READER QUESTION:
I went through competent person for fall protection several years ago and since that time a lot has changed regarding the types of fall protection equipment and systems that are available. Should I get update training for this role?
ROCO TECH PANEL ANSWER:
Yes, definitely. In fact, ANSI Z359.2 states competent person training update training shall be conducted at least every two years. It is always a great idea for competent persons to stay abreast of not only any legislative changes, but also to stay current on consensus standards such as ANSI, and certainly on emerging equipment technologies. It is amazing how quickly new fall protection equipment is becoming available. It wasn’t long ago that harness mount self-retracting lanyards were just a drawing on an engineer’s desk, and now there are so many different versions it is mind boggling. OSHA’s recognition of suspension trauma as a workplace hazard to fallen suspended authorized persons has created an entire market segment for systems to help deal with this hazard. So receiving update training for this crucial role at least every two years is certainly a great idea.
READER QUESTION:
Can I complete competent person for fall protection training via an on-line course?
ROCO TECH PANEL ANSWER:
We discourage that type of course other than for learning the legislated requirements. There just is no substitute for hands-on training. One of the most important responsibilities of a competent person for fall protection is the performance of periodic equipment inspections. I can’t imagine having any way to show competency of this skill without demonstrating it to a live instructor/evaluator.
This article appeared in OH&S, November 2015
Whatever training you attend and complete should be viewed as the launching point to get you started on learning everything you can about fall protection.
Gravity doesn't need to go to school. She is a master at pulling all objects toward the center of our blue planet and has been doing so since the dawn of time. So, yep, she is the grand master. Whereas we mere mortals are still learning how to counter her effects. Part of our learning is how to protect our workers at height from falling into her grasp. And OSHA recognizes we are still learning and thus requires employers to provide appropriate training to protect their workers at height—as well as from the grand master's constant grip.
There are several roles and responsibilities within any comprehensive fall protection program, and there are just as many courses of instruction that provide a baseline of knowledge and skills designed to get the individuals occupying these positions started or to enhance their ability to perform in these roles. But no single course of instruction currently covers, nor will one ever cover, every bit of knowledge needed for every work at height situation.
There is an old joke that goes like this: "What do you call the bottom graduate of medical school?" The answer is, "Doctor, of course."
What does that have to do with fall protection training, you may ask? Well, the rest of the story is that very often that bottom medical school graduate goes on to become a leader in his or her specialty. And that happens because they practice. That's why they call it practicing medicine, I suppose.
So this is where it will begin to make sense. Fall protection training is the beginning and should not and cannot be thought of as the "end all" for whatever role and responsibility for which you are training. Whatever training you attend and complete should be viewed as the launching point to get you started on learning everything you can about fall protection. This includes compliance requirements; fall protection system capabilities and limitations; the dynamics of a fall, including clearance requirements and swing fall; post-fall rescue; and, as importantly, what is the best fit for your Authorized Persons.
Gaining the knowledge and understanding of these and many other facets of fall protection requires continuous self-study and research. It also requires getting out and visiting your facility to find out what the structural geometry is and to learn about the processes, as well as the Authorized Persons' needs and concerns.
During the past 35 years, I have attended training for all sorts of occupational duties, and the one common denominator has been that all of them provide a foundation to build from. For the most part, I felt I could function in the role I was being trained for, but I would equate it to functioning at the "apprentice" or "journeyman" level. I knew I still had much to learn before mastering the task.
This is especially true for fall protection training. To learn every single OSHA requirement regarding fall protection is a very tall order. I don't know of any fall protection Competent Person course that covers it all or would attempt to cover it all. And to know the particular challenges of every location where work is performed at height can only be gained through experience. In order to move toward mastering the craft, it is important to take the initiative to learn beyond the formal training.
However, self-study is so much easier than it was 15 or 20 years ago. The ease of accessing OSHA standards, letters of interpretation, summaries and explanations of final rules, and other OSHA resources pertaining to fall protection on the World Wide Web opens up a wealth of information.
It is also my good fortune that I visit many different client sites where I encounter a smorgasbord of fall protection challenges that provide learning opportunities. Oftentimes, I am able to recite the information nearly verbatim that pertains to the issue, but as often as not, I need to do some research to locate the answer or to refresh my memory once again. This is expected and, in lieu of a photographic memory, there is just too much information to learn and retain with 100 percent accuracy.
With the emerging technologies in manufacturing and design of fall protection equipment and systems, it is often a great learning exercise to visit some of the leading equipment manufacturers' and retailers' online catalogs. It is actually pretty exciting to peruse these sites and see many of these modern solutions. And the equipment isn't limited to lanyards and body support, either: There are solutions such as temporary or permanent retro-fitted guardrail systems, harness mount SRLs, nonpenetrating anchor connectors, temporary user-installed horizontal lifelines, and the list goes on. Inviting a fall protection dealer representative to your site may prove to be very educational and beneficial time spent.
Sharing Lessons LearnedBack in my military days, we had a program known as "CROSSTELL," which was a formal messaging system designed to share lessons learned and to disseminate new ideas or techniques between common users. Within the private sector there are similar programs known as BKP (best known practices) or BKM (best known methods) that often provide a vehicle to share useful information within a common industry or within a single corporation. The warning here is to cross-check the BKM or BKP to ensure it is indeed compliant with any applicable legislated requirements. And if you develop what you feel is a BKM or BKP, don’t be bashful about sharing.
Much of the continuing education we have talked about so far is in "black and white" in the form of regulations or interpretations, or a form of equipment that has accompanying printed user instructions. The intangibles are often the most difficult and dynamic pieces of the puzzle to learn. Getting out into the work environment is a very big part of your ongoing self-education.
Performing a fall hazard survey as outlined in ANSI Z359.2 is a great starting point for learning the various means of protecting workers from falls. Always keeping the hierarchy of fall protection in mind, performing a comprehensive assessment of the known and potential areas for work at height will definitely provide an education. Now is the time to take your knowledge of compliance requirements, the BKM/BKPs, a broad knowledge of the equipment that is available, and then determine what will work best for the configuration of the structure, the environmental conditions, and also through interviewing the workers who will be employing the equipment to learn what their needs are. Will they need equipment that provides a high degree of mobility? Are they concerned about heavy or bulky equipment or exposed to hot working environments? Do they need equipment that can be set up and taken down quickly to facilitate moving from point to point? This can only be determined by talking to and listening to the Authorized Persons and their foremen.
By considering a formal fall protection course of instruction the endpoint for your fall protection training, no matter what capacity you are working in, is doing a disservice to your co-workers and to yourself. Accepting the onus of continuing your "training" through self-study, visiting the equipment offerings, and assessing the working environment and the needs of the workers to do their jobs is all a part of your continuing—ongoing—fall protection education.
The following article was featured in the September issue of ISHN, and authored by Roco Chief Instructor Pat Furr.
Every team has their most valuable player or person, their MVP. When you consider all the personnel who make up the fall protection team at your facility, who is your MVP?
Chances are it is your Competent Person. OSHA defines a Competent Person as “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” In order to do their job and become your Fall Protection MVP, it is very important that your Competent Person be.....well, competent.
Understanding Regulations & Standards
Competence can come through formal training, work experience, self-study, or most likely a combination of all three. Areas in which the Competent Person must be well versed include a thorough understanding of legislated requirements pertaining to fall protection. A great deal of time must be spent visiting the applicable OSHA regulations that apply to the type of work activities that the Competent Person will be overseeing.
This can be rather daunting, but there are plenty of resources to help in this effort. OSHA provides clarification through the issuance of letters of interpretation, Safety and Health Information Bulletins (SHIBs) and safety posters, and several training institutions provide formal training covering OSHA regulations as part of their curricula.
In addition to understanding the OSHA legislated requirements, it is also helpful that the Competent Person use consensus standards, BKM, and certainly any company policies that strengthen the OSHA required protections. The ANSI/ASSE Z359 family of standards is a big help, especially Z359.2 titled, “Minimum Requirements for a Comprehensive Managed Fall Protection Program.” This document provides recommended guidance for roles and responsibilities, training, fall hazard surveys, procedures, the hierarchy of fall protection, anchorages, inspection, maintenance and storage of fall protection equipment, rescue procedures, incident investigation, and evaluating program effectiveness.
Meeting the Needs of Authorized Persons
The Competent Person is in a unique position. They must communicate to the Authorized Persons that will be employing the fall protection procedures and systems, and also to the Program Administrator. In many cases, the Competent Person may be the Program Administrator, too. In this position, the Competent Person must strive to understand the needs of Authorized Persons regarding systems and equipment that will not create an unacceptable hindrance to their job.
If the fall protection equipment is so burdensome that workers cannot do their job, or is very uncomfortable, there is a better chance they will be reluctant to use it. So one of the most important aspects of the Competent Person’s education is to stay abreast of the types of fall protection equipment and systems commercially available. With the recent explosion of modern, lightweight, multi-function, easily deployed fall protection equipment and systems, the question of feasibility and overcoming reluctance on the part of the Authorized Person is becoming a concern of the past.
Fall Hazard Survey
The “Fall Hazard Survey” is a great tool for the Competent Person to use to identify existing and potential future fall hazards at the worksite, and to determine means to abate those hazards. This exercise is outlined in ANSI/ASSE Z359.2 and provides a systematic approach to this most valuable step. I refer to it as the fall hazard walk-about — a top-to-bottom, north-to-south, thorough physical review of all areas in which current or future work at height may be performed. The goal is to identify fall hazards by type and to identify one or more means to eliminate or control hazards while keeping the hierarchy of fall protection in mind at all times.
Once the Fall Hazard Survey is completed, it may call for the use of active fall protection equipment and systems if falls cannot be eliminated through engineering controls. In this instance, the Competent Person may have to impose limits on work activities and prescribe specific guidance on equipment and non-certified anchor point selection, and also on equipment use limitations to control swing falls and clearance requirements. Procedures put into place to eliminate or control fall hazards should be documented and included in the fall protection program.
Rescue Planning
One often overlooked duty of the Competent Person is to prepare or ensure that written rescue pre-plans are developed for any identified fall hazard that calls for the use of personnel fall arrest systems. I advocate development of a rescue from height pre-plan anytime employees are performing work at an elevated location that is accessed by means other than a stairwell or elevator. This includes platforms that may be protected by passive restraints such as standard guardrails or parapets. Always consider the possibility that a worker may be injured or become suddenly ill while at this elevated position and will need prompt rescue to get them safely to ground level.
Equipment Inspections & Incident Investigation
There are two primary types of fall protection equipment and system inspections, and the Competent Person plays a role in both types. The Competent Person is tasked with performing OSHA-mandated periodic inspections and any periodic inspections in accordance with the manufacturer’s instructions for use. Pre-use inspections of fall protection equipment will be completed by the Authorized Person, but the training on these pre-use inspections and the person who ensures that these inspections are indeed completed is the Competent Person. If any equipment fails a pre-use or periodic inspection, it is immediately removed from service. In the unfortunate event that there is a fall from height incident, the Competent Person will participate in the investigation.
Role Recap 
I’d like to summarize the role of the Competent Person “According to Pat” by saying they:
I hope you have your own “Fall Protection MVP” at your work site and, if not, maybe it is time to groom one.
The following article was featured in the June 2014 issue of ISHN, and authored by Roco Chief Instructor Pat Furr.
As part of my safety consulting duties, I have seen many fall protection programs for a wide variety of industries. When I ask about an employer’s fall protection plan, it’s pretty scary to be told, “Well, I can show you our program in two minutes”— and then see no more than a locker with a rag-tag assortment of body belts, harnesses and a few six- foot energy-absorbing lanyards of questionable integrity.
Now, it is rare to come across such an inadequate program. But truth be told, the comprehensiveness, diligence and effectiveness of the programs I have assessed run a fairly wide spectrum from so-so to top notch.
Top-notch programs all had several common elements, but the one element that stands out the most as being consistently included in the best programs is the completion of fall hazard surveys.
The fall hazard survey, or what I like to call the fall hazard “walk-about,” is a critical early step in the process of assembling a comprehensive managed fall protection program. And a survey should be conducted again when certain changes occur including, but not limited to, changes in the facility configuration, changes to work processes, changes to legislated requirements, and the emergence of modern fall protection equipment solutions.
Outlined in ANSI Z359.2, the fall hazard survey is an effective means to identify areas where work is performed at height, identify ways to eliminate or control fall hazards, and help determine which hazards require the highest priority when it comes to allocating sometimes limited resources. A comprehensive fall hazard survey is the best way to identify and understand the types of fall hazards that need to be addressed to provide the best protection to your workers at height.
This requires that the Qualified or Competent Person do a top to bottom, left to right, tour of the facility to identify known areas where work at height is currently being performed, and any areas where future work at height may take place.
It may be helpful to have an area foreman or even an Authorized Person with thorough knowledge of the specific work areas available to ask questions regarding the work process and their needs and concerns.
The goal of this survey is to not only identify areas of work at height, but to determine the most protective means of abating fall hazards. 
The Qualified/Competent Person must have the “Hierarchy of Fall Protection” in mind at all times. By having the goal of eliminating the fall hazard first and foremost, any opportunities to bring the work to the ground or to perform the work from the ground should present themselves during this survey. This may require a change in the configuration of certain structures, or the retrofitting of systems that allow the work to be performed from the ground. This may incur some significant costs, but in the long run the changes will be more than offset by avoiding a fall from height and the direct and indirect costs of such an accident.
Continuing the survey while still adhering to the Hierarchy of Fall Protection, the Qualified/ Competent Person may have to consider the use of fall restraint measures, either passive measures in the form of guardrails or parapets, or active measures in the form of body belts or harnesses with lanyards anchored in a way that the system prevents the Authorized Worker from reaching the leading edge of a fall hazard. Once active measures are employed, it is critically important to work with the Authorized Persons to understand what their work activities entail to come to a solution that provides the needed protection but also considers their need for mobility.
If the lower echelons of the Hierarchy of Fall Protection cannot be employed, a fall arrest system may be the only feasible solution. This is where the Qualified/Competent Person’s knowledge of current fall arrest systems and components really shows its value. Lightweight, breathable, multi-function fall protection equipment available today protects workers while also providing the ease of use and freedom of movement that has been missing for many years. This is an important tool that the Competent Person can use to their advantage when faced with any resistance from certain Authorized Persons.
During the fall hazard survey, consider the presence of any environmental factors that may affect the performance of the fall protection equipment or systems as well as an alternate solution, specialized materials, or even a reconfiguration of the structure/process. Environmental factors can include hot objects, sharp edges, slowly engulfing materials, chemicals, weather factors, or any other environmental factor that may render the fall protection equipment ineffective.
Once the entire facility has been surveyed, it’s time to document in writing the findings and the means to abate the identified fall hazards. The Fall Hazard Survey Report becomes a part of the written fall protection program. It should be reviewed periodically and whenever there is a change to legislated requirements or a change in the facility or fall protection equipment.
If any identified areas require the use of fall arrest systems, then that triggers the need to complete a written rescue pre-plan. It is my opinion that rescue
pre-plans should also include anywhere workers are performing work at height, such as elevated platforms that have been accessed by means other than elevators or stairs, with the goal that the rescue plan provides a capability to get the injured or suddenly ill worker to the ground promptly.
Time to TrainOnce the Fall Hazard Survey is completed and documented, it is time for the Qualified Competent Person to provide training to the Authorized Persons on the types of equipment, systems, selection of anchor points, clearance requirements, swing fall hazards, and pre-use inspections of their equipment. Training may vary depending on the areas that Authorized Persons are assigned duties, but in all cases the type of training, any required re-training, and the criteria that would trigger the need for retraining must be documented.
The fall hazard survey is a valuable tool that provides a thorough assessment of the entire facility to honestly identify fall hazards and determine the most effective means to protect workers from falls. Look at it as an expanded JHA that focuses specifically on areas of work at height.
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