MANUFACTURING TECHNICAL INSTRUCTIONS - SAFETY FALL HAZARD CONTROL REQUIREMENTS SERIES & NO. SMI - 157

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1 1 of PURPOSE To establish minimum requirements and guidelines for controlling hazardous exposure of personnel to falls from working elevations in conformance with Federal and State OSHA rules and regulations and ANSI standards. 2.0 REFERENCES: Federal and State Occupational Safety and Health Acts. SMI Automation, Safeguarding Requirements for Design, Construction, Manufacturing and Installation of Chrysler LLC Tool and Design Standards, Vol. IV. Chrysler LLC General Safety Specifications for Industrial Equipment (CS ). ANSI Z359 Safety Requirements for Personal Fall Arrest Systems, Sub and Components. 3.0 FUNCTIONS AFFECTED Manufacturing Manufacturing Engineering Facilities Engineering Maintenance Employee Safety Purchasing Industrial Hygiene 4.0 OPERATIONS AFFECTED Chrysler LLC and Subsidiaries Contractors of Chrysler LLC and Subsidiaries 5.0 DEFINITIONS Competent person means one who is capable of identifying hazardous or dangerous conditions in any fall protection system or any component thereof, as well as in their application and use with related equipment. Qualified person means one with a recognized degree or professional certificate and extensive knowledge and

2 2 of 6 experience in the subject field who is capable of design, analysis, evaluation and specifications in the subject work, project or product. Platforms means any elevated surface designed or used primarily as a walking or working surface, and any other elevated surfaces upon which employees are required or allowed to walk or work while performing assigned tasks on a predictable and regular basis. Platforms used by employees shall be guarded in accordance with 29 CFR (c)(1). Predictable and regular basis means employee functions such as, but not limited to, inspections, service, repair and maintenance which are performed: a. At least every 2 weeks or b. For a total of 4 man-hours or more during any sequential 4-week period (e.g. 2 employees once every 4 weeks for 2 hours = 4 man-hours per 4-week period). 6.0 EMPLOYEE INFORMATION AND INSTRUCTIONS 6.1 Employees whose duties require them to work at elevations and employees whose duties require them to design, construct, install, maintain and/or change facilities and/or equipment where employees may be required to work at elevations, shall comply with the following requirements: Whenever performance of any task would allow a worker to fall a distance of six feet or more, or any distance where the likelihood of a serious or fatal injury exists, the hazards of falling shall be identified, evaluated and controlled. A. Fall hazards shall be determined throughout all affected operations and, through an ongoing process, be identified before specific tasks are performed that would place workers at risk of falling. Four primary methods that may be utilized to identify fall hazards are: (i) reviewing accident/incident records, (ii) surveying workers, (iii) conducting individual and group interviews, and (iv) inspection of facilities and equipment for fall hazards. B. Manufacturing Engineering shall identify potential fall hazards in equipment and services covered by

3 3 of 6 procurement specifications and shall assure that such specifications address fall hazard concerns and require vendors to eliminate fall hazards or prevent exposures to same in provided goods and services or show cause why they cannot. When such elimination or prevention means cannot feasibly be provided, alternative lower order means of fall protection shall be specified. C. Fall hazards identified in accordance with (A) and (B) above, shall be prioritized and evaluated with the aim of controlling as many hazardous situations as quickly as possible. Fall hazards shall be ranked according to how dangerous they are, considering: (i) consequences of a fall at the fall hazard location, (ii) probability that conditions or tasks will result in a fall, and (iii) total exposure time of workers. Immediate action shall be taken to provide interim controls to protect workers faced with fall hazards while awaiting the implementation of engineering means of control as set forth below. D. In situations where the safeguarding requirements of platforms are not applicable because employees are exposed to falls from an elevated surface on other than a predictable and regular basis, personal protective equipment as required or other effective fall protection shall be provided Actions to control fall hazards shall be selected in accordance with the following priorities: 1. First priority - eliminate the fall hazard and/or risk by engineering means 2. Second priority - prevent exposure to the fall hazard by engineering means 3. Third priority - implement workplace warnings of fall hazards 4. Fourth priority - implement training and procedures (administrative controls) 5. Fifth priority - implement personal protective equipment (PPE). First consideration must be given to the elimination of the fall hazard or prevention of exposures to it. If it is not feasible to do so, then lower priority means of controlling the outcomes of a fall shall be selected. When personal protective equipment must be resorted to, workplace warnings, training and procedures shall still be established and enforced Engineering and supervisory personnel on all projects and recurring work shall assure that planning for continuous safety at heights for all workers has been completed prior to commencement of any work aloft. Such planning shall, at a minimum, consider:

4 4 of 6 1. Worker required paths of movement, fall hazards in such paths, and means of continuous fall hazard elimination, prevention and protection throughout such paths. 2. Emergency rescue and/or evacuation paths and means for performing rescue and/or evacuation. 3. Verification that all anchorage points for PPE have been pre-approved by a qualified person and that all personnel who will work aloft have been trained in the required fall protection equipment and procedures and instructed in the specific hazards and countermeasures for same in the work and work site at hand Work at heights should not be started without consideration for emergencies and preparedness for emergency response. Each plant should have an emergency response plan which addresses the rescue and evacuation of persons working at heights (a sample rescue plan is shown in Attachment A ). Such plan should be developed and maintained with the participation of personnel who are familiar with the work to be done at heights. (A confined space emergency response plan may also be used in this program.) The plan should consider: 1. Environmental and site-specific factors which may affect rescue and evacuation operations, and how these factors are to be controlled. 2. Duties and responsibilities of workers in the event of an emergency at heights. 3. Identity of rescue personnel, backup personnel and emergency chain of command. 4. Correct paths for rescue and evacuation of workers from heights. 5. Rescue and evacuation equipment to be used All fall protection PPE and procedures for the selection, inspection, rigging, maintenance, training and use of same shall meet or exceed the requirements of Federal and State OSHA regulations and ANSI Z359 standards. Manufacturers of such PPE procured by the affected operations shall be required to certify that their equipment meets the applicable requirements and provide proof of same. All affected operations shall comply with the requirements of Federal and State OSHA regulations, ANSI Z359 standards, and

5 5 of 6 manufacturer instructions. To assure equipment compatibility, each plant should standardize on the equipment of a single manufacturer as approved by Corporate Safety All workers in affected operations who are required to work at heights or who have an assigned role in the development, implementation, and maintenance of the fall hazard control program shall be trained in the applicable disciplines necessary for each of them to safely carry out their respective duties and responsibilities. See paragraph below. A. At a minimum, such training shall differentiate between the training needs of the following categories: 1. Supervisors of at-risk workers 2. At-risk workers 3. Designated qualified persons 4. Designated competent persons. B. Except as specified herein below, all fall hazard control training shall be performed by or through Chrysler LLC approved sources. Specialized advanced training by contracted experts shall be provided to the following: 1. Fall hazard control trainers 2. Designated competent persons 3. Designated qualified persons. C. Training content, at a minimum, shall include the following: i) Need for a policy & program ii) Selecting, using, inspecting & maintaining components of personal fall arrest iii) Checklists for fall protection applications

6 6 of 6 iv) Chrysler LLC fall hazard control policy & program vii) Physics of fall arrest & suspension x) Human body in fall arrest & suspension xiii) Fall hazard awareness, identification & analysis xvi) Planning for fall hazard elimination & prevention xix) Overview of personal for safety at heights xxii) Components of personal fall arrest xxv) Planning for continuous safety at heights v) Portable temporary climbing viii) Fixed permanent climbing xi) Components of personnelriding xiv) Rigging & use of personnelriding xvii) Components of personal restraint xx) Rigging & use of personal restraint xxiii) Components of rescue & evacuation xxvi) Rigging & use of rescue & evacuation vi) ix) Federal & State OSHA regulations ANSI standards xii) Engineered xv) Anchorage design, selection and use xviii) Special subjects for Committee members & Coordinator s xxi) Special subjects for supervisors of at-risk workers xxiv) Special subjects for facilities engineers or designated qualified persons xxvii) Special subjects for trainers & designated competent persons

7 7 of At the plant level, overall management of the fall hazard control program resides with the plant manager. Duties of other key participants in the program are as follows: 1. The plant manager may establish a fall hazard control committee to facilitate identification and evaluation of fall hazards, propose controls for fall hazards, and monitor implementation of plans approved by the plant manager. Additionally, the plant manager may designate one or more coordinators to review plans and schedules, coordinate the efforts of various departments, ensure adherence to procedures and plans, and report progress of the fall hazard control program. 2. Supervisors of at-risk workers shall assure that: (a) (b) (c) Work in fall-hazardous situations is properly planned, including provisions for emergency rescue and evacuation. All fall safety equipment is properly selected, inspected, installed, used, and maintained in accordance with established guidelines. All questions regarding this fall hazard control program are satisfactorily answered. 3. A competent person shall be called upon by supervisors for consultation in carrying out this program. The competent person shall be capable of: (a) (b) (c) (d) (e) Selecting and/or making proper connections to approved anchorages. Performing periodic inspection of all fall protection and rescue equipment. Properly using all fall protection equipment. Identifying hazardous or dangerous conditions in any fall protection or rescue equipment and taking prompt corrective measures when danger is imminent. Ensuring that any substitution or change to fall protection, rescue and evacuation equipment meets the established standard.

8 8 of 6 (f) Selecting temporary anchorage points during emergency situations when a qualified person is unavailable. 4. A qualified person shall be called upon by supervisors for consultation in carrying out this program. A qualified person or the use of an appropriate contractor vendor shall be identified for each facility to approve anchorage points for fall protection, rescue and evacuation. The qualified person shall be capable of: (a) (b) (c) (d) Selecting temporary and permanent anchorage points. Determining appropriate rescue and evacuation equipment. Designing and supervising the installation and use of engineered such as horizontal lifelines. Designing new anchorages and/or evaluating existing structure for anchorage capability. 4. Fall protection inspection is an important program element. Required inspections are as follows: (a) (b) (c) A user inspection shall be done before and after each use of a fall arrest system. The inspection shall be done by the person who will be using the equipment or by the person issuing the equipment from the storage crib. A formal inspection shall be done anytime equipment has been used in a fall incident. A formal inspection shall be done annually with documented records by a qualified, trained person. Each plant shall arrange for this inspection normally done by an approved vendor. 5. The minimum requirements outlined above shall be followed by each plant in establishing and implementing an effective fall hazard control program that assures the safety of workers performing tasks at heights A properly attached full-body safety harness and lanyard is required to be worn at all times (whether inside or outside the work basket) by all occupants in any elevated work platform,

9 9 of 6 including, but not limited to aerial lifts, scissor lifts, geni-booms, and articulating boom work baskets. VI. RESPONSIBILITY It is the responsibility of individual plant management at each Chrysler LLC location to establish, enforce and maintain a comprehensive fall hazard control program that ensures that it is an ongoing process in accordance with this Manufacturing Technical Instruction.

10 10 of 6 Appendix A (Sample Rescue Plan) (To be inserted into the locations Fall Protection Program) Working at Heights Emergency Response Procedure This plan has been developed to ensure employees working at heights are provided prompt rescue if suspended in the event of a fall. The local fall hazard assessment has been used to determine the extent of the response methods listed in this procedure. Location Fall Protection Program Administrator: (Management Member LJHSC) To help ensure a prompt response in the event of a fall from heights, the site may utilize on-site or off-site persons to provide rescue assistance. In all situations, persons providing rescue assistance shall be readily available and competent to provide these services to Chrysler employees. In the event of a fall from heights where an employee is suspended in their harness; Call the plant emergency number:. State the nature of the incident, and location of the suspended employee Do not attempt to move any person on your own unless there is a life threatening danger and you are authorized to do so. Communicate with the employee, try to calm them. If accessible and safe to do so, a ladder or aerial lift (via a trained employee) can be used to access a suspended employee so they can climb down safely. If it is unsafe to perform a rescue, off-site Emergency Services should be contacted. Never put yourself at risk - wait for Emergency Services to arrive. Other employees should stay clear of activities unless otherwise directed by Emergency Services personnel Equipment designated for use in the rescue of an employee suspended from heights shall be defined, in good working order, and readily available for rescue during any work at heights activity. (list equipment here, i.e., 30ft. Geni Boom)

11 11 of 6 If all normal controls (use of an aerial lift, ladder, engineering solutions, etc.) have been exhausted and it is determined during the assessment that high-angle rescue may become necessary, plants must contact corporate safety before proceeding. Training Employees designated to assist in a work from heights rescue shall receive training which includes; NTC Kiosk training on Fall Protection How to use the locations written fall protection and rescue program NTC Kiosk training on Aerial Lift Operation Re-training shall be conducted when it becomes apparent that employees who would assist in a rescue do not have the knowledge to properly assist in rescue operations.

12 12 of 6 VII. CHANGE HISTORY : 09/03/2008 Date of Last Revision: 06/30/1998 Document Author: Chrysler LLC. Process Owner / Document Manager: Chrysler LLC. Reason for Change: Major format and text arrangement changes made to improve document flow and changes in external requirements. Revision: Section Changed Change Made: Date: 1. Page Headers Delete all references to Daimler and added LLC 07/15/08 Whole document Delete all references to Daimler and added LLC 5.0 Added definition text from S-17 Safety Bulletin D New item added text from S-17 Safety Bulletin Added reference to Appendix A New item added text from S-38 Safety Bulletin Appendix A New item added