Connecticut Department of Transportation
Division of Occupational Health & Safety
Fall Protection Program
October 1999
Connecticut Department of Transportation
Division of Occupational Health and Safety
Fall Protection Program
Introduction
Each year 300,000 American workers are disabled in work-related falls. According to the National Safety Council, falls are one of the leading causes of death in the workplace. Besides this tragedy there are countless millions of dollars lost in terms of productivity, worker's compensation, product liability, and fines from regulatory agencies related to falls.
Scope and General Application
The CONNDOT Fall Protection Program (FPP) incorporates all elements and standards established by OSHA, including but not limited to, 29 CFR 1910 & 1926. Application of the appropriate standard depends largely upon the type of work being done and conditions that exist at the time of the operation. In very general terms, anytime an employee is exposed to the hazard of falling six feet or more fall protection must be in place. The types of fall hazards can be very diverse. Some of the more common types of fall hazards that CONNDOT operations encounter include: Bucket trucks, roofs, raised structures such as bridges or towers as well as excavations or trenches. In general, work requiring fall protection can be broken down into two categories:
Construction – 29 CFR 1926 Construction Industry Standard, which would include:
New construction projects
Large-scale renovations
Extensive repair of existing facilities, structures or other systems
Facility, Highway System Maintenance – 29 CFR 1910 General Industry Standard, which would include:
Routine facility maintenance (including system replacement)
Bridge and other raised structure maintenance
Roadside maintenance including tree and electrical work
Excavations
29 CFR 1910 and 29 CFR 1926 are two very broad standards, however they are not all encompassing. If specific requirements are not outlined in one standard then another standard may be applied. Additionally, there are other standards that may be applicable depending upon conditions such as, 29 CFR such CRF 1915 – Shipyard Employment, CFR 1917 – Marine Terminals and CFR 1918 Longshoring. Contact the Division of OHS for further assistance.
A more in-depth outline of the requirements of each standard are discussed later in the program.
This program shall apply to all employees on all CONNDOT operations where employees are exposed to a fall hazard in excess of six feet. The requirements do not apply to individuals making an inspection, investigation or assessment of workplace conditions prior to the start of maintenance or construction work, unless the supervisor or the Division of Occupational Health and Safety (OHS) deems it necessary.
General Responsibilities
Management / Supervision
1.Support of the written Fall Protection Plan (FPP).
2.Appropriate the necessary resources required to implement the plan.
3.Assure that employees covered by the plan receive the necessary training.
4. Assure that all necessary fall protection equipment is provided and maintained in a good state of repair.
5. Enforce all established regulations, safety guidelines and provisions of the Fall Protection Plan.
6.Identify the activities and locations where fall hazards exist within their jurisdictions.
CONNDOT Division of Occupational Health & Safety
1.Develop, maintain and review the FPP periodically to determine if revisions are necessary.
2.Provide guidance and technical assistance to supervisors regarding the FPP and the application of the regulations.
3.Promote Agency wide compliance with the OSHA Regulations.
5.Provide a means by which supervisors and employees can direct suggestions, complaints, and concerns regarding the CONNDOT Fall Protection Program.
Employee
1.Participate willingly in all training programs offered by the Agency and learn as much as possible about the Fall Protection Program.
2.Abide by all regulations and safety guidelines and apply to the fullest extent possible the safety and health precautions specified by the Agency.
3.Report any problems that are observed which could compromise health and safety to his or her immediate supervisor.
4.Maintain all equipment and perform all required inspections to his or her fall protection equipment to ensure a safe and sanitary operating condition.
5.Ensure that no other individuals are exposed to fall hazards based on the operations being conducted.
Failure to Follow the CONNDOT Fall Protection Program
All employees who are exposed to a fall hazard shall follow the program and any safety policies, procedures, guidelines or training requiring fall protection. If there is a question regarding a specific fall protection situation, consult your immediate supervisor. Failure to follow the basic guidelines of the Fall Protection Plan may result in disciplinary action. Each supervisor that has employees covered by this program shall take the necessary disciplinary action for employees who knowingly violate the plan.
Construction Standard 1926 Subpart M – Fall Protection
The construction standard applies to CONNDOT operations that are generally major in nature. This would include new building or highway construction projects, major building renovations, bridge work where extensive repair work is required or other similar types of activities. 1926 would not include those operations that would be considered routine in nature.
The requirements within 1926 are very comprehensive and address a wide variety of fall protection issues. These issues include:
Section 1926.501 sets forth those workplaces, conditions, operations, and circumstances for which fall protection shall be provided except as follows:
(i)Requirements relating to fall protection for employees working on scaffolds are provided in subpart L of this part.
(ii)Requirements relating to fall protection for employees working on certain cranes and derricks are provided in subpart N of this part.
(iii)Requirements relating to fall protection for employees performing steel erection work are provided in 1926.105 and in subpart R of this part.
(iv)Requirements relating to fall protection for employees working on certain types of equipment used in tunneling operations are provided in subpart S of this part.
(v)Requirements relating to fall protection for employees engaged in the construction of electric transmission and distribution lines and equipment are provided in subpart V of this part.
(vi)Requirements relating to fall protection for employees working on stairways and ladders are provided in subpart X of this part.
Section 1926.502 sets forth the requirements for the installation, construction, and proper use of fall protection required by part 1926, except as follows:
(i)Performance requirements for guardrail systems used on scaffolds and performance requirements for falling object protection used on scaffolds are provided in subpart L of this part.
(ii)Performance requirements for stairways, stair rail systems, and handrails are provided in subpart X of this part.
(iii)Additional performance requirements for personal climbing equipment, lineman's body belts, safety straps, and lanyards are provided in Subpart V of this part.
(iv)Section 1926.502 does not apply to steel erection activities. (Note: Section 1926.104 sets the criteria for body belts, lanyards and lifelines used for fall protection in steel erection activities. Paragraphs (b), (c) and (f) of 1926.107 provide definitions for the pertinent terms).
Section 1926.503 sets forth requirements for training in the installation and use of fall protection systems, except in relation to steel erection activities.
When CONNDOT operations involve construction activities, the preceding requirements must be addressed on a case by case basis.
General Industry Standard 1910
The General Industry Standard incorporates a wide variety of work practices and operations. Set up a bit differently from the Construction Standard, 1910 addresses specific operations and fall protection required for those operations. Instead of having one all encompassing standard such as in 1926, 1910 contains numerous standards, many of which have fall protection components. Listed below are some of the more frequently encountered standards by CONNDOT.
29 CFR 1910
Subpart DWalking and Working Surfaces
Subpart FPowered Platforms, Manlifts, and Vehicle-Mounted Work Platforms
Subpart JGeneral Environmental Controls
Subpart RSpecial Industries
Each one of these standards has specific fall protection requirements that must be applied. The Supervisor must be familiar with the regulations that apply to their specific operations and take steps to meet them. The Division of OHS will assist supervisors in developing solutions to their operational fall protection issues.
In addition to these requirements, other specialized operations that CONNDOT may be involved in would be covered under other sections of 29 CFR such CRF 1915 – Shipyard Employment, CFR 1917 – Marine Terminals and CFR 1918 Longshoring. Contact the Division of OHS for further assistance.
Fall Protection Selection
Prior to the selection of any fall protection system the supervisor must evaluate the operation and apply the correct standard. They also have to evaluate the strength of the walking/working surface and the potential for a fall greater than six feet. The walking/working surface shall be capable of supporting all expected loads, including any required safety factor. OSHA generally encourages the selection of engineering controls first when attempting to control a hazard. Specifications for individual fall protection elements such as guardrail systems are included in the standards.
Facility Specific Fall Protection Plans
Facilities where employees are required to be exposed to a potential fall of 6 feet or greater must have a written fall protection plan in place. If engineering controls, such as a guardrail system are not feasible to protect the employee, then personal fall arrest equipment shall be used. All sites where an employee is required to approach or work within 10 feet of the fall hazard shall be protected by a fall protection system. The following requirements shall also be incorporated as a part of all plans:
- All facilities where there is the potential for an employee to fall six feet or more shall have a written Fall Protection Plan in place.
- All facility specific written fall protection plans shall be maintained at the facility as well as by Property & Facilities with copies sent to the Division of OHS.
- The plans shall be reviewed by the supervisor for applicability and shall be updated as conditions warrant.
- All effected employees shall be trained in the requirements of the plan and any equipment they are required to use.
- Any vendors, contractors or other personnel shall be informed of the fall protection requirements of the facility.
Positioning Devices
Positioning devices, such as belts, are not recognized as fall protection equipment and will not be used for such. Combination, fall protection and position devices are available from some manufacturers. Section 1926.502 (e) contains positioning device requirements. Note the strength and snaphook requirements for positioning devices.
Personal Fall Arrest Equipment
Personal fall arresting equipment shall be purchased through the current Agency vendor. The equipment is tested as a system and substitution of equipment from another manufacturer of personal fall protection equipment could result in a component or system failure. It is important to realize that components from a single manufacturer may not be compatible for all types of fall protection equipment. Personal fall arresting equipment shall be used only for this purpose. Personal fall arresting equipment and associated system components are designed for a combined weight (employee plus tools, etc.) of 310 lbs. If the combined weight exceeds 310 lbs., system modifications may be necessary.
In most situations the anchor point should be located near or above shoulder level. In selecting fall protection equipment consideration should be given to the possibility of injuries associated with "swinging" after the fall, retrieval and the location of where the individual will be after the fall.
Consideration must be given to conditions that could affect the performance of the equipment selected. The following is a short list of conditions that could adversely affect the equipment being used: temperature extremes, use of corrosive substances (solids, liquids or gases), welding/torch cutting, abrasive blasting, high moisture, grease/oil, and chemicals. Wire rope should never be used where an electrical hazard exists, nor should it be used without a shock-absorbing lanyard.
Safety belts are not acceptable for personal fall arresting equipment, but may be used for positioning only. Equipment designed for fall protection shall not be used for positioning.
Shock absorbing lanyards shall be used where possible. Lanyards, lifelines, full-body harnesses shall be protected against abrasion or cutting. Special beam wraps are available for anchor points that would cause a lanyard to abrade or be cut. Non-locking snap hooks are prohibited. Self-closing, self- locking keepers shall be used.
Training & Education
Each employee exposed to a fall hazard shall be trained to recognize the hazards and take action to prevent a fall. Initial training shall be completed prior to the employee being exposed to the hazard. Training shall be provided by a competent individual and shall cover at a minimum, the following topics:
a.The nature of the fall hazards in the work area;
b.The correct procedures for erecting, maintaining and disassembling and inspecting any fall protection system to be used;
c. The use and operation of guardrails, personal fall arrest systems, safety net system, warning line systems, safety monitoring systems, controlled access zones and other protection to be used;
d.The role of each employee in the safety monitoring system when this system is used;
e.The correct procedure for the handling and storage of equipment and materials and the erection of overhead protection; and
f.The role of employees in the fall protection plans;
g.The OSHA Fall Protection standard
A written certification shall be kept for each employee who completes the training. Only the most recently (up-to-date) certificate need be kept.
Retraining (refresher) training shall be provided when any one of the following exists:
1.Changes in the workplace or fall protection equipment that render previous training obsolete or,
2.If the individual demonstrates a lack of knowledge regarding the basic components of the Fall Protection Plan,
3.At intervals deemed acceptable by the supervision with a refresher in the form of a Tailgate Safety Talk at least annually. Records shall be kept in each units files.
Equipment Inspection
Any fall arrest equipment that has been subjected to a fall shall be discarded.
Equipment shall be maintained in accordance with the manufacturer's guidelines and inspected prior to each use.
As a part of the manufacturer’s guidelines the following should be checked:
D-rings - cracks, distortion, corrosion, pitting or excessive wear.
Buckles - distortion, sharp edges or cracks.
Body harnesses - burns, damaged due to chemicals, cuts, abrasion to the material. Broken stitches. One of the best ways to check the material is to hold sections of the material between the hands and bend the material into a U-shape to look for damage.
Keepers and snap locks - make sure they operate correctly. Do not rely on the sound of the latches, they must be connected.
Retractable lines - they should operate smoothly. The rope or cable should not be damaged. A quick pull of the line should cause the line to lock. The retractable lifeline assemblies shall be returned to the factory for recertification as specified by the manufacturer. In most cases, the manufacturer specifies an annual inspection. Check the date on the unit for the last certification.
Lanyards (rope, webbed or cable) - Look for cuts, frayed parts, damaged fibers, and the condition of connections. There should be no knots in the line. A knot can result in a substantial reduction in strength.
Shock Absorber - Check for ripped stitches, signs of impact loading and connections.
Posting of Fall Hazards
Fixed (non-transient) fall hazards that are routinely encountered should be posted with signs stating "Fall Protection Required." The sign(s) shall be posted at a location where the fall hazard is first encountered. If there are multiple entry points where the fall hazard is encountered, each location should be posted.
Fall Protection Considerations for New Construction and Renovations
All new construction must provide fall protection in accordance with applicable building codes. One factor that may be overlooked is the provision for fall protection during building maintenance. Provisions shall be incorporated into building design and construction for fall protection. Anchor points and cable or rails system for fixed ladders are two examples of overlooked features.