NR-35 WORK AT HEIGHT. SIT Ordinance No. 313 dated March 23, /27/12

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1 Translation by Miguel C. Branchtein NR-35 WORK AT HEIGHT Publication Published SIT Ordinance No. 313 dated March 23, /27/12 Changes / Updates Published MTE Ordinance No. 593 dated April 28, /30/14 MTE Ordinance No dated September 24, /25/14 MTb Ordinance No dated September 21, /22/ Purpose and Field of Application This Standard establishes minimum requirements and protective measures for working at height, involving planning, organization and implementation, to ensure the safety and health of workers directly or indirectly involved in this activity Work at height is any activity performed 2.00 m (two meters) above the level below, where there is fall risk This standard is complemented by the official technical standards established by the competent Governing Bodies and, in the absence of these, by the relevant international standards Responsibilities It is up to the employer: a) To ensure the implementation of the protection measures laid down in this Standard; b) To ensure the realization of Risk Analysis - RA and, where applicable, the issuance of the Work Permit; c) To ensure the elaboration of the operational procedure for routine activities of work at height; d) To ensure the realization of a preliminary assessment of the workplace conditions, by the study, planning, implementation of actions and applicable additional safety measures; e) To monitor the compliance by contractors with the protection measures established in this standard; f) To provide the workers with up to date information on the risks and control measures; g) To ensure that any work at height will start only after adoption of the protective measures defined in this standard; h) To ensure the suspension of the work at height upon noticing any unforseen hazardous condition, whose removal or immediate neutralization is not immediately possible; i) To establish a system of authorization of employees to work at height; j) To ensure that all work at height is carried out under supervision, as defined by the risk analysis in accordance with the peculiarities of the activity;

2 k) To ensure the organization and archiving of the documentation in this Standard It is up to the workers: a) To comply with the laws and regulations on work at height, including the procedures issued by the employer; b) To cooperate with the employer in implementing the provisions of this Standard; c) To stop their activities exercising the right of refusal, whenever perceiving serious and imminent risk to their health and safety or that of others, communicating immediately the fact to his superior, who shall take steps appropriate action; d) Not to endanger other s safety and health Training The employer shall promote program for training workers to carry out work at height A worker trained for work at height shall have been approved in a theoretical and practical training, with a minimum of eight hours, whose curriculum shall at least include: a) Regulations applicable to working at heights; b) Risk analysis and hindering conditions; c) Risks inherent to work at height and their prevention and control measures; d) Collective protection systems, equipment and procedures; e) Personal protective equipment for work at height: selection, inspection, maintenance and limitations; f) Typical accidents in work at height; g) Conduct in emergency situations, including rescue techniques and first aid notions The employer shall conduct regular two-yearly training and whenever takes place any of the following situations: a) Change in work procedures, conditions or operations; b) Event indicating the need for further training; c) Return to work after a period exceeding ninety days; d) Company change The biennial periodic training shall have minimum workload of eight hours as content programmatic defined by the employer In the cases provided for in paragraphs "a", "b", "c" and "d", workload and program content They shall meet the situation that motivated The initial training, periodic and possible to work at a height may be taught in together with other training company The training shall preferably be done during normal working hours The time spent in training shall be counted as effective working time The training shall be taught by instructors with proven expertise in the subject, under the responsibility of a qualified professional in safety.

3 At the end of training certificate shall be issued containing the worker's name, programmatic content, hours, date, location of the training, name and qualifications of instructors and signature of the responsible professional The certificate shall be given to the employee and a copy filed at the company The training shall be recorded in the employee's record. 4. Planning, Organization and Execution The work at height shall be planned, organized and executed by trained and authorized worker It is considered authorized for work at height the worker that is trained, whose health state was assessed and deemed fit to perform that activity and has formal approval from the company It is up to the employer to assess the health status of workers at height, ensuring that: a) The medical examinations and the evaluation method are integral parts of the Occupational Health Medical Control Program - PCMSO and shall be registered therein; b) Evaluation shall be performed periodically, considering the risks involved in each situation; c) Medical assessment shall be aimed at diseases that can cause sudden illness and falls, and also consider the psychosocial factors The ability to work at height shall be registered in the occupational health attestation The company shall maintain up-to-date records registering the scope of the each employee s authorization for work at height In planning the work at height, measures adopted shall follow this hierarchy: a) measures to avoid work at height, whenever there are alternative execution means; b) measures to eliminate the fall risk; c) measures to minimize the fall consequences All work at height shall be carried out under supervision, the form of which is to be determined by the analysis risk according to the activity peculiarities The job execution shall consider the external influences that may alter the workplace conditions foreseen in the risk analysis All work at height shall be preceded by a risk analysis In addition to the inherent work at height risks, the risk analysis shall consider: a) The place where the services will be performed and its surroundings; b) Work area isolation and signage; c) Establishment of anchor points and anchor systems; d) Adverse weather conditions;

4 e) Collective and personal protective systems selection, inspection, use and limits, according to the current technical standards, the guidelines of the manufacturers and the principles of impact and fall factor minimization; f) The risk of falling materials and tools; g) Simultaneously done jobs posing specific risks; h) Compliance with other health and safety regulatory standards; i) Additional risks; j) Impeditive conditions; k) Emergency situations and rescue and first aid planning, as to reduce the worker inert suspension time; l) Need for communication system; m) Supervision form For routine work at height activities, the risk analysis may be contemplated in its operational procedure The operational procedures for work at height activities shall contain, at least: a) The task guidelines and requirements; b) The administrative guidelines; c) The details of the task; d) The risk control measures; e) The impeditive conditions; f) Collective and personal protection systems; g) The powers and responsibilities Non-routine work at height activities shall be previously authorized by Work Permit For non-routine activities, the control measures shall be established in the Risk Analysis and in the Work Permit The work permit shall be issued, be approved by the person responsible for authorizing, be available at the activity site, and finally, be closed and filed allowing traceability The Work Permit shall contain: a) Minimal requirements for execution; b) Provisions and measures set out in the Risk Analysis; c) A listing of all involved personnel and their authorizations The Work Permit shall have validity limited to the duration of the activity, restricted to one work shift and may be revalidated by the approver in case there aren t changes in the conditions or in the work team Fall Protection Systems (Updated by Ordinance MTb No. 1113, dated September 21, 2016)

5 Whenever work at height cannot be avoided, a fall protection system is mandatory The fall protection system shall: a) Be appropriate to the task to be performed; b) Be selected according to risk analysis, considering, in addition to the risks to which the worker is exposed, the additional risks; c) Be selected by a qualified safety professional; d) Withstand the maximum applied force during a fall; e) Meet national technical standards or, in their absence, international standards; f) Have all its elements compatible among themselves and submitted to systematic inspection The selection of fall protection system shall consider using: a) Collective fall protection system - CFPS; b) Personal fall protection system - PFPS: b.1) when it is impossible to adopt a CFPS; b.2) when the CFPS does not offer complete protection against fall risk; b.3) for emergency situations The CFPS shall be designed by a legally qualified professional The PFPS can of the following kinds: travel restraint, fall arrest, work position or rope access The PFPS consists of the following elements: a) Anchor system; b) Connecting element; c) Personal protective equipment Personal protective equipment shall be: a) Certified; b) Appropriate for the intended use; c) Used considering the usage limits; d) Adjusted to the worker weight and height The manufacturer or the supplier of PPE must provide information on its performance and usage limits, considering the total mass applied to the system (worker and equipment) and the other aspects set out in section Inspection of PFPS must be carried out upon acquisition and periodically, refusing its defective or deformed elements Before the start of the work shall be carried out a routine inspection of all PFPS elements The inspection results shall be recorded: a) Upon the acquisition;

6 b) On periodic and routine inspection when PFPS elements are refused PFPS elements that are defective, degraded, deformed or which have suffered a drop impact must be made impossible to use and discarded except when its restoration is possible according to national, or in their absence, international, technical standards and in accordance with the recommendations of manufacturer The PFPS shall be selected so that the impact force transmitted to the worker upon a fall is at most 6 kn Travel restraint anchor system shall be dimensioned to withstand the forces that may be applied Whenever, in accordance with the risk analysis, the occurrence of a fall with level difference is possible, the system shall be dimensioned as fall arrest In fall arrest PFPS and in rope access system, personal protective equipment shall be full body harness The full body harness, when used in fall restraint, must be connected by its fall arrest attachment point indicated by the manufacturer The use of fall arrest system that incorporates a guided type fall arrester shall meet the manufacturer's recommendations, in particular as to: a) Compatibility of the guided type fall arrester with the vertical lifeline; b) Maximum length of the connecting element The risk analysis set up in this standard shall consider in relation to the PFPS at least: a) That the worker must remain connected to the system during the whole period of fall risk exposure; b) The free fall distance; c) The fall factor; d) The use of a connecting element that ensures an impact limited to at most 6 kn is transmitted to the worker during fall arrest; e) The available clearance; f) Compatibility between the elements of PFPS The lanyard and the fall arrester shall be positioned: a) Whenever applicable, above the height of the PPE fall arrest attachment point; b) So as to minimize the free fall distance; c) So as to ensure that in case of fall the worker does not collides with the any lower structure The lanyard, except when specified by the manufacturer and considering its limitations of use, cannot be used: a) Connected to another lifeline, connecting element or length extender; b) With knots or ties Emergency and Rescue

7 The employer shall provide a team to respond to emergencies on work at height The team can be internal or external to the company composed by workers at height themselves, depending on the characteristics of activities The employer shall ensure that the team has the necessary resources for respond to emergencies The emergency response actions shall be included in the company emergency plan The rescue team integrants shall be able to perform the rescue, provide first aid and be physically and mentally fit for the activity. Glossary (Inserted by Ordinance MTb No. 1113, dated September 21, 2016) Energy absorber: element which limits impact force transmitted to worker by dissipating kinetic energy. Risk Analysis - RA: assessment of risks, causes, consequences and control measures. Structural Anchor: an element fixed permanently to the structure to which an anchor device or a PPE can be connected. Routine activities: usual activities, regardless of the frequency, which are part of company 's work process. Conformity assessment: demonstration that the requirements specified in a technical standard relating to a product, process, system, or person are met. Certification: certification by a conformity assessment body for products, processes, systems or people that the technical standard requirements were met. Certified: that was submitted to certification Full body Harness: Personal Protective Equipment used in work at height, consisting of support at the bottom of the chest, above the shoulders and on the thighs. Impeditive conditions: situations that prevent the completion or continuation of the service, as they endanger worker s health or physical integrity. Anchor device: removable device designed for use as a part of a personal fall protection system whose elements comprise one or more fixed or mobile anchor points. Braking distance: distance covered during the energy absorbing system activation, usually comprehended between the start of braking and the end of the fall. Free fall distance: distance covered between the beginning of the fall and the beginning of the fall arrest Attaching element: Safety harness element for the attachment of a connecting element Fall arrest attaching element: Attaching element designed to withstand the fall arrest impact force located on the dorsal or on the pectoral region. Fixing element: element intended to fix components of the anchor system with each other. Connecting element: element with the function of connecting the safety harness or belt to the anchor system, which may incorporate an energy absorber. Also called union component.

8 Ancillary equipment: equipment used in rope access beside the harness, the lanyard, the fall arrester and the rope, such as connectors, textile anchor rings or straps, pulleys, blocker, descender, ascender, among others. Structure: a natural or artificial structure that integrates an anchor system, able to resist the efforts of this system. Extender: Connection component or element of a sliding guided fall arrester. Fall factor: ratio between the free fall distance and the length of the connecting element that will arrest him. Impact force: dynamic force generated while arresting a worker fall. Maximum applicable force: Maximum force that can be applied to an anchor system element. External influences: variables that shall be considered in the definition and selection of protective measures, whose control is not possible to implement in advance. Assisted Operation: activity carried out under permanent supervision by a professional with knowledge to assess the risks and implement the measures to control, minimize or neutralize such risks. Work Permit: written document containing a set of control measures aimed at development of safe work, as well as emergency measures and rescue. Anchor point: part of an anchor system where personal protective equipment can be connected Anchor point: part of an anchor system to where personal protective equipment is connected Legally qualified professional: previously qualified worker with registration in the competent class council. Additional risks: risk factors specific to each environment or activity, in addition to those inherent to work at height. Rope access system: work system in which ropes are used as means of access and as fall protection. Work positioning system: work system configured to allow the worker to remain positioned in the work place, wholly or partially suspended, without the use of hands. Fall Protection System FPS: system designed to eliminate worker fall risk or to minimize the fall consequences. Travel restraint system: FPS that limits worker movement so that the worker is not exposed to any fall risk. Fall arrest system: FPS that does not prevent the fall, but stops it after its onset, reducing its consequences. Inert suspension: situation where a worker remains suspended by the personal fall protection system, to the time of rescue. Lanyard: connecting element for a safety system, adjustable or not, to support, to position and/or to limit the movement of the worker. Qualified worker: Worker certifying completion of course specific for his activity in an official education system recognized institution.

9 Fall arrester: safety device for user fall protection in activities that require vertical or horizontal traveling, when connected with safety harness. Clearance: region between the anchor point and the closest lower obstacle against which the worker might clash upon falling, such as the ground level or lower level. ANNEX I ROPE ACCESS (Inserted by Ordinance MTE No. 593, dated April 28, 2014)\ 1. Application field 1.1 For purposes of this Regulatory Standard, rope access is the progression technique using ropes, with other equipment to ascend, descend or travel horizontally, as well for work positioning, usually incorporating two independently set safety systems, one as a means of access and the other as a safety rope used with safety harness. 1.2 In work situations on a slope, the application of this Annex shall be set up by risk analysis. 1.3 The provisions of this Annex shall not apply in the following situations: a) recreational activities, sports and adventure tourism; b) arboriculture; c) emergency response services for rescue people who do not belong to the own rope access team. 2. Activities execution 2.1 Rope access activities shall be performed: a) By procedures in conformity with national technical standards; b) By certified workers in conformity with personnel certifying national technical standards; (See deadline for implementation in Art. 3rd MTE Ordinance No. 593/2014 and extension in Art. 1 of the Ordinance MTE No. 1471/2014) c) By a team containing at least two workers, one of them being the supervisor The certification process of these workers includes the initial and periodic training required by NR-35 subparagraphs and During the activity, the worker shall be connected to at least two ropes with independent anchor points Activity connected to only one rope may be permitted if both following requirements are met: a) Risk assessment demonstrates that the use of a second rope would generate a higher risk; b) Additional measures are implemented, according to the risk analysis, to ensure a safety performance at least equivalent to using two ropes. 3. Equipment and ropes 3.1 The ropes shall meet national technical standards.

10 3.2 Ancillary equipment used shall be certified according to national technical standards or, failing that, according to international technical standards. (See deadline for implementation of Art. 3rd MTE Ordinance No. 593/2014) In the absence of international standards, certification by foreign standards can be accepted since European standard (EN) requirements are met. 3.3 Equipment and ropes shall be inspected in the following situations: a) Prior to use; b) Periodically, at least every six months The interval between inspections shall be reduced depending on the type of use or in case of exposure to aggressive media. 3.4 Inspections shall meet manufacturer's recommendations and the criteria established in the risk analysis or in the operational procedure All equipment or rope with defects, wear, deterioration or deformation shall be refused, made unusable and discarded Risk Analysis shall consider the external interference that might compromise equipment and ropes integrity Upon exposure to chemical agents that might compromise the integrity of the ropes or equipment, additional measures shall be adopted in accordance with the recommendations of manufacturer, and considering the incompatibility tables between the chemical agents and the materials of rope and equipment In activities nearby energized systems, or likely to get energized, additional measures shall be adopted. 3.5 Inspections shall be recorded: a) Upon acquisition; b) On periodical inspections; c) When the equipment or ropes are refused. 3.6 Rope access equipment shall be stored and kept according to manufacturer or supplier recommendations. 4. Rescue 4.1 The team shall be able of self rescuing and rescuing of the team. 4.2 For each work front shall be a workers rescue plan. 5. Impeditive conditions 5.1 In addition to impeditive conditions identified in Risk Analysis, as stated in NR-35, j, rope access shall be discontinued immediately in the event of winds exceeding forty kilometers per hour. 5.2 Rope access with wind up to forty-six kilometers per hour may be authorized, provided that: a) Work deferral impossibility is justified by document signed by the responsible by work execution;

11 b) Complementary risk analysis with assessment of risks, their causes, consequences and control measures, is carried out by a multidisciplinary team coordinated by a qualified professional in occupational safety or, in the absence of the latter, by the responsible for compliance with this standard, attached to the justification, with the applicable additional protective measures, signed by all participants; c) Additional security measures that make it possible to carry out the activities are deployed; d) The work is performed by supervisor assisted activity. ANNEX II Anchor systems (Inserted by Ordinance MTb No. 1113, dated September 21, 2016) 1. Scope 1.1 This Annex applies to the anchor system, defined as a set of components, part of a personal fall protection system PFPS, that incorporates one or more anchor points, where Fall Protection Personal Protective Equipment (PPE) can be connected, directly or through another component, and designed to withstand the applied forces. 1.2 Anchor systems covered in this Annex may meet the following purposes: a) Fall arrest; b) Travel restraint; c) Work positioning; d) Rope access. 1.3 The provisions of this Annex do not apply to the following situations: a) Recreational activities, sports and adventure tourism; b) Arboriculture; c) Anchor systems for collective protection equipment; d) Anchor systems for anchoring access equipment; e) Anchor systems for vertical or horizontal personnel and materials transport equipment; 2 Anchor system components 2.1 The anchor system can present its anchor point: a) Directly in the structure; b) In a structural anchor; c) In an anchor device The structure which is part of an anchor system shall be able to resist the maximum force applicable. 2.2 Structural anchor and fasteners shall: a) Be designed and constructed under responsibility of a legally qualified professional; b) Meet the national technical standards or, failing that, the applicable international standards.

12 2.2.1 The structural anchors which have anchor points shall have marking by the manufacturer or by the responsible legally qualified professional containing at least: a) Manufacturer identification; b) Lot number, serial number or other means of traceability; c) Maximum number of workers that can be connected simultaneously or maximum applicable force The anchor points of the structural anchors already installed that do not have the marking required in this item shall have its marking reconstituted by the manufacturer or by the responsible legally qualified professional In the impossibility of recovery of the information, the anchor points shall be tested under the responsibility of a legally qualified professional and marked with the identification of the maximum number of workers simultaneously connected or the maximum applicable force and identification allowing traceability of the test; 2.3 The anchor device shall meet one of the following requirements: a) Be certified; b) Be manufactured in conformity with national technical standards in force under the responsibility of a legally qualified professional; c) Be designed by a legally qualified professional, with reference to the national technical standards in force, as part of a complete personal fall protection system. 3 Anchor system requirements 3.1 Anchor systems shall: a) Be installed by trained workers; b) Be subject to initial and periodic inspection The initial inspection shall be performed after installation, modification or change of location Periodic inspection of the anchor system shall be conducted in accordance with the operational procedure, considering the anchor system design and the assembly design, respecting the manufacturer's instructions and applicable regulatory and technical standards, with intervals not exceeding 12 months. 3.2 Temporary anchor systems shall: a) Meet the requirements for compatibility with each installation site according to operational procedure; b) Have fixing points defined under responsibility of a legally qualified professional. [This last requirement is still lacking consensus among the three parties in the NR 35 national tripartite commission. An alternative proposal is: Have fixing points defined by a trained worker.] 3.3 The permanent anchor system shall have design and the installation shall be under responsibility of a legally qualified professional; 4 Specifications and design 4.1 The design, if applicable, and the technical specifications of the anchor system shall: a) Be under responsibility of a legally qualified professional;

13 b) Be drawn up taking into account the anchor system operational procedures; c) Contain an indication of the structures that will be used in the anchor system; d) Contain details and/or specification of the anchor devices, structural anchors and fasteners to be used The design, if applicable, and the technical specifications shall include calculation determining the following parameters: a) Worker(s) fall arrest impact force, taking into account the effect of simultaneous or sequential impacts; b) The efforts on each part of the anchor system resulting from the impact force; c) The required clearance. 5. Operational Procedures 5.1 The anchor system shall have operational procedure for assembly and use The assembly operational procedure shall: a) Contemplate the assembly, maintenance, alteration, relocation and disassembly; b) Be prepared by a qualified professional in labor safety, considering the project requirements, if applicable, and the manufacturer s instructions.