Environment, Health and Safety

High Risk Work Program

Attachment 5: Fall Protection Program Site-Specific Template

Location Name: / Prepared By: / Date Effective: / Revision No.:
1

Operation Name: ______

Area: ______

Approved By: ______

Signature of Site/Department/Area Manager

1.Purpose and Scope

1.1The purpose is to establish the (insert site or organization name) site’s procedure for fall protection.These minimum fall protection requirements apply to all personnel involved in operation, maintenance, inspection, and construction activities at the site.

1.2The scope or coverage of the Fall Protection Program includes: (enter a description of the site, plant, operational unit, research area, or building covered by this procedure).

2.Responsibilities and Accountability

2.1The person accountable for the written Fall Protection Program is: (insert name and/or job title and telephone extension).

2.2Authorized Personnelare responsible to:

  • Understand Fall Protection Program requirements
  • Complete all required training and comply with this procedure
  • Request clarification from Competent person or EHS Staff when fall protection requirements or methods are not fully understood before initiating work activity
  • Understand the use, maintenance and inspection of fall protection equipment prior to use
  • Recognize approved anchor points

2.3Line Management is responsible to:

  • Implement the site fall protection program and promote engineering controls, where feasible
  • Provide necessary resources for required equipment and personnel training
  • Verify that fall protection procedures and permits are implemented for elevated work
  • Integrate Fall Protection requirements into writtenconstruction and maintenance documents and/or departmental procedures
  • Monitors Merck andcontractor personnelactivity to verify compliance with established work practices and training requirements

2.4Construction Project Management Teams are responsible to:

  • Establish the project specifications in the written contract prior to the bidding process, including the approved methods andtemporary measuresof fall protection during eachphase of the project (e.g.steel erection, scaffolding, use of ladders, etc.).
  • Communicate fall protection methods to be used prior to the commencement of work to affected personnel
  • Designand/or verify installation of fixed and engineered fall protection controls for all new, modified and renovated facilities

2.5Site Contractors are responsible to:

  • Work in conjunction with the Merck Engineer/Supervisor or designated alternate (e.g., Construction Manager) to establish fall protection methods/procedures
  • Develop and implement a project-specific fall protection program meeting the Merck Fall Protection requirements
  • Assignpersonnel who are properly trained in the use of fall protection equipment/systems and provide training documentation to Merck
  • Verify compliance with established work procedures and safety requirements

2.6Site EHS is responsible to:

Provide technical supportand guidance on the application of control measures.

Assist with periodic program assessments and confirm the site program complies with local regulatory requirements and requirements defined in this procedure.

3.Procedure

3.1Routine Elevated Work

Where routine elevated work is performed, engineering controls are implemented to control fall hazards. All routinely accessed elevated work surfaces with an elevation difference greater than 1.2 meters (4 feet) , sloped surfaces, and surfaces adjacent to dangerous equipment havea standard railing (top, midrail, and toe board) system on every open side. If guarding is not feasible, other permanent engineered fall protection systemsare implemented and managed by standard operating procedures (SOP). This is accomplished by: (site to specifythe method)

3.2Non-Routine Elevated Work

Where non-routine elevated work is performed, procedural and permit controls are implemented in accordance with the site's Elevated Work Permit. Fall protection includes methods described in sections 3.4 through 3.9, may be used in conjunction with a permit.

3.3Hierarchy of Controls

The following hierarchy of controls is used to eliminate or control fall hazards in new and existing facilities and equipment:

  1. Elimination: For routine operations and maintenance, fall hazards are eliminated (by relocating equipment or controls to eliminate the need to access locations with fall hazards) or the risk is reduced by engineering controls (standard railings, equipment placement).
  1. Passive Fall Protection: Isolating or separating personnel from the fall hazard.
  2. Active Fall Protection:
  3. Fall Restraint: Securing to an anchor point using a lanyard designed to prevent personnel from reaching an unguarded edge.
  4. Personal Fall Arrest System (PFAS): Protective equipment required in the absence of permanent engineered fall protection system.
  5. Administrative Control -Work practices or procedures that signals or warnsauthorized person to avoid a fall hazard.

Applicability to Maintenance and Repair and Construction Activities

All work performed by Merck or other personnel supporting maintenance and repair activities implement fall protection requirements and controls at or above the 4 feet/1.2 meter fall hazard elevation.

All work supporting construction and installation activities observe the same fall protection requirements and controls, unless a higher elevated not to exceed 6 feet/2 meters is permitted by local regulations and the work is conducted in an area completely segregated from Merck personnel or personnel performing maintenance and repair for Merck.

3.4Guardrail Systems

All elevated work platforms must have a guardrailsystem around the entire periphery. Design of permanent guardrail systemmust be in accordance with local, state/provincial and national regulations and Merck Engineering Design Guides. In the absence of local regulations, or when local regulations are less stringent the following minimum requirements apply:

  • Guard railing systems must include a toprail around the upper periphery. The height of the toprail above the platform must be 1.07m +/- 0.08m (42 inches +/- 3 inches). The guardrail must include a midrail approximately midway between the toprail and the platform surface. Each toprail, midrail or equivalent vertical barrier must withstand a concentrated test load of 91 kg (200 pounds) applied at any point in all directions.
  • Flexible materials such as cables, chains, and ropes may not be used in the railing system, except as a midrail at access openings 0.76m (30 inches) wide, or less.
  • Platforms must include toeboards on all sides. The minimum toeboard height is 10 cm (4 inches). Toeboards may be omitted at the access opening(s).
  • Design of temporary guardrail systems must be in accordance with Merck Engineering Design Guides. Temporary systems must be constructed of suitable materials, including wood, pipe, cable, etc. Non-metallic rope is prohibited. Wire rope is only allowed for construction applications.
  • General Requirements for Guard railing Use
  • Personnel must not climb on or lean over the guardrail systems.
  • Guardrail systems may not be used as anchor or tie off points.
  • Any break or opening in the guardrail system (i.e., fixed ladder access point) must be protected with a self closing gate.
  • Where falling objects present a hazard to persons below, additional screening between the midrail and toe board may be required.

3.5Personal Fall Arrest Systems

Personal Fall Arrest Systems must comply with all local, state/provincial and national regulations and manufacturer’s recommendations for inspection, use and storage. If local regulations do not exist, then the American National Standards Institute Z359.1-2007 standardmust be used.

Personal fall arrest systems (PFAS) have three key components:

  • Body Wear: Support equipment worn by the user
  • Connecting Device: Device used to connect the body wear to the anchor point
  • Anchor Point: Secure point of attachment for the connection device

Body Wear

Body wear consists of a full body harnessmade from light and heat-resistant synthetic materials. Full body harnesses secure the legs, waist, chest and shoulders and are attached to a connecting device by the D-ring in the center of the back near the shoulders. The connecting device is connected to an anchor point.

The full body harness is the only acceptable type of body wear due to the distribution of force in the event of a fall and ability to suspend personnel in an upright position while waiting assistance.The use of body belts is prohibited for all fall arrest applications.

Connecting Devices

Connecting devices (safety lanyards, shock-absorbing lanyards, horizontal or vertical lifelines) connect the harness to the anchor point or as a connection device to a lifeline system. Lanyards are short lines made of rope, strap, webbing, cable or similar materials with connectors on both ends. Some lanyards have shock-absorbing features to provide additional force reduction (up to 80%) in the event of a fall.

When personnel detachandreattach a lanyard to a new anchor point, during movement either horizontally or laterally, the “Y” lanyard technique is required. Two safety lanyards are used, and the “first” lanyard must not be detached from the anchor point until the “second" lanyard is attached to the “new” anchor point. Detaching and reattaching a single lanyard is not permitted.

A retractable lifeline is a self-contained device linking the harness to the anchor point. The device is continuously taut, allowing the user to travel varying distances and directions while still attached to a fall protection device. As the user moves away from the device, the device lets out the lifeline and retracts as the user moves closer to the device. This system gives the user the ability to move in various directions within the safe working distance of the lifeline. If a fall occurs, a locking mechanism in the device stops the lifeline, which then acts as a fixed arresting system.

Vertical lifelines are used in conjunction with an attached fall arrest device, such as the rope grab, between the harness and the anchor point. A lifeline is suspended vertically from an anchor point located overhead. The user attaches the harness to the lifeline with a safety lanyard and the rope grab or similar fall-arresting device. This system gives the user the ability to move limited horizontal distances and different vertical heights when the system is adjusted. If a fall occurs, the fall-arresting device locks and the lifeline act as a fixed arresting system.

Horizontal lifelines are cables suspended horizontally between two fixed anchor points at a level even with or above the user. The user attaches the harness to the lifeline with a safety lanyard and fall arresting device. This system gives the user the ability to move horizontally the length of the lifeline. Provided the lifeline meets the proper rating, multiple users are allowed on the horizontal lifeline. If a fall occurs, the lifeline acts as a fixed arresting system.

A proper attachment toanchor points is essential. Use of knots is not permitted, and lifelines may not be wrappeddirectly around a support structure.

Anchor Points

Anchor points are secure points of attachment for the connection device of a fall protection system. Anchor points are structural elementslocated above or at the elevation ofthe user. Anchor points positioned above the user are preferable due to reduced distance of free fall. The connection to the anchor point is a direct connection with a locking snap-hook with a spring-loaded keeper, cross arm strap, eye bolt or other method to properly secure the connection device. The anchor point must be capable of withstanding a static force of 2,275 kg (5,000 pounds), increased by a factor of 0.2 (20%) for each additional lanyard.

Certified Anchor Points

  • Permanently designed anchor points are identified and documentation regarding the acceptability of the anchor points is maintained in local site files.
  • Anchor points have a minimum breaking strength of 2,250 kg (5,000 pounds) and are designed by a Competent Person.
  • Anchor points are certified by a Competent Person prior to initial use.
  • Permanently designed anchor points are visually inspected by Competent Person on an annual basis (or prior to use if time period between uses exceeds 1 year)for cracks, rusting or other signs of support deterioration.
  • Points are free of rough or sharp edges that can damage the connector or lifeline.
  • Points are positioned:
  • At a height to maintain free fall to 1.8 meters (6 feet) or less
  • At a height to prevent the user from contacting the ground or equipment below, accounting for free fall distance, deceleration distance and worker height
  • To prevent swing into surrounding structures or equipment in the event of a fall

Non-Certified Anchor Points

Anchor points including strong structural elements (e.g., steel beams) capable of supporting 2,250 kg (5,000 pounds) but are not designed or intended as permanent fall protection anchor points. These anchor points must be confirmed by a structural engineer and reviewed by a CompetentPerson prior to being used for fall protection. Suitable attachment devices (e.g. beam clamp) must be used.

Positioning Systems

Positioning fall protection systems are designed to hold or support the user at an elevated surface, typically in an activity where both hands need to be free to perform work. The positioning system is engaged each time the user leans back or rests. These systems are set up to allow for a maximum of 0.6 meters (two feet) of free fall.

Positioning systems do not provide complete fall protection therefore the system mustbe used in conjunction with a fall arrest system to provide complete fall protection.

Restraint Systems

Restraint fall protection systems are designed to physically restrain the user from reaching a point where a fall could occur. These systems limit the length of the connection device, or position the anchor point such that the user is prevented from reaching the point of the fall hazard. The effect is to eliminate the need for actual fall protection. Applications include working near the edge of an unguarded platform or roof.

Suspension Systems

Suspension fall protection systems are designed to lower and support personnel at an elevated height, typically for an activity where both hands need to be free to perform work. Suspension systems are set up to allow no potential for free fall.

Use of Personal Fall Arrest Systems

  • Equipment must be inspected prior to each use.
  • For positioning and fall arrest, an approved full body harness equipped with a D-ring in the center of the back near the shoulders must be used.
  • Approved lanyard of appropriate length must be used for positioning and fall arrest.
  • Shock absorbing lanyards must not be used for positioning purposes.
  • A lanyard must be connected at all times.
  • When repositioning is required, a second lanyard must be connected to the new connection point prior to disconnecting the first lanyard.
  • All connecting devices must be approved for intended use and of a self-locking design.

Inspection and Maintenance of Personal Fall Arrest System Components

Personal fall arrest system components (body wear and connecting devices)are inspected by the user prior to every use and replaced if found damaged or defective. Personal Fall Arrest Systems exposed to an in-service load (arresting a fall) must be immediately removed from service and discarded or re-certified by the manufacturer.

Personal fall arrest system components are stored in a clean area protected from exposure to sunlight, surface contamination, or wear and in compliance with manufacturer’s recommendations.

Periodic inspections of connecting devices must be performed by trained inspector as frequently as required by applicable regulations and manufacturer’s recommendations, but no less than annually. Inspection criteria include:

  • Body wear (harnesses) must be inspected for cuts, burns, chemical damage, abrasions, stretching, frayed fibers or edges, pulled stitches or other signs of wear.
  • Buckles, D-rings and grommets (harness hardware) must be inspected for proper function, elongation, distortion, loose components, rust, cracks, free movement or other signs of wear.
  • Safety lanyards must be inspected for cuts, burns, chemical damage, abrasions, stretching, frayed fibers or edges, pulled stitches or other signs of wear.
  • Safety lanyard hardware must be inspected for proper function, elongation, distortion, loose components, rust, cracks, free movement or other signs of wear or malfunctioning. Spring-loaded locking snap-hooks must be inspected for proper functioning, seating and closure.
  • Shock absorber (lanyard) must be inspected for any signs of wear affecting the functioning of the shock absorber. The shock absorber must be checked for signs of elongation or deployment of the warning flag.
  • Ropes and cables must be inspected for signs of cuts, burns, chemical damage, abrasions, stretching, frayed fibers or edges, rust, pulled stitches or other signs of wear.
  • Retractable lifelines and winches mustbe inspected for proper functioning.
  • All fall protection equipment found to be defective must be removed from service immediately until properly repaired or replaced. Equipment must only be repaired by a qualified person familiar with the fall protection equipment.

3.6Ladders

Portable Ladders

Portable ladders include step ladders and extension ladders. The primary purpose of portable ladders is for access to remote work areas where permanent access is not provided or feasible. Ladders are not intended to be used as a work platform, unless specifically designed and include a work platform. Ladder use is intended for non-routine access or inspection tasks or other tasks where three points of contact can be maintained or only broken for short durations. Personnel also remain within the plane of the ladder and do allow their waist line to be above the top step. When these conditions can not be met, a job safety analysis (JSA)/risk assessment is conducted to determine the most appropriate type of fall protection (e.g., work platform, rolling staircase with standard railing, etc.).

General Portable Ladder Use Rules:

  • Portable ladders are used in accordance with manufacturer's specifications
  • Users observed the “4-to-1” use rule to determine the proper ladder angle. For every four (4) feet the ladder extends vertically from the ground to the support point, the ladder base mustbe one (1) foot out horizontally from directly below the support point
  • Straight ladders over 1.8 meters (6 feet)are secured to a structural member to prevent the movement of the ladder. If the ladder cannot be secured, then additional personnel must be assigned to ensure that the base of the ladder remains secure
  • Stepladders (4 leg design) are permitted up to 3 meters (10 feet) in height
  • Movable platform ladders (4 leg design with wheels) are permitted to 8 meters (20 feet) and have side railings provided over 1.2 meters (4 feet).
  • Personnel working above 1.2 meters (4feet) must maintain 3 points of contact or implement additional fall protection measures.
  • Portable straight ladders are restricted to 8 meters (25 feet) in working height
  • Portable ladders, including step ladders, must be of non-conductive design
  • All ladders must be inspected prior to use for the following:
  • Missing or loose steps or rungs
  • Damaged or worn non-slip feet
  • Loose nails, screws, bolts or nuts
  • Loose or faulty spreaders, locks or other metal parts in poor repair
  • Cracked, split, worn or broken rails, braces, steps or rungs
  • Sharp edges on rails and rungs
  • Rough or splintered surfaces
  • Corrosion, oxidation and excessive wear, especially on treads
  • Rot, decay, or warped rails in wooden ladders
  • Cracks and exposed fiberglass
  • Distortion of the rails
  • Missing identification labels

Fixed Ladders