OSHA is raising fines and promoting a robust Stop Falls outreach campaign, so this is no time for miscues related to fall protection. Fall protection has been the top OSHA violation for five years in a row, and the long-awaited update to the walking/working surfaces and personal fall protection system regulation that governs maintenance activities—29 CFR 1910, Subparts D and I—is in the final stages of approval with the Office of Management and Budget.
When it comes to falls, a split-second decision or a single step can lead to death, before anyone even realizes what happened. Here are a few tips to improve fall safety for workers and reduce the risk of OSHA fall protection violations:
1. Use less PPE (personal protective equipment): Harnesses and lanyards are some of the most visible aspects of fall protection, but they really should be a last resort. Using PPE means you haven’t removed the person from the hazard, or the hazard from the person. Plus, even if you provide the right equipment, there are still too many opportunities for failure: general misuse of equipment, inadequate fall clearance, improper anchorage and swing fall hazards. Look for ways to use passive controls that would force a worker to actively overcome the barrier.
2. Consider more than just roofs: Due to the obvious danger of falling off an unprotected roof edge, fall hazards associated with roof access and maintenance are typically acknowledged. Workers are likely to be exposed to several other fall hazards while performing routine maintenance in and around facilities, however, and many of these less obvious hazards may present even greater risk. Explore your facility for other fall-off or fall-through hazards, such as pits, mezzanines, modular offices, elevator shafts, retaining walls and landscaping areas.
3. Invest in training: When dealing with a subject this complex, only well-informed individuals can make the right decisions about fall protection. That’s why it’s critical to provide proper training for the people who supervise or use fall-protection systems. While the law simply requires that you provide training, the goal of fall-protection training should be to change behavior. To truly impact safety, training needs to include more than just generic instruction on regulations and equipment use. Find a training provider that can provide a customized training experience that will truly motivate your personnel to focus on safety. Hint: A mandatory 20-minute video isn’t likely to do that.
4. Maintain appropriate documentation: Proper management of a fall-protection program requires documentation to prove that key program elements have been addressed, including personnel training, equipment inspection and system re-certification. While this may seem like administrative paperwork, it is vitally important—effective training and systems can mean the difference between life and death. Regardless of whether you’re doing all the right things, the documentation you provide when OSHA visits will speak volumes about your focus on safety.
The spotlight on fall protection is only increasing as fall injuries and fatalities continue to rise. Although advanced equipment is more prevalent than ever, it’s clear that you can’t rely on just purchasing gear to ensure safety and compliance.
Kimberly Messer is the corporate marketing manager for LJB Inc., a consulting firm that provides civil and structural engineering, as well as safety and environmental services. She recently published the fiction book, Falling for Work: A Story of Death and Determination, to share her best practices for fall prevention and protection. She can be reached at KMesser@LJBinc.com.
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