A program is a planned, coordinated group of activities or procedures that have a specific purpose. It helps to think of the company's Fall Protection Program as one of the "subsystems" within the company's Safety Management System (SMS). It's a subsystem because, like any system, it contains interrelated elements that work toward a common goal. To help understand how systems work, let's take a short look the nature of systems in general.
A system is a group of interacting, interrelated, or interdependent elements forming a complex whole. All systems have structure, inputs, processes, and outputs. In terms of structure, the best systems are designed with formal (written) policies, plans, programs, processes, procedures and practices that produce intended results. However, systems may be structured in a very informal manner, and most likely result in inefficient and ineffective outputs. Either way, systems will produce only what they are designed to produce: they can't produce anything else.
To better understand systems, let's take a look at the image of "Syssie" the cow. You're probably wondering what a cow has to do with safety management system: just read on.
Syssie the cow is actually a very complicated system that, like all systems, has:
Like Syssie, a safety management system has:
The bottom line: There are two important things to remember about systems:
The challenge is to design, develop and deploy your system so that it is both efficient and effective.
The Fall Protection Program is just one part of the company’s much larger Safety Management System. And, as with all systems, it also has structure, behavior, and results.
There should be at least seven major elements in a successful Fall Protection Program. These seven major elements include:
Each employee is required to use fall protection and, before being allowed to perform work requiring fall protection, each employee must demonstrate:
It's important to know that the element which usually results in more OSHA citations is the failure to provide adequate fall protection training. If someone is seriously injured or dies as a result of a fall, OSHA compliance officers (and lawyers) will look long and hard at your training program because they know that it is the area that is more likely lacking in due diligence.
You can learn more about the elements of an effective safety management system in Course 700.
Does your company have a written safety and health policy? It should. A written policy reflects commitment to a safe, healthful workplace, summarizes management and employee responsibilities, and emphasizes the safety and health program's role in achieving that goal. It allows managers and supervisors to make decisions about working at elevation without having to check with the employer. Keep the policy brief, commit to it, and enforce it.
Business Policy. Our company is committed to achieving and maintaining a safe, healthful workplace for all its employees. We base our commitment on a safety and health program that involves all employees in the effort to eliminate or control workplace hazards. All employees, including managers and supervisors, will be held accountable for following this policy.
Management Responsibilities. Managers are responsible for preventing workplace injuries and illnesses and will consider all employee suggestions for achieving a safe, healthful workplace. Managers will stay informed about workplace hazards and will review the safety and health program at least once a year.
Supervisor Responsibilities. Supervisors are responsible for supervising and training employees to work safely. Supervisors must enforce safe work practices and correct hazardous conditions.
Safety committee responsibilities. The safety committee includes managers and other employees who are responsible for identifying hazardous conditions and unsafe conditions, and recommending how to eliminate, prevent, or control them. The committee is also responsible for helping managers review the safety and health program's strengths and weaknesses.
Employees' responsibilities. Our safety and health program achieves success through our employees. All employees are responsible for identifying and reporting hazards immediately to their supervisors or safety committee representatives, for following safe work practices, and for using required personal protective equipment.
OSHA rules require that competent or qualified persons to perform certain activities. They must have the training and expertise to evaluate hazardous conditions, inspect equipment, evaluate mechanical systems, or train others how to work safely. The following definitions for competent and qualified persons are related to fall protection:
Use the following guidelines to determine who might be eligible as a competent/qualified person:
Two journeyman electricians were relocating power poles to service job trailers at a landfill. They were using an older digger derrick truck that had a boom and an auger for drilling holes. The end of the boom had a motorized hoist for setting the poles and there were two side-by-side buckets on a separate onboard aerial work platform at the end of the boom.
At the start of the day, they drilled two holes for poles near a tall shop building and set the first of two 50-foot poles without incident.
They picked up the second pole using the hoist cable at the end of the digger derrick boom. A synthetic-fiber lifting strap was wrapped around the pole and attached to the hook. Another rope was attached to the eye of the strap so that the strap could be loosened from the ground. After they set the pole, one of the electricians was unable to remove the strap by tugging on it, so he decided to remove it from the aerial platform.
He climbed the onboard fixed ladder, grabbed the top of the bucket with both hands, and placed one foot on its outside lower lip. As he swung his other foot over the top of the bucket, it swiveled vertically and he fell, hitting parts of the truck and landing on the ground. His injuries included two fractured vertebrae and soft tissue.
Source: Oregon OSHA 2014
This WorkSafeBC video highlights the need for fall protection systems in the workplace. With dramatic footage of accidents and computer animation, this video outlines the steps to develop safe practices when working from heights.