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Fall Protection and
Prevention
November 2009
Fall injuries are one of the
three leading causes of disabling work injuries in the
United States (US). The US Department of Labor (DOL)
lists falls as one of the leading causes of traumatic
occupational death, accounting for eight percent of all
occupational fatalities from trauma. The federal
Occupational Safety and Health Administration (OSHA) has
provided preliminary results for the top 10 most
frequently cited standards for 2009. All five of the
Construction standards cited (29 CFR 1926) are related to
working at heights, fall protection, and prevention. The
General Industry standards related to fall protection and
prevention (29 CFR 1910 Subpart D) once again made the top
ten list for 2009. The standard for guarding floor and
wall openings and holes (1910.23) moved onto the list for
2009, replacing the walking and working surfaces standard
(1910.21) from 2008.
The standards cited in the top
10 lists are fairly consistent from year to year.
Unfortunately, this relates to employers continuing to
expose their employees to fall hazards that can result in
severe injury or death and leading to serious and willful
fines from OSHA. OSHA’s general industry standards state
that any time a worker is at a height of four feet or
more, the worker is at risk and needs to be protected. So
what can employers do to protect employees and reduce fall
hazards?
The first thing that should be
done is to read and understand the full requirements of
the Subpart D standard, then inspect the facility and
review jobs where fall hazards exist and develop plans to
provide adequate protection. For example, rooftops,
catwalks, platforms and stairs that are accessed for
maintenance or operating tasks should be inspected to
ensure areas have properly installed guardrails and ladder
systems. Subpart D* has several standards that include
work instruction details regarding the installation,
maintenance and use of equipment to protect the user from
falls. Details include, but are not limited to:
The most common method used to
protect workers from falls is the use of properly
installed guardrails. Guardrails must meet the specific
design requirements presented in Subpart D, which requires
guardrails on flat surfaces include a toprail, midrail and
a toeboard. The toprail must be installed at 42 inches
from the standing surface, and the midrail at 21 inches,
plus or minus 3 inches. Toeboards are vertical guards
that are installed to prevent items from falling to areas
below. Guardrails must not be made of flimsy materials.
Each rail has specific requirements for the amount of
force they can withstand. The toprail, for example, must
be able to withstand 200 lbs. of force in all directions.
Guardrails and handrails for stairways have additional
design requirements.
An item that is often
overlooked during original construction of roofs is the
proper guarding of skylights. A common method of
protection for skylights is the use of screens. Screens
used for fall prevention must be rated to hold up to 200
lbs. When skylights are made of materials that may
fracture, such as glass or plastic, the screen must be
installed below the skylight to retain and prevent any
materials from falling below. If screens are not
required, a guardrail system as previously described must
be installed around the skylight.
Portable and fixed ladders
also have several design requirements. Clearance
requirements for vertical fixed ladders include:
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Maintain 7 inches clear from
the back of the climbing side
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Maintain 30 inches clear on
the climbing side
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Ladder heights exceeding 20
feet require installation of specifically designed cages
When fall prevention
guardrails or other systems are not available, personal
fall arrest systems may be required to ensure employees
are not exposed to falls from heights. Personal fall
arrest systems include 3 parts: anchorage connector,
connecting devices, and body wear. The design, use, and
care of each of the three parts are all integrally
important. Even though all 3 parts may be in place, if
equipment is defective, not properly matched, or employees
are not trained to use it correctly, the equipment can
fail. Examples of situations where failure of fall arrest
systems can cause injury or death may include:
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Frayed or corroded lanyard
connecting devices
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Worn mechanics of double
locking mechanism
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Connection points less than
5,000 lb. rating per person
-
Wrong equipment selected for
a particular situation
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Equipment not worn properly
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Greater than 15 degree angle
from connection point
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Improper fall distance
calculation
Without a well developed fall
protection policy and program that includes training on
equipment use and inspection, these failures and others
are likely to occur.
Miller Fall Protection, a leading manufacturer of fall
arrest system points out: “the manufacture and sales of
fall protection products have steadily grown over the past
decade, however the number of injuries and deaths
associated with falls from heights has also increased.”
Some argue that fall arrest systems give the worker a
false sense of protection. This is the typical argument
from those who are not trained on the proper use and care
requirements of the equipment. Fall arrest systems, when
used and cared for properly, will provide the protection
as intended, meaning it will prevent someone from
being seriously injured or killed.
Of course, it should not go
unmentioned that the majority of falls causing injury in
general industry occur at ground level where most of the
work happens. The cause of falls at ground level may be
due to poor housekeeping and maintenance issues, but often
are caused by lack of attention, bad habits or personal
health issues. Considering this, it is important to
inform employees of precautions that they must take to
prevent falls and maintain safe work areas. Many of
these are common sense items and include:
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Shoes should be firmly
fastened, fit your feet properly, and have non-skid
soles and other weather specific features.
-
Always hold the handrail
while on stairs. When carrying items that require both
hands, use the elevator instead of the stairs.
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Wear your glasses or
contacts. Proper vision is important in recognizing
slip, trip, and fall hazards and in reducing fall
injuries.
-
Clear walkways of clutter,
debris or other hazards.
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Clean up spills as soon as
they occur or are noticed.
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Keep phone and electrical
cords out of the path of travel.
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Have furniture arranged so
that it is not an obstacle.
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Remove ice and snow from
walkways and steps as soon as possible.
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Make sure that areas where
people walk are well lit.
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Secure area rugs with carpet
tape and install non-skid mats or other non-slip
surfaces in tubs and showers.
In order to ensure compliance
with Subpart D, it is recommended that each facility
develop a policy and program to ensure new installations
meet all regulatory and code requirements and that
existing equipment and work areas are frequently inspected
and maintained to be in a safe working condition.
Facilities should have an experienced safety professional
or trained safety committee responsible for auditing the
company’s compliance with Subpart D regulations and
implementing and maintaining the specific requirements of
the company’s program.
*OSHA General Industry Subpart
D - Walking working Surfaces – Specific references for
consideration:
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1910.21 Definitions used in
Subpart D
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1910.22(c) requires guarding
to protect workers from the hazards (falls) of open
pits, tanks, vats, ditches, etc.
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1910.23 (a) and (b) requires
guarding for stairway floor openings, ladder way floor
openings, hatchway floor openings, chute floor openings,
skylight floor openings, infrequently used pits,
trapdoor floor openings, manhole floor openings and
temporary floor openings, regardless of depth
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1910.23 (b) requires every
wall opening from which there is a drop of more than
four feet to be guarded
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1910.23 (c) requires every
open sided floor, platform or runway 4 feet or more
above the adjacent floor or ground level to be guarded
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1910.23 (c)(3) requires open
sided floors, platforms or runways, regardless of
height, that are above or adjacent to dangerous
equipment to be guarded.
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1910.23 (d) requires
guarding on open sides of every flight of stairs having
four or more risers
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1910.24 requires guarding on
the open sides of exposed fixed industrial stairways and
stair platforms (4 or more feet above adjacent floor)
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1910.25 and 26 cover the use
of wooden and metal ladders and do not contain any
specific requirements for fall protection or prevention,
but do limit the height of specific types of ladders
that can be used
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1910.27 requires all landing
platforms for fixed ladders to be guarded
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1910.27 allows workers to
climb fixed ladders (to any height) without fall
protection when guarded landing platforms are provided
for each 20 feet of height or fraction thereof
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1910.28 requires all
scaffold platforms to be guarded when they are 10 feet
or more above the ground or floor
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1910.29 requires that
manually propelled mobile ladder stand platforms and
mobile work platforms with work levels 10 feet or more
above the ground be guarded
For
further information or if you need assistance with your
fall protection program, please contact Geoff Gilbert at
Capaccio
Environmental Engineering, Inc. at
508.970.0033 x142 or by email at
ggilbert@capaccio.com.
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