Fall protection (general requirements) consistently tops OSHA’s annual list1 of the most common safety violations cited across industries.
Other fall-related violations, like those related to ladders and scaffolding, are typically not far behind – in 2021, they came in third and fourth, respectively.
Falls are one of OSHA’s Fatal Four and among the most common causes of on-the-job injury and death. Even falls from a short distance can cause serious injury.
With the right protective equipment, training and fall protection systems, it’s possible for businesses to mitigate or even eliminate fall risks on their worksites. Mistakes in fall protection mean that workers can be left vulnerable, even with protections
“with the right protective equipment, training and fall protection systems, it’s possible to eliminate fall risks on worksites”
These are five of the most common fall protection mistakes, why they happen, and how businesses can avoid them when developing fall protection systems. With the right strategy, it is entirely possible to make falls much less likely, even on sites where the exposure of workers to heights is part of business as usual.
1. Lack of Fall Protection Systems
In some cases, the gaps in a site’s fall protection systems are particularly large. Basic protection may not be offered at all, potentially exposing workers to serious fall risks.
OSHA guidance is likely the best place to begin when determining the minimum necessary fall protection for a given site. According to OSHA requirements on fall protection2, employers must do the following to protect employees from falls, slips and related hazards:
- Provide fall protection systems to employees working at elevations of four feet in general industry, six feet in construction and eight feet in longshoring operations.
- (For employees working over dangerous equipment and machinery, fall protection must be provided regardless of height.)
- Guard every hole into which a worker could walk, using protective equipment like railings or floor hole covers.
- Provide a guard rail and toe-board around all elevated and open-sided platforms and floors.
- Provide the same protections around dangerous equipment and machinery.
- Provide working conditions free of known dangers.
- Keep floors in work areas both clean and dry.
- Source and provide fall protection PPE to workers at no cost.
- Train workers on fall protection and hazards.
Additionally, certain hazards may require the use of specific safety equipment – like safety nets, harnesses and lines, stair railings or handrails. Many businesses also provide protective hand equipment and clothing.
These items may not directly contribute to a site’s fall safety systems, but they can make these systems safer to use while also protecting workers from other hazards.
An audit of site safety will help employers understand how fall protection systems currently work, and where gaps in existing systems may need to be addressed.
“there should be employees dedicated to a regular and thorough inspection of all PPE currently in use”
This review will help site owners and managers ensure that basic protections are in place. A walkthrough can also help this team identify other potential safety hazards3 – like electrocution risks or hazardous materials, both of which are common construction site hazards.
These essential site protections can be grouped into three broad categories – planning, providing, and training.
Planning involves the review of the site and fall hazards to determine which protection must be offered. Providing means the supply of that protective equipment to employees. Training ensures that employees know how to identify and mitigate fall hazards, as well as how to use, install and disassemble these systems properly.
Missing any one of these three basic categories can render on-site fall protection systems ineffective or even useless. Ensuring that all three are met will mean that a company has provided the basic fall protection that will lay the foundation for effective on-site fall safety.
2. Systems aren’t Properly Maintained
On some sites, fall protection systems do exist – but they are not maintained, inspected, or repaired with any regularity.
While these systems should offer protection, normal wear and tear – like a rusted D-ring or worn stitching in a harness – can cause essential system equipment to fail suddenly during a fall, meaning that it will not provide fall protection when workers need it most.
Regular inspection, testing, maintenance, and repair can ensure that these systems provide protection – or, if a piece of equipment is on the verge of failure, workers can identify it and remove it from service.
Inspection of Equipment
Effective maintenance will require employee buy-in. Ideally, essential protection systems should be inspected before every use to ensure that the tool, harness, anchor, or other PPE item is functioning correctly and not damaged.
Employers that want to ensure their equipment is kept in the best condition possible should follow basic OSHA requirements for safety equipment4, as well as best practices for inspecting and testing that equipment.
OSHA specifically recommends that workers should inspect their own harnesses before each use for signs of visible wear, deterioration, and damage. If a system or piece of equipment shows any of these defects, the worker must discard it.
A system or procedure for disposing of damaged PPE and receiving a new or non-damaged replacement can help streamline this process. These systems can also ensure that damaged items are captured and stored properly for repair – rather than discarded – if repair is a possibility.
A five-step inspection process will help workers catch many of the common issues that fall protection systems develop over time:
- First, workers should inspect metal components – like D-rings – for signs of wear, deterioration, or damage.
- Next, the workers should check for loose stitching and webbing. Stitching holds harnesses and other essential pieces of equipment together, and stitching that is starting to fall apart could make a piece of PPE dangerous.
- Workers should then inspect ropes for frayed edges, loose strands, and other signs of damage.
- In the event of a fall, workers should inspect personal arrest systems and similar equipment for damage.
- Once this inspection is complete, workers should discard and repair or replace damaged equipment as needed.
Requirements for Testing Equipment
OSHA also outlines specific requirements for how fall protection equipment must be tested. These requirements are slightly different for construction compared to general industry.
The most significant difference is in the length of free fall the positioning system allows.
For general industry, with the exception of window cleaners, the positioning system must pass a 250-pound four-foot drop test. Fall arrest systems must prevent a six-foot free fall.
Construction industry requirements are somewhat different. Instead, workers must have a means of stopping their fall or preventing it whenever they work six feet above a lower level. The same protection must also be provided to employees or contractors working above dangerous equipment.
In certain cases, a site may be exempted from fall protection requirements in certain cases – like when workers inspect a site prior to the installation or after the removal of fall protection systems.
While safety or body belts may be used as part of a suite of fall protection equipment – like a positioning device that prevents workers from falling more than two feet – these devices can’t be a worker’s only means of personal fall arrest.
Reactive maintenance can appear more cost-effective than preventative maintenance, but there are long-term costs associated with the inspection or repair of fall protection systems only as needed.
Effective maintenance strategies will be preventative. Ideally, there should be employees dedicated to a regular and thorough inspection of all PPE currently in use.
If workers spot signs of wear or damage during these inspections, many OEMs offer repair or replacement services that will allow a business to service or replace damaged components and equipment.
3. Workers Lack Training
Fall protection systems aren’t enough on their own. Workers also need to know how to properly use these systems, inspect them, and take advantage of the protection they offer.
As with fall protection systems themselves, OSHA also regulates the training on fall protection5 that workers should receive.
To start, employers must provide a training programme for each employee that might be exposed to fall hazards.
The programme must enable the worker to recognise the hazards of falling and the procedures they will follow on-site to minimise these hazards.
This training must be conducted by a trainer competent in the area of fall hazards and protection, and must include several key elements:
- The nature of fall hazards in the work area or job site,
- The correct procedures for installing, maintaining, dissembling, and inspecting fall protection systems,
- The use and operation of different fall protection systems (including guardrails, personal fall arrest systems, safety nets, warning lines, safety monitoring technology, controlled access zones and other protection to be used),
- And the role that each employee plays in using and operating these systems,
Certain businesses, depending on the type of work their employees perform, may also be required to include additional elements in their training programmes, like an explanation of the limitations of safety equipment provided on-site.
All of this training should be documented so that employers can verify worker compliance with training standards. Training documentation should include information like the identity of each employee trained, the date of the training and the signature of the person who conducted the training.
“without regular retraining, knowledge on safety systems may be rendered obsolete by changing equipment, regulations, or on-site practices”
Retraining and Regular Refresher Courses
Like equipment, training requires maintenance. Without regular retraining, employees may have knowledge on how to use safety systems that is rendered obsolete by changing equipment, regulations, or on-site practices.
In some cases, safety knowledge may also be simply forgotten without regular use. Best practices related to systems not used on a daily basis may be particularly easy to forget.
Retraining must be performed whenever an employer believes that employees no longer have the knowledge they need to properly use site safety equipment. For example, a company may adopt a new safety system that workers haven’t used before – requiring training in the new system.
Another employer may determine that one or more employees have inadequate knowledge of the protective systems that they use on-site, requiring additional training or retraining.
OSHA designs and provides a wide range of training materials that businesses can use to keep employees informed. These resources include fact sheets, posters, and similar materials that trainers can use to illustrate talking points or break down safety topics. Safety posters can also provide workers with helpful safety reminders if posted visibly around the workplace.
When designing a training programme for employees, businesses can take advantage of these resources to streamline course development and ensure that trainers cover essential fall safety topics.
4. Equipment is Improperly Deployed or Misused
In some cases, safety equipment is available and workers have been trained in how to use it – however, the actual installation of the equipment is wrong, potentially increasing the risk of system failure.
For example, a site may use an anchorage of inadequate strength6 for a user, potentially putting that user at risk of a fall. On another site, workers may incorrectly connect anchorages. If there is not an uninterrupted load path between the anchor and the fall path of the worker, the system may not provide protection to a worker in the event of a fall.
Correct placement of anchorages and effective fall protection system design are both necessary to ensure that adequate fall protection is offered to workers. Otherwise, the cost of these systems – including resources invested into maintenance and repair – will go to waste.
Testing fall protection systems is a good way to ensure that they provide the protection your workers need as they are installed.
OSHA also regulates the testing of fall protection systems. For example, OSHA standard 1910.27(b)(1)(i)7 states that:
“Before any rope descent system is used, the building owner must inform the employer, in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds (2,268 kg), in any direction, for each employee attached.”
In addition to the testing requirement, OSHA also regulates the frequency of testing and who may test these anchorages:
“The information must be based on an annual inspection by a qualified person and certification of each anchorage by a qualified person, as necessary, and at least every 10 years.”
Testing to meet OSHA guidelines on safety systems can help a site owner ensure that fall protection systems are not only installed, but installed in a way that will provide full protection in the event of a slip or fall.
5. The Right Protection isn’t Offered
Businesses may sometimes appear to have a robust safety system that helps protect workers from falls and similar safety risks. However, the systems that they have in place don’t provide full or proper protection to workers – meaning they may still be at risk.
This safety equipment may be insufficient or just poorly suited to the safety needs of workers on a particular jobsite.
Safety audits and reviews are one strategy that businesses can use to identify inadequacies in a site’s fall protection systems.
Testing can also help a business identify potential safety gaps that appear when systems aren’t well-suited to the hazards present on a site.
Maximise Site Fall Protection
Fall safety violations are some of the most common cited by OSHA. While falls are particularly common in construction, industries of all kinds may need to protect workers from fall hazards.
Simple best practices and compliance with OSHA standards can help ensure worker safety when heights create workplace fall risks. Regular inspection, training and testing are particularly important.
These practices will help employers ensure that the PPE and safety systems they purchase are a good fit for their particular jobsites, and that their employees know how to use these systems correctly. Preventative maintenance will also be important. Repairing damaged fall protection systems before existing issues become serious can extend the lifespan of these systems and reduce the risk of sudden failure.