Fall Protection Basics

Fall protection violations typically take top place every year on OSHA’s Top 10 list. While addressing your fall protection program with an eye toward preventing violations is good, it’s even better to take actions that will improve fall protection immediately.

For employers, consider these steps:

• Assess fall protection PPE (harnesses and lanyards) for age. If it’s over 10 years old, replace it. If you don’t know the age, replace it, and start tracking the age.
• Perform a visual inspection of fall protection PPE. If there’s any wear, stitching damage, or other signs of deterioration, replace it.
• Ensure fall protection PPE is of the correct type for arresting a short fall. The ropes that climbers use are intended to stretch, thus softening the fall into free air. The lanyards for construction and maintenance workers are intended to not stretch because you typically do not have enough free air in which to fall.
• Inspect elevated work areas for correctly placed fall protection anchors that are correctly attached into structural steel or similar. Process piping, electrical raceway, and fire protection supply pipes are not fall protection attachment points.
• Ensure each work procedure for elevated work contains a complete list of the test equipment, tools, and materials needed to perform that elevated work. This reduces the amount of time a person is unprotected while going to and from elevation.
• Begin the process of assessing elevated work areas for opportunities to design out the need to work at elevation in the first place.
• Determine the last known fall protection training session for each employee who is likely to work at elevation. The training requirements are provided in 29 CFR 1926.503. OSHA does not provide an exact number of years after which retraining must be done, but NFPA 70E requires that lockout/tagout retraining be conducted after three years [110.4(B)(2)] and you might start with that. OSHA does require the employer to retrain if an employee doesn’t appear to have the necessary skill and understanding [29 CFR 1926.503(c)].

If you’re an employee whose work causes you to rely on fall protection, take these steps:

• Always inspect your harness and lanyard before and after each use.
• If you fall, don’t consider that a non-event simply because your fall protection protected you. Determine the cause of the fall, and report this to your supervisor. If it was your fault, you still report this to your supervisor — maybe you need training.
• If there’s not an adequate fall protection anchor, determine what is probably needed and report this to your supervisor.
• Never climb above the point of attachment (or anchor). If you are below it, your maximum fall is the length of your lanyard. That is typically 6 ft. The more you go above that distance, the more force you will feel when you come to that sudden stop when the lanyard goes taut.
• Be on the lookout for ways to design out elevated work. Why does this maintenance procedure require me to climb up there and check the voltage at the terminals? Putting a test port over here on the main panel would eliminate that climb.
• Eliminate trips. Getting to and from the elevation is the most dangerous part, as you typically don’t clip in until you get there. Use tools with magnetic tips, bring “dropper” spare parts, use adequate light, and focus on what you are doing.
• While OSHA does require specific actions by your employer, your personal safety is your personal responsibility. Understand this fact and act accordingly. Be attentive, not distracted, especially when moving one of your feet while at elevation. It takes only one wrong step to have a disaster, so before moving your foot, look at where you’ll be putting it. Is that surface firm and secure? What might happen if it’s not? Move with that last question in mind. Your fall protection is designed to prevent a ground fall, but you can hit something quite painfully even at the end of a 6-ft lanyard.