UPDATE: OSHA recently unveiled its top 10 most frequently cited violations for 2010, and topping the list is Fall Protection. With 7,139 violations, Fall Protection is still at the top, switching places with last year’s first place holder, Scaffolding. OSHA reported that 260 workers died in 2010 from falls, which continues to be the leading cause of death in construction. So, you’ve developed an exemplary employee safety program and the shining gem is your fall protection program.

Using an organized approach and ANSI guidance for completing a “Fall Hazard Survey Report,” you have identified all the areas that workers are exposed to falls from height. Adhering to the hierarchy of fall protection, you’ve also been able to engineer out many of these fall hazards by bringing the work to the ground. Outstanding! For several of the remaining areas, you’ve installed passive fall restraint systems like guard rails and parapets. Great! Still, there are several areas that could not be protected by engineering out the hazard or providing passive restraint.

For some of these areas you are able to protect your employees from falls with active restraint, using body support and a restraint lanyard connected to a suitable anchor that prevents the worker from falling. Good. But, there are still a few remaining areas that you could not protect your employees from falls using the lower hierarchy solutions, and the only feasible solution was the use of personal fall arrest systems (PFAS). OK. You are still providing a compliant and possibly the most logical and feasible program that will provide a high degree of fall protection for your work force. Job well done! Or is it?

By taking the steps covered above and using the “Hierarchy of Fall Protection,” the employer is doing exactly what OSHA expects of them to protect their employees from the devastating injuries resulting from falls. However, there is one more piece to the puzzle…what are the potential outcomes and OSHA expectations after an employee falls? Especially if the employee is using PFAS.

OSHA’s Fall Protection regulations state that the employer shall provide prompt rescue in the event of a fall, or shall assure that employees are able to rescue themselves (OSHA 1926.502 and 1910.66 app. C). Although both regulations include “self-rescue” as the first choice in most cases — can we really rely on a worker to self-rescue in the event of a fall? What if the worker is injured during the fall, or what if a sudden medical emergency caused the fall? Are we confident that the individual will be able to perform self-rescue? In our opinion, relying on an employee to provide self-rescue after a fall does not fully meet the spirit of OSHA Fall Protection regulations. In fact, we feel that the only way to provide 100% rescue coverage is to assume that self-rescue is not a reliable option.

The irony is that an employer with an inadequate fall protection program may not face the need for a fallen/suspended worker rescue capability. In this environment, if the employee falls and has no PFAS, there is probably no need for rescue; it is more likely now a recovery. At this point, what the employee really needs is a “help wanted” ad to replace the employee and a very good lawyer.

Just a few years ago it was fairly common for employers not to be aware of the “after fall” hazards created by the PFAS. The understanding was that the PFAS did its job and the emergency was averted. However, in 2004, OSHA published a Safety and Health Information Bulletin (SHIB 03-24-2004 updated 2011 https://osha.gov/dts/shib/shib032404.html) that provided advice and information on suspension trauma/orthostatic intolerance. In fact, the bulletin states that “research indicates that suspension…can result in unconsciousness, followed by death, in less than 30 minutes.” As a recognized hazard, an understanding of suspension trauma makes it clear that post fall arrest suspended workers are still at risk of serious and possibly fatal injury even in the absence of primary injury prior to, or during the fall.

Although OSHA regulations do not assign a specific time criteria to what constitutes “prompt rescue,” ANSI Z359.2 does. ANSI recommends that “physical or verbal” contact be made with the fallen worker within four (4) to six (6) minutes. Notice that ANSI includes verbal contact in their recommendation. It makes sense that if verbal contact is established, the fallen worker’s condition can be assessed and a determination made on the general urgency of the situation. For example, if responders can establish verbal contact with the fallen/suspended worker, and the victim is alert and oriented, has normal or near normal breathing function, and has no obvious signs of bleeding, then the rescue can be approached in a measured manner. Responders should also remind the suspended worker to “bicycle” their legs — or to deploy any system that is designed to delay the onset of suspension trauma. Obviously, the victim needs to be rescued in a safe and expeditious manner before the onset of suspension trauma, if possible.

However, if the victim is unresponsive, or showing signs of breathing difficulty, or active bleeding, then the sense of urgency should be elevated and the victim must be rescued ASAP. This presents a true dilemma for the employer who has not included a prompt rescue capability in their comprehensive fall protection program.

In fact, it is common to refer to a PFAS system as having four components:


A great way to ensure that a prompt rescue capability is available in the event of a fallen/suspended worker is to complete a “Fallen Worker Rescue Preplan” for all areas where employees are working at height. For general industry facilities, which tend to be fairly static, this can be done initially with periodic review and updates as needed. For the typical construction industry with its dynamic activities, a much more diligent and regular review of rescue needs and rescue plans may be needed.

Employers have a few options in developing a prompt rescue of fallen/suspended worker capability. Coordinating with municipal emergency responders is one option. Contracting third party professional rescue services is another possibility — especially during turnaround activities or major reconfigurations/additions. Or, the employer can choose to develop an in-house rescue capability made up of their own employees that are trained and equipped to perform the types of rescues that they may be confronted with at their facility.

Whichever option the employer chooses, it is of utmost importance that the employer vets the rescuers, even their own in-house assets, to ensure that they can actually perform the types of rescue, including the worst case that they may be responding to. For those using an outside rescue service, it is a great practice to invite the rescuers to the facility for the purpose of rescue planning and a performance evaluation of their capabilities. It is very common for outside rescuers to be caught off guard when confronted with unique structural or victim access constraints upon seeing the facility for the first time. This may be so significant that the rescuers find themselves unequipped or lacking in the skills required to provide rescue.

The recent advent of pre-engineered rescue systems has also lulled many employers into the belief that these systems will provide an all-encompassing rescue capability. While most of these “Plug–and–Play” systems do provide a certain level of performance, they also have limitations, especially if access to the fallen/suspended worker requires a rescuer to be put on line to make physical contact with the victim. In this case, it is quite likely that the employer may need to consider a technical rescue capability exceeding the capabilities of a pre-engineered rescue system.

The need for a more technical rescue approach can only be determined after a thorough evaluation of rescue needs based on Fallen Worker Rescue Preplans. We often refer to this as a fallen worker “walk-about” where knowledgeable representatives of the employer (usually the competent person or the competent rescuer) tour the facility to develop Fallen Worker Rescue Preplans. These individuals will need a thorough understanding of the work processes, the areas of workers at height, the access routes, the types of PPE/PFAS being used, and most importantly, an understanding of the techniques and equipment necessary to affect a safe and prompt rescue.

Once the Fallen Worker Rescue Preplans have been completed, they become part of the comprehensive fall protection program and should be reviewed and updated as necessary.  With the seemingly continuous advent of new rescue equipment and techniques, it would be a great idea to review your preplans to see if there are opportunities to add these innovations, especially if they provide a safer and more efficient means of rescue.

In summary, it is of utmost importance for employers to ensure that their workers at height (especially if using PFAS) are afforded prompt rescue should they fall and remain suspended from their PFAS system. Whether the employer chooses an outside rescue service or elects to develop an in-house team, they should ensure that the rescue team can perform any and all types of rescues they may be summoned to. If a pre-engineered rescue system or a technical rescue capability is determined to be the most appropriate route, ensure that the rescuers receive thorough, high quality training on the types of systems they will need to employ.

If you would like more information or need assistance in preparing your Fallen Worker Rescue Preplans, please call Roco at 800-647-7626.

We recently received a question about  what constitutes a prompt and capable rescue response for fallen workers at height suspended by their Personal Fall Arrest System (PFAS).

Question:  My question concerns guidance on the number of rescue/standby team members needed for response to “worker at heights” type incidents. We work in a chemical plant, so it’s basically areas such as columns, etc.

Answer:  OSHA guidance for rescue of fallen workers utilizing personal fall arrest systems (PFAS) is quite vague in that it calls for “prompt rescue.” For more definitive guidance on the subject, ANSI Z359.2 Para E6.1 recommends that contact with the rescue subject (communication or physical contact) should occur as soon as possible after the fall. The recommended goal for rescue subject contact should be less than six minutes. What constitutes “prompt rescue” can vary depending on the circumstances. The type of potential hazards identified in the Fall Hazard Survey report should determine rescue planning.

For example, if the work area exposes the worker to an IDLH condition such as energized equipment, then the Fall Hazard Survey should trigger the “Rescue Plan” to include a near immediate rescue provision because of the potential of worker electrocution leading to a fall and subsequently, a suspended victim. In a situation like this, it is imperative that prompt rescue would provide a means to have the rescue subject in a position that allows CPR in less than 6 minutes — and preferably much faster than that! The only way to respond this quickly is to have a “Stand-by Rescue” posture where the rescue system and personnel are pre-rigged and ready to initiate the rescue immediately.

For other situations, if communications with the rescue subject are established in six minutes or less, and it is determined that the victim is relatively unharmed (alert and oriented, good airway and breathing, and no signs of active bleeding) then the urgency is reduced and a more measured approach to the rescue could be employed. There is still the potential for suspension trauma to develop over a range of several minutes, so a “prompt” but measured rescue would still be necessary.

With this in mind, it is important for an employer with workers at height to complete a Fall Hazard Survey report to determine the most appropriate way to abate any fall hazards. If the use of PFAS is necessary, that triggers the need to complete fallen worker Rescue Preplans. The employer will need to identify the rescue assets and ensure they are available, equipped, and trained to perform safe and prompt rescue for any situation that they may be summoned to at the employer’s facility. For rescuers outside the employer’s workforce, it is important to thoroughly vet the prospective rescuers to make these assurances.

This information was provided by Pat Furr, Roco Chief Instructor and Technical Consultant. He regularly assists Roco customers in identifying opportunities to improve their fall protection programs and can guide safety professionals in the completion of Fall Hazard Survey reports. Roco can also assist in the development of fallen worker Rescue Preplans. For help with selecting the proper equipment or training, call us at 800-647-7626.

A recent accident involving a worker who fell from height inside the mono-tube of a water tower under construction, underscores the need to have a thorough understanding of Fall Protection systems and practices required by OSHA while undertaking hazardous work activities. It also emphasizes the importance of preplanning for rescue. Be sure to read additional comments from Roco Chief Instructor Pat Furr at the end of the article. Thanks to Dr. Skip Williams for submitting this story.

EAST WINDSOR, NJ… A worker fell nearly 50 feet to his death inside a new water tower under construction in a rural area of the township, police said. The 56 year-old man, whose name police did not release, was on a scaffold inside a tubular portion of the tower when he fell, landing on a solid floor 30 feet above the bottom of the structure. There was no water inside, and the worker was wearing a full body harness, said East Winsor Volunteer Fire Company No. 1 Chief Kevin Brink, one of the first responders on the scene. Mounting a ladder and coming up through a trap door in the floor where the man fell, Brink saw the man unconcious, unresponsive and bleeding. “I tell you this: I’ve seen worse people living,” he said. “To me, he was considered living until the paramedics pronounced him.”

The tower he was working on rises about 80 feet above the trees and farmland on Millstone Road. The familiar bubble-shaped cap that will hold water is not installed yet, and the structure yesterday looked much like a massive vase, with a dull pyramid for a bottom and a cylindrical tube mounted on top. A large crane had four metal lines grasping the top of the cylinder, and smaller cranes and trucks dotted the mud and gravel lot set back from the roadway. The victim, an employee of New Castle, Del.-based CBI Services, fell around 10:30 a.m., and was working near the top of the cylinder, Brink said. Fellow workers called 911, and police, firefighters and medical personnel rushed to the scene. The man’s colleagues entered a door at ground level and used ladders to get through the door at the bottom of the cylinder, where the man lay.

As firefighters donned equipment and prepared a basket to rush the man to a waiting ambulance, paramedics entered the structure and pronounced the victim dead. “We were just called out there for the actual rescue, unfortunately the person didn’t make it and it turned into a recovery,” Brink said. Police examined the body before firefighters put it inside the basket and lowered it out of the tower using a rope system, Brink said. By noon, the man’s body was out and ready to be turned over to the medical examiner.

A spokesperson for CBI Services would only say that an investigation is under way. Along with police and the medical examiner, both the Mercer County Prosecutor’s Office and OSHA responded to the scene, police said. “We’ve never really had any type of industrial accident out there,” Brink said. Unfamiliar with the layout of the tower, Brink said he initially was not sure if he would have to bring the company’s 100-foot ladder truck to reach the heights of the structure. “If he was stuck at the top, we were already starting to think about that,” he said.  Alex Zdan, Staff Writer/ New Jersey Times

NOTE:  While we were not present at the scene and don’t know all the details, here are some general comments from Chief Instructor Pat Furr concerning fall protection safety.

This incident took place while work was being done from a scaffold erected inside the tower. The worker fell from his work position and came to rest on a solid platform between the scaffold level and the ground. He was wearing a full body harness for body support as part of his personal fall protection system. However, this begs the question, “Why bother wearing a harness if the complete fall protection system is not employed?”

A complete personal fall protection system, which would be considered an active system, requires all of the components required by OSHA in order to be considered an effective/compliant means of personal fall protection. The harness is just the start. In addition to the harness for body support, there needs to be a connector attached to the appropriate point of the harness.

For fall restraint, a static lanyard can be used and connected to the rear or front waist belt attachment points of the harness (not the side attachment points); or, if desired, a body belt, or the dorsal attachment point of the full body harness. The lanyard must be adjusted to a length that does not allow the worker to fall from any exposed edges. This restraint lanyard does not need an energy absorber. If there is any potential that the worker may fall, then the lanyard must have an energy absorber that limits the impact forces at the harness to no more than 1,800 pounds. It must also limit the workers freefall to 6 feet or less.

An alternative is to use a Self-Retracting Lifeline (SRL). The third component of a personal fall protection system is a suitable anchor. The anchor point must be able to withstand a 1,000 pound force without failure for fall restraint, and a 5,000 pound force if used for fall arrest. These anchors can be as light as two times the anticipated forces if designated by a qualified person. Only one worker can be attached to the anchor point unless the minimum breaking strengths are multiplied by the number of workers using the same anchor point.

To review, the three physical components of a personal fall protection system are: (1) body support, (2) connector, and (3) anchor. For a fall arrest system, a fourth component is required, and that is prompt rescue.

This worker was on a scaffold. If the scaffold was completed with a green tag affixed, then it would have had standard guard rails to provide a passive fall restraint system and a harness would not have been necessary. If the scaffold was not completed and green tagged, then a personal fall protection system would be required.

Too often we encounter workers who are either unaware of the requirements to ensure safety at height – or choose to ignore the safety requirements that would most likely save their life or prevent serious injury. Bottom line…the use of a harness without completing the entire system only comprises 33% of the system which equates to 0% fall protection.