees hear the options available to them.

AS: It is and although my job entails selling equipment, I don’t approach my visits with ‘making a sale’ as my primary objective. I want to hear from the potential customer what their needs are and what their big concerns are.

PF: Are there any common themes in those discussions?

AS: Many people assume a fall arrest system is the only solution, when really we ought to take a step back and approach the problem using the hierarchy of fall protection. It’s not always possible, but quite often there’s a solution on a lower step of the hierarchy that restrains a worker from falling, or that brings some of the work to the ground – which is usually the safest solution.

PF: That reminds me of an exercise I often do when I’m presenting on fall protection or giving a talk at a conference. I ask everyone in the audience to close their eyes and visualize whatever comes to mind as I state two words: fall protection. Then I ask them what they were visualizing.

AS: Let me guess… they say harness and fall arrest lanyard.

PF: Yep, those are the most common answers.

AS: That’s why it’s important for us to listen to the customer, assess their situation, and discuss solutions that work best for their application and provide the least amount of risk to the worker. For example, we have a lot of customers who need to regularly access a flat roof on an older structure with no perimeter guardrails or parapets. When I tell them about retrofitting guardrails such as our VersiRail system, they worry about the costs. When we discuss other options such as active restraint or even fall arrest systems and the time it takes to set up and the limited mobility they often provide, they start to see the advantages of a passive fall protection system which doesn’t require authorized person training or specialized equipment. And compared to the average cost for one fatal incident, let alone the tragedy of such an occurrence, suddenly the cost for a perimeter guardrail system sounds affordable.

However, for those who still can’t justify the cost, we do have non-penetrating temporary anchors that work great on flat roofs for both active restraint and fall arrest anchors. Our Constant Force Post is one such example.

Ways To Improve Your Fall Protection Program

PF: What do you see as a less obvious deficiency in fall protection programs beyond the more common shortfalls such as general lack of compliance?

AS: One area that’s often overlooked is the need to read and understand the instructions for use for equipment and systems. This information is essential to ensure correct and safe usage. Not all SRLs are designed for leading edge applications. Not all personal fall limiters can be mounted at foot level. Even something as simple as proper fit of a full body harness varies from harness to harness. That’s why I encourage employers and fall protection program owners to work with a manufacturer who can help them standardize their equipment and provide follow-up support and training.

PF: That’s definitely a concern. Do you have any others that you would like to address?

AS: Greater focus on authorized person pre-use inspections. Unfortunately, OSHA only requires an annual periodic inspection be performed by a competent person for most fall protection equipment. Some systems such as horizontal lifelines need to be inspected by a qualified person. MSA recommends periodic inspection by a competent person on most pieces of equipment at 6-month intervals and depending on environmental conditions and type of wear and tear the equipment is exposed to, it can be even more frequent. We count on the authorized persons doing a thorough pre-use inspection, but often these are not being done as they should.

PF: Oh I agree 100%. I’ve seen some downright scary equipment that had no business being used on the job. My suggestion for program administrators: have your authorized persons perform the pre-use inspection on their coworker’s kit and vice versa. Nobody likes to get called out for having failed to do their job, so trading harnesses so that I inspect yours while you inspect mine creates an incentive to make sure yours is in serviceable condition.

 

 

Retrieval Self-Retracting Lifelines: A Primer

PF: I'd like to hear your thoughts on a piece of equipment that many end users are either unaware of, or don’t fully understand its capabilities. I'm talking about a retrieval self-retracting lifeline (RSRL).

AS: RSRLs are great in specific applications. Sometimes we are confronted with multiple hazards as defined by OSHA and ANSI. For instance, we may have a significantly high vertical entry into a permit required confined space. This involves at least two different OSHA regulations and requires certain protections as mandated by those different regs. We need to protect the entrant from the fall hazard and have a means of retrieving the entrant in the event of an emergency. In the case of the confined space regulation, if the vertical entry is greater than 5’, then the retrieval system must be a mechanical means of retrieval that is of sufficient hauling ability to lift the entrant up and out of the space. RSRLs satisfy both needs by providing fall arrest and retrieval capability.

PF: What types of anchors or anchor systems do you recommend for RSRLs in order to support a vertical confined space entrant? 

AS: A tripod is a good choice, but for situations where there’s limited space, or some other obstruction that prevents the use of a tripod, the MSA Xtirpa system is a great way to mount either the RSRL or a straight winch system. It’s easy to set up and extremely lightweight. It’s compatible with a large assortment of mounting systems such as the manhole collar shown below, ballasted cantilever mounts, floor bolted mounts and many other options.

 

Regulatory Changes: OSHA’s Walking and Working Surfaces

PF: Let’s talk about the changes to the OSHA Walking and Working Surfaces regulation and specifically the changes to fixed vertical ladders and the shift to vertical ladder safety systems as a move away from cages and wells. What are the options for employers to retrofit these systems (without getting into the mandated timeline issues)?

AS: We have two primary ways these systems can be installed. The first way is we can come out and install it for you, whether it’s one of our kits or it’s a custom-built system. For all applications greater than 90’, we facilitate an MSA-authorized installer to perform the installation. The second way is if a customer purchases one of our kits, they can opt to handle the installation themselves. We have kits up 90’, so they cover a lot of applications. All that’s really needed are some basic mechanical skills and the ability to follow the instructions provided within the user’s manual.

PF: I really think ladder cages are a poor solution for worker safety. I certainly wouldn’t want to fall through a ladder cage and get hung up in it. I can only imagine the horrific injuries that would result. I’m glad that OSHA has decided to make them obsolete, but I’m concerned that many employers will wait until 2036 approaches before making the move to a safer system.

AS: I agree and share your concern, Pat. Another way to meet compliance is to use a top mount davit with an SRL and tagline. This solution is an option when evaluating a vertical ladder safety system. Some companies go with this option because they’re easy to install and don’t require the user to have a front chest d-ring on their harness. Another option would be to use a twin leg personal fall limiter and clip along from rung to rung.  

Fall Protection in Residential Roofing

PF: You and I have worked together in the past up in your neck of the woods, presenting information to a variety of groups on fall protection equipment. As more safety managers see these new systems and equipment, they are very apt to provide a safer yet more user-friendly solution to their authorized workers. However, we are still seeing a particular segment of the construction industry lagging in providing compliant fall protection for their workers. That industry is residential construction and in particular residential roofing.

AS: Yes, residential roofing is clearly a segment that needs us to demonstrate that there are great solutions that not only keep their employees safe, but also make it easier for workers to do their jobs. I remember a recent conference where you had a steep angle roofing mock set up, and seeing the smiles on the faces of attendees when they realized they could let their harness support their weight instead of trying to curl their toes and hold onto the sheathing while laying felt. I think for most of them it was quite a revelation. I believe you had two different systems set up. The positioning system was simply a 5/8” lifeline with a short shock-absorbing lanyard attached to a manual rope grab. And on the other exposure you had a temporary horizontal lifeline along the peak with a leading edge SRL attached to it.

PF: Yes, but the SRL was not just any SRL. It was your V-Edge Leading Edge SRL.

AS: Yes, it was great to see the attendees’ reactions as the V-Edge followed their movement along the horizontal lifeline. In addition to the leading edge feature of that particular SRL, it also has a built-in roll-cage around the clear cable housing which allows the entire unit to pivot around a floor mounted anchor. This keeps the direction of pull or tension of the cable directly in line with the user and SRL. It works great on steep angle roofs attached to a horizontal lifeline to keep the device aligned vertically with the user as they move about the roof.

Viewing Your Safety Equipment Rep As A Resource To Help Solve For Safety Concerns

PF: There’s certainly a lot of innovation happening in the fall protection equipment market. How do you recommend employers think about worker safety in the context of these new technologies?

AS: I think it’s a high return on investment exercise for employers to invite safety equipment representatives into their facility to look at different applications, almost like an audit. A good equipment rep specializes in staying on top of all the latest developments in the dynamic world of equipment and safety systems. It’s tough for an employer to do that on their own, so the safety equipment rep ideally will partner with the employer to evaluate all their concerns and help them prioritize. I’ve found employers are often pleasantly surprised with the solutions folks like me come up with, either because they didn’t think a solution existed, or because they were surprised we could make the workplace safer without impeding production.

PF: Andy, I want to thank you for having this chat with Roco Rescue and I know we have just scratched the surface of everything fall protection. I hope our readers have found this both informative and entertaining, and perhaps got them thinking about their own fall protection needs.

AS: Thanks so much for inviting me to join you today Pat. We at MSA want to ensure employers are armed with all the information they need to select the fall protection equipment and systems that best suit their needs. We love talking about how our products can be used in various applications, but most importantly how they can be used to ensure workers make it home safely.

We recently had a Facebook inquiry about attaching a rappeler's belay line (safety line) to their high-point dorsal connection on their harness. We choose to do this for a number of reasons including: (a) compliance with applicable regulations; (b) adherence to safe and practical rescue procedures; and, (c) the physiological effects of falls – how the body absorbs an impact force. Let’s take a general look at these considerations.

Compliance

OSHA considers our rappel/lower main lines as “work positioning” lines and our belay or safety lines as “fall protection.” The fact that they and we, as rescuers, consider the safety line as fall protection, or more accurately as our Personal Fall Arrest System (PFAS), kicks in a few requirements and considerations for all private sector responders and for municipal responders governed by OSHA-approved State Plans. These responders are required to comply with applicable OSHA regulations.

However, keep in mind, these regulations are designed to protect workers (and rescuers) from harm and injury. During training, since it is not a real rescue, we should be following the applicable regulations and standards for safety as well as liability reasons. Even during actual rescues, it is important to adequately protect our people from injury. The days of “rescue at all costs” are gone. We are responsible for designing training, systems and SOPs/SOGs that protect our people in a rescue situation.

Note the following key points from OSHA 1926.502(d):

• Limiting the free fall distance (max free fall 6 feet)
“…be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level”

• Deceleration distance of 3.5 feet (41 inches)
“…bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)”

• Maximum allowable impact load 1,800lbf.
“…limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness”

• Improvised anchorage strengths of 5,000lbf or twice the anticipated load.

“Anchorages used for attachment of personal fall arrest equipment shall be…capable of supporting at least 5,000 pounds (22.2 kN) per employee attached…”
“Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.”

• Harness attachment should be to the high-point dorsal connection point.

“The attachment point of the body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head.”

You may have heard the statement, “Firefighters/rescuers don't need fall protection or need to follow OSHA.” This is not true for the 27 State Plan states where OSHA regulations do apply to public sector employees including emergency responders. It puts the burden on the employer, agency or department to establish fall protection and rescue protocols that would adequately protect their people.

To illustrate this, here is an excerpt from an article written by Stephen Speer, a NY career firefighter, for “Fire Rescue” magazine which deals with potential OSHA violations during rescue operations and training exercises. (Note: New York is a State-Plan state.)

“I spoke to a New York State Public Employee Safety & Health (PESH) supervisor about the following scenario and asked if there were areas that could be potential violations.

Scenario: A firefighter operating from a roof ladder is cutting a ventilation hole on a pitched roof. The firefighter falls from the roof and is injured.

In what areas, if any, could an incident commander or company officer be cited? In response, I received 12 pages of documentation. The documents showed that in evaluating potential violations of the general duty clause to see if anyone is responsible, the following four elements must be met:

1. The employer failed to keep the workplace free from a hazard to which employees of that employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or likely to cause death or serious physical harm.

NFPA 1500, chapter 8.5.1.1, states that operations should be limited to those that can be completed safely. In this scenario, there is the potential for citation if all four elements apply. As the above scenario illustrates, whether or not you have an aerial apparatus, you must consider fall arrest protection.”

Practicality

When rescuers are sent into a vertical confined space, we use the safety line (PFAS) to protect them as they are being lowered and raised from the space. It is also used as “an immediate means of retrieval” should something go wrong inside the space. Having the safety/retrieval line attachment point at the high-point dorsal position allows us to attempt an emergency retrieval with the victim being extracted in a low profile to fit through a narrow portal.

Physiological Effects

There have been numerous studies on the effects on the body when subject to a fall and arrest while in a harness. They generally come to the same conclusion that high-point dorsal attachment is the most survivable and provides for the greatest injury reduction. Here are excerpts from two studies.

1) Excerpt from a study conducted by Dr. M. Amphoux entitled, “Exposure of Human Body in Falling Accidents,” which he presented at the International Fall Protection Seminar in 1983:

In experiments on the position of the attachment point on the harnesses, Amphoux found that a high attachment point was preferable because “it gave a better-disposed suspension” and that it was “especially effective when the attachment is on the back. When the falling stops, the neck flexes forward. If the attachment point is in the front of the sternum, the neck flexes backwards and the lanyard may strike the face.”

Amphoux continued that it would be better for the compression to be localized on the body of vertebrae and not on the posterior joints, which were too fragile. “Therefore,” he said, “the attachment point would be better on the back than pre-sternal and should be high enough to reduce the potential neck injury. In addition, the forward flexion would be stopped by the thrust of the chin on the chest.”

This was why Amphoux and his colleagues strictly recommended attachment high on the back. It also protected the face from the lanyard when falling. In the case of falling head first, regaining a feet-first position would involve flexion of the head, whereas if the attachment were pre-sternal, the head would more often be projected backwards [whiplash effect].

However, it was accepted that a front attachment might be preferred in a few working situations. This was only acceptable when the height of the potential fall was very short. Whatever the choice of body support, it should not be forgotten that it was only a compromise and not a guarantee of absolute security.

2) Excerpt from “Survivable Impact Forces on Human Body Constrained by Full Body Harness,” HSL/2003/09 by Harry Crawford:

The one-size-fits-all policy of some harness manufacturers may not be suitable for the range of body weight 50kg to 140kg. Although it may be possible for those in the wide range of body weight/size to don such a harness, the position of the harness/lanyard attachment is of paramount importance. For best performance and least risk of injury, the attachment should be as high as possible between the shoulder blades.

Note: They also concluded that the shorter the fall, the less impact and less chance of injury no matter which type of harness or where the connection point was.

Like any rescue or work safety technique, you need to look at all the variables and decide which technique and equipment will best protect you or your co-workers. We choose the high-point back connection because of the variety of situations and locations we might face during a rescue based on the three considerations mentioned earlier in this article.

Thanks for a great question and taking the time to look into the reasons why systems or techniques are used. I hope this answers your question. If you have additional questions, please contact me at 800-647-7626.

By Dennis O'Connell, Roco Director of Training

Does your company authorize employees to work at height using personal fall arrest systems (PFAS)?

If so, you need to keep reading. Even if your employees don't use personal fall arrest systems, but they work at height using passive restraint, active restraint, or work-positioning systems, you need to keep on reading.

If you have demonstrated that there is no feasible means to utilize employee protection on the "Hierarchy of Fall Protection" other than fall arrest, meaning there is no way to bring the work to the ground or to use a fall restraint, then you have accepted that at some point, your employee will fall.

The personal fall arrest system (PFAS) is there to arrest their fall before they hit the ground or other hard parts, and to minimize injury during that fall and arrest event. OSHA requires employers who authorize personal fall protection systems to provide "prompt rescue," and a big reason for this is OSHA now recognizes suspension trauma as a hazard. Reference: 1910.140(c)(21) "The employer must provide for prompt rescue of each employee in the event of a fall," OSHA Safety and Health Information Bulletin (SHIB 03-24-2004, updated 2011) regarding Suspension Trauma.

Even though this is not specifically required by OSHA, wouldn't it make sense to have a prompt rescue capability for times when an employee is injured or becomes suddenly ill while working at height?

This could be an employee who is protected by passive restraint but not PFAS. For instance, if an employee needs to climb a vertical fixed ladder to access a platform with perimeter guardrails 20 feet above the next lower level and is incapacitated due to injury or illness, how will you get that employee to the ground for treatment and transport? Most likely it will require a technical rope rescue effort or some other means of getting them from height and safely to the ground.

Having Suspended Worker Rescue Preplans already in place goes a long way in preparing for the emergency of a fallen suspended worker or a worker that is injured or becomes ill but is isolated by height. By completing these preplans, it should become apparent when the requirements for viable rescue go beyond what I call the "Fred Flintstone" rescue (i.e., "so easy a caveman can do it!").

Additionally, there are products that will delay the onset of suspension trauma should a worker fall and remain suspended in their PFAS. These can significantly improve survivability after fall arrest while awaiting rescue.

Assisted, non-technical rescue can be accomplished using ladders, man lifts, or many other primitive but effective means. However, there comes a point where the situation will require some degree of technical rescue capability. If you have done an honest and knowledgeable assessment of the rescue needs for your facility for all the known or potential areas where you may have employees working at height, you very likely will have found the need for a technical rescue requirement.

If you are lucky, and your facility is located in a municipality that has emergency responders with a rope rescue capability that is willing and able to respond to your location, then you still must ensure that they can perform what needs to be done.

A really good way to do this is to have them come to your facility for the purposes of preplanning and hopefully demonstrating their abilities. Simply posting "911" as the plan, and calling it good, is not even close.

Some facilities have in-house teams that are equipped and trained to perform technical rescue. These in-house teams are generally the fastest to respond and it usually eliminates the problem of relying on a municipal rescue team that may be called out on a separate emergency.

For companies that do not have a municipal agency that can and will respond or does not have the technical ability to perform the types of rescues that may be required, there is always the option of training host employees to perform these types of rescue.

The first option is a single day of training using pre-engineered rescue systems or what we like to call "plug and play" systems. The second option is a two-day "build as you go" class that provides solutions in rescue environments that the pre-engineered systems are unable to cover.

Roco's one-day Pre-Engineered Rescue Systems training relies on manufactured rescue systems that require no knot tying, or the need to create mechanical advantages, or to load friction control devices. These systems are so straight forward that most students will be able to operate them safely and proficiently even if they haven't performed refresher training for several months. With these systems, you literally take the system out of a bag, hang it up to a suitable anchor, and you are ready to rescue.

Roco teaches a variety of techniques that are suitable for a conscious, uninjured suspended victim and also for an unconscious or injured victim who would need to be connected to the rescue system remotely by the use of a telescopic "gotcha pole." As straightforward and easy as this system is to become proficient with, it does have its limitations. For example, in order for this type of system to be employed, the rescuer(s) must be able to safely get into a position above or slightly offset, and within about 10 feet from the victim. If that is not possible, then it is time to prepare for a technical suspended worker rescue.

Roco's two-day Suspended Worker Rescue class teaches a limited variety of knots, including tied full-body harnesses, mechanical advantage systems, anchoring, friction control, lowering, rappelling, hauling, and line transfer systems. These skills are not that hard to master, but they are perishable and require sufficient practice at regular intervals in order to maintain proficiency. This type of "build as you go" capability allows the rescue team to create a system that will work for just about any situation and structural configuration except for the most extreme settings.

So, if your facility seems to be behind the curve regarding the rescue of workers from height, you may need to discuss training options - either for the worker that has fallen and remains suspended from their PFAS, or for the one who is injured or ill at height with no way to get down.

Remember, a worker cannot hang suspended for any length of time without the danger of suspension trauma, which can be deadly.

If we can assist you in assessing your fall protection rescue needs, please contact us at info@rocorescue.com, or call our office at 800-647-7626.

Additional Resources

• Hierarchy of Fall Protection Poster
• Sample Suspended Worker Rescue Preplan
• Suspension Trauma Poster