Fall Protection Program Elements
The Fall Protection Program – A System within a System
Believe it or not, all companies have safety management systems. And, as with every system, it has structure, behavior and results. In fact, you cannot NOT have a safety management system in
your company. The most efficient and effective safety management systems are very organized with comprehensive written details describing specific safety policies, plans, programs, processes,
procedures and practices. At the other end of the spectrum, the safety management system is unorganized, inefficient, ineffective, lacking direction, and very informal. It may appear that the
safety management system doesn’t exist in your company, yet it always does in some form.
To help us understand this principle, take a look at the image of Sissie the cow. You’re probably thinking, “What does a cow have to do with safety management systems?” Well, just read on.
Sissie the cow is actually a very complicated system that has structure, behavior, and results. You know Sissie is a cow because she has structure: she looks like a cow. If you watch Sissie
for a while, you’ll notice that she behaves like a cow: usually just eating grass all day. And finally, if you follow Sissie around, you’ll see that her behavior has results: basically she
eliminates waste and produces milk. Okay, how does Sissie the cow relate to safety management systems? Let’s take a look.
- Structure: It always exists, but what does it look like? It might be a little hard to describe the structure of a safety management system, but, just like Sissie the cow, it always has a
structure that ranges from extremely organized and formal to extremely unorganized and informal.
- Behavior: The resulting behavior of a formal safety management system differs greatly from the behavior we see in a safety management system that is informal. If you
watch collective behaviors
of managers and employees working within a formal safety management system, you’ll notice it’s quite different from resulting behaviors from an unorganized, informal system.
Fall Protection Program Elements
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:
- Commitment: All employees—including company executive officers, managers, and supervisors—are committed to making the Fall Protection Program succeed. An employer’s
attitude toward job safety and health is reflected by his or her employees. If the employer commits serious time and money into the Fall Protection Program, employees will see that and be
equally serious about safety.
- Accountability: Everyone in the company, from top management to each employee, should be held accountable for following fall protection policies, plans, processes,
procedures and safe work practices. To be held
accountable, performance is measured and consequences result. Employee safety performance is evaluated and one of three consequences result:
- It is rewarded. Safe performance is recognized and rewarded in some way.
- It is punished. When justified, unsafe performance should result in some form of reprimand or disciplinary action.
- It is ignored. Yes, ignoring performance is, itself, a consequence.
- Involvement: All employees, including managers and supervisors, should participate in making the Fall Protection Program succeed. Employee involvement helps ensure
employees gain some ownership in fall protection procedures and practices, so they’re more likely to use them when not being supervised.
- Hazard prevention, identification, and control: Employees anticipate potential fall hazards as they work throughout the day. Their awareness is such that actual fall
hazards are identified and reported. Employees are involved in controlling fall hazards by eliminating or substituting the hazards, changing processes and procedures, and using fall protection systems.
- Accident investigation: Managers and supervisors promptly investigate all fall accidents and near misses, and then determine how to eliminate their causes. They conduct
a thorough “analysis” for the express purpose of improving the safety management system, not assigning blame. Remember, fix the system, not the blame!
- Education and Training: All employees are educated about the fall hazards in the workplace and they receive training in how to safely accomplish tasks while working at
elevation, and how to properly use fall
protection equipment. The employer must provide training to each employee who is required to use fall protection. Each employee should be trained to know at least the following about fall protection:
- why it is necessary
- when it is necessary
- how to properly don, doff, adjust and wear fall protection
- the limitations of fall protection
- the proper care, maintenance, useful life, and disposal of fall protection
Each employee is required to use fall protection and, before being allowed to perform work requiring fall protection, each employee must demonstrate:
- an understanding of the training
- the ability to use fall protection properly
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 in lawsuits) 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.
- Analysis and Evaluation: Improving the Fall Protection Program using an effective analysis and evaluation process is one of the most important safety staff activities.
Managers and supervisors, with help from
other employees, should analyze and evaluate the program's strengths and weaknesses at least once a year. To do this, the employer should use these basic steps:
- Identify what you have.
- Compare what exists with what is known to work best.
- Make improvements as needed.
You can learn more about the elements of an effective safety management system in Course 700.
Prepare a Safety and Health Policy
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.
Take a look at a sample policy.
Designate Competent Persons and Qualified Persons
You'll find activities throughout OSHA's workplace safety and health rules that are required to be conducted by competent and qualified persons.
Competent person and qualified person are terms that federal OSHA created to designate individuals who have the training and expertise to evaluate hazardous conditions, inspect equipment,
evaluate mechanical systems, or train others how to work safely.
Who Can Be Competent and Qualified Persons?
The following definitions for competent and qualified persons are related to fall protection:
- Competent Person: A competent person is one who is capable of identifying existing and predictable fall hazards that are dangerous to employees, and authorized to stop work
and take prompt corrective action to eliminate them.
- Qualified Person: A qualified person is one who, by possession of a recognized degree, certificate, or professional standing or who, by extensive knowledge, training, and
experience, has successfully demonstrated the knowledge, skills, and ability to solve or resolve problems relating to fall protection at work.
Determining Who Can Be a Competent or Qualified Person
Although federal OSHA defines competent and qualified persons, it doesn't provide specifics for determining who can assume these roles. The following guidelines may help:
- Know the OSHA rules that apply to your workplace. The rules will tell you if you need to designate a competent or a qualified person.
- If an OSHA rule that applies to your workplace requires a competent or a qualified person, note duties and responsibilities the rule requires the person to perform.
- If an OSHA rule that applies to your workplace requires a competent person, that person must have the authority to take prompt corrective measures to eliminate hazards.
- Determine the knowledge, training, and experience the competent or qualified person needs to meet the rule's requirements.
- Designate a person who has the knowledge, training, and experience that meets the rule's requirements.
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.
- The equipment was not regularly inspected and maintained in safe operating condition.
- The bucket leveling cable, which kept the bucket level as the boom was raised and lowered, broke under the electrician’s weight, which caused the bucket to swivel.
- One of the electricians said that, from time to time, he had checked things on the truck, such as tires, lights, and oil and water levels, but had not performed a pre-operation
inspection or thorough periodic inspection on the digger derrick or the aerial boom lift.
- The company field superintendent said the truck had not been thoroughly inspected in over two years.
Source: Oregon OSHA 2014
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