Preparing to Prevent Falls
Fall Protection Program
A construction Fall Protection Program is what you and your coworkers do to achieve and maintain a safe, healthful workplace. There are as many types of safety and health programs as there are
construction worksites, but not all programs are successful. What makes a successful safety and health program? There are seven elements:
- Commitment: All employees - including company executive officers, managers, and supervisors - are committed to making the program succeed.
- Accountability: All employees - including company executive officers, managers, and supervisors - are held accountable for following safe work practices.
- Involvement: All employees, including managers and supervisors, participate in making the program succeed.
- Hazard identification: All employees are trained to identify hazards, and there are procedures for conducting hazard inspections and reporting hazards.
- Accident investigation: Managers and supervisors promptly investigate all accidents and near misses and then determine how to eliminate their causes.
- Training: All employees receive training in identifying construction worksite hazards and learning safe work practices.
- Evaluation: Managers and supervisors, with help from other employees, evaluate the program's strengths and weaknesses at least once a year.
You may notice the element which usually results in more OSHA citations due to inadequate implementation is the training element. 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.
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 and healthful worksite, summarizes management and employee responsibilities,
and emphasizes the safety and health program's role in achieving that goal. 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.
OSHA offers the following definitions:
- The "competent person": A competent person is one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary,
hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. [1926.32(f)]
- The "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 his or her ability to solve or resolve problems relating to the subject matter, the work, or the project. [1926.32(m)]
Designate Competent Persons and Qualified Persons (Continued)
Choosing 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 construction worksite. The rules will tell you if you need to designate a competent or a qualified person.
- If an OSHA rule that applies to your construction worksite requires a competent or a qualified person, note duties and responsibilities that the rule requires the person to perform.
- If an OSHA rule that applies to your construction worksite 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.
Designate Competent Persons and Qualified Persons (Continued)
Duties and Responsibilities
The competent person
- Serves as the monitor in a safety-monitoring system and is responsible for recognizing hazards that cause falls and warning workers about them.
- Determines that safety nets meet minimum requirements.
- Inspects a personal fall-arrest system after it arrests a fall and determines if the system is undamaged and can be used again.
- Evaluates any alteration in a personal fall-arrest system and determines if the system is safe to use.
- Supervises the installation of slide-guard systems.
- Trains employees to recognize hazards that cause falls and to follow procedures that minimize the hazards.
The qualified person
- Supervises design, installation, and use of horizontal lifeline systems to ensure that they can maintain a safety factor of at least two - twice the impact of a worker free-falling 6 feet.
- Supervises design, installation, and use of personal fall-restraint anchorages.
- Supervises design, installation, and use of personal fall-arrest anchorages.
This photograph shows the two-story home workers were framing when the accident occurred. Photo: Courtesy: NCDOL/OSH
(Click to enlarge)
On September 5, 2006, a 30-year-old construction laborer (the victim) was fatally injured when he fell through a floor opening to a concrete floor approximately 10 feet, 10 inches below.
The victim had spent the majority of his work shift cutting plywood sheathing and handing it up to coworkers who were sheathing the roof. He was working from the second floor of a
two-story, single-family home under construction where he and other workers had completed most, but not all, of the subfloor (plywood sheathing secured over floor joists) on previous workdays.
They had left a floor area open in an attic space where a walk-in closet was to be constructed later. At the end of the shift, the victim’s lead worker asked two workers to complete
the second story subfloor in the attic space. One of these workers joined the roofers to lay roofer’s felt. The other co-worker joined the victim and together, they cut two sheets of plywood sheathing
and placed them over the joists in the open area in the attic space.
They were not wearing fall protection. The co-worker reported he was looking down at the sheets of unsecured plywood sheathing trying to make the pieces fit into an opening that was
not square and when he looked up the victim was gone. The victim had apparently stepped onto a piece of the unsecured plywood sheathing that covered part of the floor opening, and when the plywood
sheathing pivoted on the floor joist, he fell through the opening.
- Ensure all employees are provided with and use appropriate fall protection when exposed to fall hazards.
- Ensure through employee training and job-site inspection that correct construction procedures, such as use of appropriate fasteners, are followed during all phases of construction.
- Develop, implement, and enforce a comprehensive, written fall protection program that, at a minimum, complies with applicable OSHA fall prevention standards.
- Assign a competent person to inspect the worksite before work begins to identify fall hazards and to determine the appropriate fall prevention systems for workers.
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