Title: Fall Protection Effective Date: 5/20/2006 Control Number: THG_0003 Revision Number: 1 Date: 10/10/2015 Annual Review Completed: 5/13/2015
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1 Title: Fall Protection Effective Date: 5/20/2006 Control Number: THG_0003 Revision Number: 1 Date: 10/10/2015 Annual Review Completed: 5/13/2015 Fall Protection CONTENTS I. INTRODUCTION II. PURPOSE III. SCOPE IV. RESPONSIBILITIES V. DEFINITIONS VI. IDENTIFICATION OF FALL HAZARDS & CONTROL MEASURES VII. HIERARCHY OF CONTROLS VIII. TRAINING IX. INSPECTION X. RECORDKEEPING XI. CONTRACTORS XII. RESCUE Appendix A- Fall Protection Equipment Annual Inspection Checklist Appendix B- Diagram showing total fall distance Appendix C- Sample picture showing a guardrail system Appendix D- Sample picture showing a fall restraint system Appendix E- Example of a Relief Step Safety Device I. INTRODUCTION Page 1 of 17
2 a. It is the policy of the Hillis Group, LLC to take all necessary measures to prevent falls from elevated locations. Fall hazards shall be eliminated through the application of engineering controls whenever possible. Administrative controls and fall protection equipment shall be used when engineering controls are either not feasible or do not completely eliminate the fall hazard. II. III. IV. PURPOSE a. The purpose of this program is to prevent injuries due to falls from elevated locations. This program has been developed in accordance with the following OSHA standards: i. 29 CFR 1910 Subpart D, Walking-Working Surfaces ii. 29 CFR 1910 Subpart F, Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms iii. 29 CFR 1926 Subpart M, Fall Protection SCOPE a. This program applies to all employees at The Hillis Group, LLC worksites and facilities, including but not limited to employees of sub-contractors, inspectors, delivery drivers, and visitors. b. The use of ladders, scaffolds, and aerial lifts is not covered in detail within this program. Contact The Hillis Group, LLC EHS Office for information pertaining to these types of equipment. RESPONSIBILITIES a. President: i. Ensure that responsibilities assigned with this program are carried out within their administrative work unit. ii. Monitor implementation of this program within the work unit. iii. Ensure adequate funding is available to support this program. b. Environmental Health and Safety (EHS) Department: i. Provide program oversight and assist work units in implementing the provisions of this program. ii. Maintain records in accordance with this document. iii. Periodically audit and update this program as needed. c. Work Unit Supervisors: i. Be thoroughly informed of the contents of this program and how it relates to their areas of responsibility and authority. ii. Coordinate implementation of the fall protection program within their work unit. iii. Ensure specific fall hazards within their work unit are identified and adequately controlled. iv. Identify a competent person/s responsible for conducting annual equipment inspections. v. Conduct an investigation of all injuries and incidents involving falls from elevated locations within their work unit. vi. Ensure that records are maintained for their work unit in accordance with this document. vii. Identify specific fall hazards encountered by their employees. viii. Initiate control measures for fall hazards discovered within their assigned areas. ix. Ensure employee compliance with all provisions of the fall protection program. x. Ensure that affected personnel attend fall protection training sessions and are provided with appropriate fall protection equipment. d. Employees: Page 2 of 17
3 i. Comply with all provisions of this program, including the use of protective equipment and completion of pre-use inspections. ii. Attend all training required relative to this program. iii. Promptly report any concerns related to fall protection to their immediate supervisor. V. DEFINITIONS a. The following terms are defined to allow for a better understanding of this program: i. Anchorage means a secure point of attachment for lifelines, lanyards, or deceleration devices. ii. Body Belt means a strap with means for both securing it around the waist and attaching it to a lanyard or lifeline. The use of a body belt for fall arrest is prohibited. iii. Body Harness means an interconnected set of straps that may be secured about a person in a manner that distributes fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders and has a means of attaching it to other components of a fall arrest system. iv. Competent Person one who is capable of identifying existing and predictable hazards in the work environment and who has the authority to take prompt corrective measures to eliminate them. v. Construction Work/Activities means work for construction, alteration, and/or repair, including painting and decorating. vi. Conventional Fall Protection System the following types of systems are commonly considered conventional fall protection systems: 1. standard guardrail systems, 2. fall restraint systems, 3. and personal fall arrest systems. 4. Conventional fall protection systems must always be considered first before a specialized fall protection system. vii. Deceleration Device means any mechanism (such as a rope grab, rip-stitch lanyard, specially-woven lanyard, tearing or deforming lanyard, automatic self-retracting lifeline or lanyard, etc.) which serves to dissipate a substantial amount of energy imposed on an individual during a fall arrest. viii. Deceleration Distance means the additional vertical distance a falling person travels, excluding lifeline elongation and free fall distance, before stopping, from the point at which the deceleration device begins to operate. ix. Fall Restraint System means a system used to prevent an employee from falling off a working level. It consists of an anchorage, connectors, and a body harness. x. Floor Hole An opening measuring less than 12 inches but more than 1 inch in its least dimension in any floor, platform, pavement, or yard, through which materials but not a person may fall. xi. Floor Opening An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which a person may fall. xii. Free Fall Distance means the vertical displacement of the fall arrest attachment point on the body harness between onset of the fall and just before the system begin to apply force to arrest the fall. xiii. Handrail means an individual rail with the same specifications as the top rail of a standard stair railing. The rail must have a height between 30 and 34 inches when measured from the upper surface of the rail to the intersection of the tread surface and riser face. Handrails are not installed in conjunction with an intermediate rail or a toe board. Page 3 of 17
4 xiv. Horizontal Lifeline means a flexible line between two horizontal fixed anchorages to which a fall arrest device is connected. xv. Infeasible means that it is impossible, highly impractical, or more hazardous to perform the work using a conventional fall protection system (i.e., guardrail system, fall restraint system, or personal fall arrest system) xvi. Lanyard means a flexible line of rope or strap that generally has a connector at each end and is used for connecting a body harness to a deceleration device, lifeline, or anchorage. xvii. Low Sloped Roof Means a roof having a slope less than or equal to 4 in 12. (a 4 in 12 roof would have a vertical rise of 4 feet over a horizontal distance of 12 feet) xviii. Leading Edge means the edge of a floor, roof, or formwork for a walking/working surface (such as a deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered to be an "unprotected side and edge" during periods when it is not actively and continuously under construction. xix. Personal Fall Arrest System A system including but not limited to an anchorage, connectors, and a body harness used to arrest a person in a fall from a working level. The use of a body belt for fall arrest is prohibited. xx. Qualified Person 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 problems relating to subject matter, the work, or the project. (Note: This person is usually an engineer.) xxi. Residential Construction is where the working environment, materials, methods and procedures are essentially the same as those used in building a typical single family home or townhouse. Residential construction is characterized by the use of wood frames, floor joists and roof structures. xxii. Restraint Line means a device which is attached between the employee and an anchorage to prevent the employee from falling off an elevated surface. xxiii. Roof Work means the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work. Roof work does not include the construction of the roof deck. xxiv. Safety Net means a net installed underneath the work platform which is used to catch a person during a fall. xxv. Specialized Fall Protection Systems the following types of systems are commonly considered specialized fall protection systems: 1. safety monitor system, 2. warning line system, 3. designated areas, 4. fall protection plans. xxvi. Standard Guardrail is an engineering fall protection control consisting of a top rail, intermediate rail and posts. (See Section 4.1 of this document for further information on standard guardrail systems). xxvii. Standard Stair Railing is an engineering control similar in construction to a standard guardrail (top rail, intermediate rail, posts) but designed for use on stairways. The top rail of a standard stair railing must have a height between 30 and 34 inches when measured from the upper surface of the rail to the intersection of the tread surface and riser face. xxviii. Toe Board A low protective barrier at least four inches high that prevents material and equipment from falling to a lower level and which protects personnel from falling. Page 4 of 17
5 xxix. Unprotected Sides and Edges means any side or edge (except at entrances to points of access) four feet or higher above a lower walking/working surface (e.g. floor, roof, ramp, or runway) where there is no wall or guardrail system at least 42 inches high. xxx. Vertical Lifeline means a flexible line which hangs vertically from a connection to an anchorage at one end and serves as a means for connecting other components of a fall arrest system to the anchorage. xxxi. Wall Opening A gap or void 30 inches or more high and 18 inches or more wide, in a wall or partition, through which a person can fall to a lower level. VI. IDENTIFICATION OF FALL HAZARDS & CONTROL MEASURES a. Supervisors are responsible for identifying specific fall hazards encountered by their employees. A qualified person must develop a Site Specific plan. The following is a list of potential fall hazards along with the applicable control measures for each condition: i. Open sided floors, platforms, catwalks and ramps four feet or more in height: 1. Fall hazards shall be addressed by installation of a standard guardrail on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. ii. Open sided floors, platforms, and ramps adjacent to or above hazardous equipment regardless of height: 1. Fall hazards shall be addressed by installation of a standard guardrail on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. iii. Stairways with four or more risers: 1. Fall hazards shall be addressed by installation of standard stair railings and/or handrails. 2. Stairways less than 44 inches wide with both sides enclosed shall have a handrail installed on the right descending side. 3. Stairways less than 44 inches wide shall have standard stair railings installed on each open side. 4. Stairways between 44 and 88 inches shall have handrails installed on each enclosed side and a standard stair railing installed on each open side. 5. Stairways more than 88 inches wide shall have a handrail on each enclosed side, a standard stair railing on each open side, and a handrail located at the midpoint of the stair width. 6. Stairway floor openings shall have a standard railing installed on all exposed sides. 7. All treads and risers on stairs must be maintained in good condition. iv. Loading Docks (Four or more feet in height): 1. Guardrail systems on the working side of loading docks are not required, where it can be demonstrated that the presence of guardrails would prevent the performance of work (i.e. truck pulling in). 2. All other sides of loading docks shall be guarded by standard guardrail systems or a removable type of guardrail system. 3. Dock doors shall remain closed after use to eliminate the fall hazard. 4. Employees that may be exposed to fall hazards associated with this type of work must be trained to recognize and avoid these hazards. v. Floor openings into which personnel can accidentally walk: 1. Fall hazards shall be addressed by the installation of a standard guardrail on all exposed sides or by a floor hole cover of substantial strength. Page 5 of 17
6 2. When floor hole covers are not in place, the opening shall be constantly attended by a designated employee or protected by a removable standard guardrail. vi. Pits, Tanks, Ditches, Weirs and Vats: 1. Fall hazards shall be addressed by the installation of a standard guardrail on all exposed sides or by a floor hole cover of substantial strength where applicable. 2. When floor hole covers are not in place, the opening shall be constantly attended by a designated employee or protected by a removable standard guardrail. vii. Manholes: 1. Manhole covers shall be placed over manhole openings at all times. If removed, a designated employee must constantly attend the opening or the opening must be protected by a removable standard guardrails. viii. Excavations more than six feet deep: 1. Fall hazards shall be addressed by the installation of guardrail systems, fences, barricades, or covers of substantial strength. 2. Walkways crossing over excavations must be equipped with standard guardrails if the walkway is six or more feet above the excavation. ix. Service platforms of bridge cranes: 1. Fall hazards shall be addressed by the installation of standard guardrails on all exposed sides. x. Hatchways leading through roof openings: 1. When the opening is not in use, the cover shall be closed. 2. When the hinged cover for an opening is left up, the exposed sides must be appropriately protected by a guardrail system. xi. Skylights installed in roof surfaces: 1. Fall hazards shall be addressed by: a. The installation of standard skylight screens which are capable of withstanding a load of at least 200 pounds applied perpendicular to any point on the screen, or b. A cover which is capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time, or c. By installing standard guardrails, or d. A personal fall arrest system. xii. Building roofs: 1. Fall hazards shall be addressed as determined by the following hierarchy of controls: a. Installation of guardrail system, b. Use of a personal restraint system, c. Use of a personal fall arrest system, d. If none of these options are feasible, specialized fall protection systems may be used with EHS approval. 2. Existing parapet walls can be used in lieu of standard guardrails as long as the top of the parapet is at least 39 above the roof surface. If this is not the case, a permanent or temporary guardrail can be installed on the parapet to reach the required height. Page 6 of 17
7 xiii. Scaffolds over six feet high: 1. Fall hazards shall be addressed by the installation of a standard guardrail on all open sides. Fall arrest systems may also need to be worn based on the type of scaffolding being used. xiv. Scissor Lift: 1. Fall hazards shall be addressed by maintaining the standard guardrails installed by the equipment manufacturer. 2. If the manufacturer has installed anchor points, a fall restraint system shall also be used. 3. Operators must follow manufacturer s recommendations as to which fall protection system to use (restraint or a personal fall arrest system). xv. Aerial / boom / bucket trucks and similar types of equipment: 1. Operators shall be secured to the anchor point provided by the equipment manufacturer by either a self-retracting lanyard or by a lanyard short enough to prevent the employee from being ejected. 2. Operators must follow manufacturer s recommendations as to which fall protection system to use. xvi. Any other situation where an individual is exposed to a fall distance of four feet or more: 1. Fall hazards shall be addressed by the installation of a standard guardrail system. When this is infeasible, other conventional or specialized fall protection systems can be utilized according to the hierarchy of controls listed in the next section. VII. HIERARCHY OF CONTROLS a. The hierarchy of controls, or preferred order of controls, shall be used to choose methods to eliminate or control fall hazards. More than one control measure may be used to reduce the risk of a fall and/or control a hazard. A summary of the hierarchy of controls is as follows: i. Conventional Fall Protection Systems Fall protection systems must be considered according to the following hierarchy of controls. Conventional fall protection systems must be utilized/installed before a specialized fall protection system can be considered. 1. Standard guardrail systems 2. Fall restraint systems 3. Personal fall arrest systems ii. Specialized Fall Protection Systems Specialized fall protection systems are only permitted after conventional types of fall protection are found infeasible. 1. Warning line system 2. Controlled Access Zone a. Designated area b. Safety monitor system c. Fall protection plans iii. Conventional Fall Protection System - Standard guardrail system requirements: 1. Note: It is permissible to purchase pre-engineered temporary guardrails which are designed to attach to the edge of roofs and parapets. All manufacturers instructions must be followed regarding installation. 2. Top rails shall have a vertical height of 42 inches when measured from the upper surface of the rail to the working surface. (OSHA allows existing rails to fall within a range of 36 to 44 inches). 3. Intermediate rails shall be halfway between the top rail and floor surface. Page 7 of 17
8 4. Toe boards shall be provided with a guardrail wherever, beneath the open sides: a. Persons can pass, b. There is moving machinery, c. There is equipment with which falling materials could create a hazard. 5. Refer to OSHA regulation for additional requirements regarding standard guardrail systems: OSHA Guardrail Regulation (e) iv. Conventional Fall Protection System - Fall restraint system requirements: 1. This system is used to prevent someone from falling off the edge of a walking/working surface to a lower level. The lanyard must be short enough to prevent a fall from occurring. 2. The anchor point must be capable of supporting 3000 pounds or twice the maximum expected force that is needed to restrain the person from exposure to the fall hazard. When determining this, consideration must be given to forces generated by a person walking, leaning, or sliding down a work surface. 3. Full body harnesses must be used as part of a fall restraint system. Body belts are not permitted. 4. Restraint lines must connect the harness directly to the anchorage independently of any other lines. 5. Knots shall not be made in lanyards or lifelines. 6. Fall protection equipment shall only be used for employee protection and not to hoist equipment or tools. 7. Restraint lines must be protected against cutting and abrasion. 8. Padding or webbing straps shall be used as needed when restraint lines must pass over or around sharp surfaces. 9. Fall protection equipment shall be stored in clean, dry areas that are free from exposure to fumes, corrosive elements, and temperature extremes. v. Conventional Fall Protection System - Personal fall arrest system requirements: 1. If a fall occurs, this system stops the persons fall before they reach the next lower level (see Appendix B for further information). 2. Only commercially manufactured equipment specifically designed for fall protection may be used. The equipment must comply with the ANSI Z359 Fall Protection Code as well as OSHA and ASTM Standards and regulations. 3. Only locking type snap hooks shall be used. Snap hooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snap hook. 4. The attachment point of the body harness shall be located in the center of the wearer s back near shoulder level. 5. Body belts may not be used as part of a fall arrest system. Only body harnesses may be used for this purpose. 6. Lifelines shall be protected against cutting and abrasion. Padding or webbing straps shall be used as needed when lifelines must pass over or around sharp surfaces. Knots shall not be made in lanyards or lifelines. 7. Lanyards are not permitted to be attached to each other in an attempt to increase length. 8. Fall arrest devices shall be connected in a manner, preferably above head level, that minimizes the free fall distance and prevents any contact with lower levels in the event of a fall (see Appendix B for further information). Page 8 of 17
9 9. The maximum potential free fall distance is six feet (see Appendix B for further information). 10. The maximum permissible deceleration distance is 3.5 feet (see Appendix B for further information). 11. Horizontal lifelines shall be designed, installed, and used under the supervision of a qualified person as part of a complete fall arrest system which maintains a safety factor of at least two times the intended load. 12. Separate lifelines shall be provided for each employee when vertical lifelines are used. 13. Fall protection equipment shall only be used for employee protection and not to hoist equipment or tools. 14. Anchorages used for attachment of fall protection equipment shall be independent of any anchorage being used to suspend platforms. 15. Anchorages shall be capable of supporting at least 5000 pounds per individual attached or shall be designed, installed, and used under the supervision of a qualified person as part of a fall arrest system which maintains a safety factor of at least two times the intended load. 16. Fall arrest systems and components subject to a fall shall be immediately removed from service. Such equipment must be destroyed prior to disposal. 17. Fall arrest systems shall not be attached to: a. standard railings b. standard guardrails c. ladders/rungs, d. Scaffolding e. light fixtures, f. conduit or plumbing g. wiring harnesses h. other lanyards i. roof stacks, vents, or pipes 18. Fall protection equipment shall be stored in clean, dry areas that are free from exposure to fumes, corrosive elements, and temperature extremes. vi. Specialized Fall Protection Systems shall be used only if conventional fall protection systems are infeasible. 1. Consult with EHS before utilizing any Specialized Fall Protection System 2. Specialized Fall Protection - Warning line system: a. A warning line system is a barrier erected on a roof to warn employees that they are approaching an unprotected roof, side or edge. A warning line is only permitted for roof work on low slope roofs in combination with a guardrail system, safety net system, personal fall arrest system, or safety monitoring system. Consult with EHS if this type of fall prevention is being considered. 3. Specialized Fall Protection - Controlled Access Zone: a. A Controlled Access Zone is an area in which certain work may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled. The use of this type of fall protection is only permitted when conducting overhand brick laying operations and related leading edge work. Consult with EHS if this type of fall prevention is being considered. Page 9 of 17
10 4. Specialized Fall Protection - Designated area: a. A type of a warning line system that can only be used in certain circumstances dependent on the type of work being performed. Consult with EHS if this type of fall prevention is being considered. 5. Specialized Fall Protection - Safety monitoring system: a. A safety monitoring system is one in which a trained worker is designated to monitor work activities in a control zone to ensure that work is done in a manner that minimizes the potential for a worker to fall. A safety monitoring system can only be utilized during low-sloped roof work when combined with a warning line system. If the roof is 50- feet or less in width the use of a safety monitoring system alone is permitted. Consult with EHS if this type of fall prevention is being considered. 6. Specialized Fall Protection - Fall protection plan: a. This option is available only to employees engaged in leading edge work, precast concrete erection work, or residential construction work who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. Consult with EHS if this type of fall protection is being considered. VIII. IX. TRAINING a. Fall protection training shall be provided to all personnel who use fall protection devices. b. Such training shall be provided before working in elevated locations. i. This includes such tasks as roof work, aerial/boom/scissor lift operation, etc. c. Fall protection trainers need to be approved by EHS. d. Fall protection training includes: i. Enabling employees to recognize fall hazards and understand the associated risks. ii. Familiarize employees with the procedures and equipment used for minimizing these hazards. iii. The use, operation, and limitations of the fall protection systems. iv. Inspection procedures for fall protection equipment. e. Supervisors are responsible for ensuring that their employees receive fall protection training when required by their job duties before they are exposed to the hazard. f. The Safety department is responsible for maintaining records of fall protection training for all employees. i. These records must be accessible upon request. g. Re-training shall be provided to employees under the following circumstances: i. Changes in the workplace render previous training obsolete. ii. Changes in the type of fall protection systems or equipment used render previous training obsolete. iii. Inadequacies in an affected employee s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skills. INSPECTION a. Pre-Use Inspections i. Fall protection equipment shall be visually inspected prior to each use by the employee who uses the equipment for wear, damage, and other deterioration. ii. Defective equipment shall be immediately removed from service and destroyed. Page 10 of 17
11 b. Annual Inspections i. An annual inspection of all fall protection equipment shall be made by a competent person who has been trained to conduct such inspections. ii. Annual inspection results shall be documented using Appendix A or an equivalent manufacturer s inspection checklist. iii. Defective equipment shall be immediately removed from service and destroyed. c. Additional inspection frequencies may be required by the manufacturer. Refer to the equipment instruction/owner s manual for complete details regarding inspection. X. RECORDKEEPING a. The Safety Department is responsible for maintaining the following: i. Records of all fall protection training provided to employees within the work unit. ii. Records of annual fall protection equipment inspections. 1. Records shall be kept for the life of the equipment. iii. If additional inspection frequencies are required by the manufacturer, those records must also be kept for the life of the equipment. XI. XII. XIII. CONTRACTORS a. Contractors engaged in activities that require working at heights shall comply with all applicable OSHA regulations regarding fall protection. b. Contractors are responsible for providing their own fall protection equipment. RESCUE a. When a personal fall arrest system is utilized, procedures shall be in place to provide prompt rescue in the event of a fall. b. There are a variety of ways in which this requirement can be met, depending on the particular circumstances of the work site. Some examples include, but are not limited to, ensuring that at least one other designated employee shall be available to monitor ongoing operations or equipping the employee utilizing the fall arrest system with communication equipment that enables the worker to obtain help promptly. c. All situations where a personal fall arrest system is currently utilized should consider purchasing a Relief Step Safety Device manufactured by Miller or an equivalent device (Appendix E). This device alleviates the effects of orthostatic intolerance (pooling of blood in the legs which restricts blood flow to the brain and other organs), also known as suspension trauma. d. Relief Step Safety Devices shall be utilized by direction of the Competent Person ONLY. see (Appendix E, page 19) 10.0 INVESTIGATION a. The Safety department will conduct an incident investigation of all falls, near misses or other incidents (property damage, etc.) b. This investigation will include all affected employees. Page 11 of 17
12 Appendix A Page 12 of 17
13 Appendix B Diagram showing total fall distance Page 13 of 17
14 Appendix C Sample picture showing a guardrail system Page 14 of 17
15 Appendix D Sample picture showing a fall restraint system Page 15 of 17
16 Appendix E Example of a Relief Step Safety Device Easy to Deploy and Use (Attaches to any brand full-body harness) Pull tab to deploy Insert foot into loop step and adjust Ability to stand allowing improved circulation Two Relief Steps provide added support, balance and comfort Page 16 of 17
17 Controlled Document Review and Approval Procedure Number THG_0003 Revision 1 Effective Date: 5/20/2006 Originator: S.C. Brockman Signature Date Safety Committee Review Date: Chairman: History Revision Number Effective Date Pages Revised Reason for Revision 1 10/10/15 All Revised Procedure Format Page 17 of 17
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