Document owner and change code Document Owner Aaron Perronne Title HSSE Manager Mark X Change Code Description X N/A First Issue A Typographical/Grammatical correction; formatting change; text clarification-no action required B Change requiring minor adjustment to process and/or records; users to be informed-no retraining required C Major change to the process and/or records; retraining of involved personnel to be conducted Table of Contents Document Owner and Change Code...1 1. Objective..2 2. Definitions...2 3. Responsibilities 3 4. General Fall Protection Requirements..4 5. Criteria and Practices for Fall Protection Systems...5 6. Situations Requiring Fall Protection...10 7. Protection from Falling Objects.12 8. Training Requirements. 12 9. Accident Investigation, Reporting and Analysis. 14 10. Fall Protection Plan Audit 15 Page 1 of 15
1 OBJECTIVE This Fall Protection Plan has been prepared for the prevention of injuries associated with falls on job sites. It has been designed according to components established by the Occupational Safety and Health Administration (OSHA) in 29 CFR 1926, Subpart M, Fall Protection. While this plan provides the generic components and parameters for fall protection, it is understood that fall protection must be project-specific, where control measures must be developed and implemented for each identified project and/or job function. In many cases, the fall protection controls are unique to that project and/or job function. A qualified person for the specified work site must prepare each fall protection plan. Mechanical Systems, Inc. is dedicated to the protection of its employees from on the job injuries. All employees of Mechanical Systems, Inc. have the responsibility to work safely on the job. The purpose of this plan is to: Supplement our standard safety policy by providing safety standards specifically designed to cover fall protection on this job. Ensure that each employee is trained and made aware of the safety provisions, which are to be implemented by this plan prior to the start of erection. 2 DEFINITIONS Body Belt or Safety Belt - a strap with means both for securing it about the waist and for attaching it to a lanyard, lifeline or deceleration device. Note: As of January 1, 1998, the use of a body belt for fall arrest is prohibited. Body Harness - straps which may be secured about the employee in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a personal fall arrest system. Competent Person - a person who is capable of recognizing and evaluating employee exposure to unsafe conditions, and is capable of specifying the necessary protection and precautions to be taken to ensure the safety of the employees. Controlled Access Zone (CAZ) - 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. Page 2 of 15
Deceleration Device - any mechanism, such as a rope grab, rip-stitch lanyard, specially-woven lanyard, tearing or deforming lanyards, automatic self-retracting lifelines/lanyards, etc., which serves to dissipate a substantial amount of energy during a fall arrest, or otherwise limit the energy imposed on an employee during fall arrest. Guardrail System - a barrier erected to prevent employees from falling to lower levels. Lanyard - a flexible line of rope, wire rope, or strap, which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. Leading Edge - the edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are place, 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. Personal Fall Arrest System - a system used to arrest an employee in a fall from working level. It consists of an anchorage, connectors, a body/safety belt or body harness, and may include a lanyard, deceleration device, lifeline or suitable combination of these. Position Device Systems - a body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning. Safety-Monitoring System - a safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. Walking/Working Surface - any surface, whether horizontal or vertical, on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel, but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties. 3 RESPONSIBILITIES The Program Administrator This person is responsible for: Developing and maintaining the program. Implementing the requirements of the program to assure the policies are adhered to at job sites by the Site Foreman and employees Conducting fall protection training to meet the requirements of this program Page 3 of 15
Foremen These people are responsible for: Ensuring their employees have been properly trained in fall protection Inspecting equipment and replacing damaged equipment when necessary Inspecting the area to determine what hazards exist or may arise during the work Giving specific and appropriate instructions to workers to prevent exposure to unsafe conditions Ensuring employees follow procedures given and understand the training provided Appraising the steps our specialty subcontractors have taken to meet their fall protection requirements Employees These people are responsible for: Participating in fall protection training Reviewing and understanding the components of the written program (copies of this program may be obtained from the Manager of Safety in the corporate office and within each Foreman s manual) Following the requirements of this program If after reading this program, you find that improvements can be made, please contact the Manager of Safety. We encourage all suggestions because we are committed to the success of this program for clear understanding, safe behavior, and involvement from every level of the company. 4 GENERAL FALL PROTECTION REQUIREMENTS OSHA currently regulates fall protection for construction under Part 1926, Subpart M. The standards for regulating fall protection systems and procedures are intended to prevent employees from falling off, onto or through working levels and to protect employees from falling objects. Fall protection requirements under the OSHA Construction regulations require considerable planning and preparation. Through a competent person, management will determine if the walking/working surface on which its employees are to work have the strength and structural integrity to support employees safely. Employees are allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity as determined by the competent person. Page 4 of 15
Each employee on a walking/working surface which is 6 feet (1.8 meters) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, safety monitoring systems, or personal fall arrest systems for the following exposures as determined by the competent person: A. unprotected sides and edges B. leading edges C. hoist areas D. ramps, runways and other walkways E. excavations F. holes G. roofing work on a low-slope roofs H. steep roofs I. wall openings J. walking/working surfaces not otherwise addressed The exposure determination shall be made without regards to the use of personal protective equipment. When Mechanical Systems, Inc. purchases equipment and raw materials for use in fall protection systems, applicable ANSI and ASTM requirements will be met. 5 CRITERIA AND PRACTICES FOR FALL PROTECTION SYSTEMS Guardrail Systems Guardrail systems shall meet the following requirements: top rail 42 inches above the walking/working level midrail (or suitable alternative) 21 inches above walking/working level ability to withstand a force of at least 200 pounds in any outward or downward direction so surfaced as to prevent injury from puncture, laceration or snagging of clothing designed so as not to constitute a projection hazard inspected at regular intervals Page 5 of 15
Safety Net Systems Safety net systems shall meet the following requirements: installed as close as practicable under the walking/working surface, but in no case more than 30 feet (9.1 meters) below such level extend outward from outermost projection of the work surface installed with sufficient clearance under them to prevent contact with the surface due to impact on the net capable of absorbing an impact force equal to that produced by drop test specified in OSHA 1926.502 (c) (4) (ii) of the fall protection standard inspected at least weekly for wear, damage, and/or deterioration defective components removed mesh opening not to exceed 36 square inches (230 square centimeters) nor be longer than 6 inches (15 centimeters) on any side Personal Fall Arrest Systems Personal fall arrest systems shall meet the following requirements: connectors, dee-rings, snaphooks, lanyards, lifelines and anchorages are designed, constructed and installed according to specifications addressed in OSHA 1926.502 (d) (1-15) limit maximum arresting force on an employee to 900 pounds when used with a body belt, 1,800 pounds when used with a body harness rigged such that an employee can neither free fall more than 6 feet (1.8 meters) nor contact any lower level body belts, harnesses and related components shall be used only for employee fall protection and not to hoist materials personal fall arrest systems an components subject to impact loading shall be removed from service until inspected an approved for use by the competent person prompt rescue of employees in the event of a fall inspected prior to each use for wear, damage and/or deterioration with defective components removed not to be attached to guardrail systems NOTE: As of January 1, 1998, the use of body belts for fall arrest is prohibited. Page 6 of 15
Positioning Device Systems Positioning device systems shall meet the following requirements: rigged such that an employee cannot fall more than 2 feet (.9 meters) secured to an anchorage capable of supporting at least twice the potential impact load of an employee s fall or 3,000 pounds, whichever is greater connectors, dee-rings and snaphooks are designed, constructed and installed according to specifications addressed in OSHA 1926.502 (e) (1-8) inspected prior to each use for wear, damage and/or deterioration with defective components removed Fall protection plan 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. The fall protection plan must conform to the following provisions: (1) The fall protection plan shall be prepared by a qualified person and developed specifically for the site where the leading edge work, precast concrete work, or residential construction work is being performed and the plan must be maintained up to date. (2) A qualified person shall approve any changes to the fall protection plan. (3) A copy of the fall protection plan with all approved changes shall be maintained at the job site. (4) The implementation of the fall protection plan shall be under the supervision of a competent person. (5) The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) is infeasible or why there use would create a greater hazard. (6) The fall protection plan shall include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. For example, the employer shall discuss the extent to which scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling. Page 7 of 15
(7) The fall protection plan shall identify each location where conventional fall protection methods cannot be used. These locations shall then be classified as controlled access zones. (8) Where no other alternative measure has been implemented, the employer shall implement a safety monitoring system in conformance with 1926.502(h). (9) The fall protection plan must include a statement, which provides the name or other method of identification for each employee who is designated to work in controlled access zones. No other employees may enter controlled access zones. (10) In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) Mechanical Systems, Inc. shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents. Controlled Access Zones (CAZ) Controlled access zones are areas in which certain work may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems. Access to such zones must be controlled. The locations of CAZ must be identified and classified as controlled access zones. Controlled access zones shall meet the following requirements: When used to control access to areas where leading edge and other operations are taking place the controlled access zone shall be defined by a control line or by any other means that restricts access. When control lines are used, they shall be erected not less than 6 feet (1.8 m) nor more than 25 feet (7.7 m) from the unprotected or leading edge, except when erecting precast concrete members. When erecting precast concrete members, the control line shall be erected not less than 6 feet (1.8 m) nor more than 60 feet (18 m) or half the length of the member being erected, whichever is less, from the leading edge. The control line shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected or leading edge. The control line shall be connected on each side to a guardrail system or wall. When used to control access to areas where overhand bricklaying and related work are taking place: The controlled access zone shall be defined by a control line erected not less than 10 feet (3.1 m) nor more than 15 feet (4.5 m) from the working edge. Page 8 of 15
The control line shall extend for a distance sufficient for the controlled access zone to enclose all employees performing overhand bricklaying and related work at the working edge and shall be approximately parallel to the working edge. Additional control lines shall be erected at each end to enclose the controlled access zone. Only employees engaged in overhand bricklaying or related work shall be permitted in the controlled access zone. Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions as follows: Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with high-visibility material. Each line shall be rigged and supported in such a way that its lowest point (including sag) is not less than 39 inches (1 m) from the walking/working surface and its highest point is not more than 45 inches (1.3 m) [50 inches (1.3 m) when overhand bricklaying operations are being performed] from the walking/working surface. Each line shall have a minimum breaking strength of 200 pounds (.88 kn). On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, controlled access zones shall be enlarged, as necessary, to enclose all points of access, material handling areas, and storage areas. On floors and roofs where guardrail systems are in place, but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day's work shall be removed. Safety Monitoring Systems A Safety Monitoring System is a safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. It is only used when no other alternate methods have been implemented. Safety Monitoring Systems shall meet the following requirements: the Site Foreman will appoint a competent Laborer to monitor the safety of other employees the safety monitor will be competent to recognize fall hazards the competent person will warn employees working under unsafe conditions or performing unsafe acts the competent person must be located on same working surface and within visual sighting distance of the employees the competent person must be close enough to communicate orally Page 9 of 15
the designated monitor shall not have other responsibilities that could draw attention away from safety monitoring duties mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-slope roofs no employee, other than an employee engaged in roofing work [on low-sloped roofs] or an employee covered by a fall protection plan, shall be allowed in an area where an employee is being protected by a safety monitoring system each employee working in a controlled access zone shall be directed to comply promptly with fall hazard warnings from safety monitors Warning Line Systems Warning line systems shall meet the following requirements: erected around all sided of the roof work area erected not less than 6 feet (1.8 meters) from roof edge when mechanical equipment is not being used points of access, materials handling areas, storage areas and hosting areas shall be connected to the work area by an access path formed by two warning lines consist of ropes, wires or chains and supporting stanchions erected according to OSHA 1926.502 (f) (2) (i-v) no employee allowed in area between roof edge and warning line unless working in that area mechanical equipment on roofs used or stored only in areas where employees are protected by warning line system, guardrail system or personal fall arrest system 6 SITUATIONS REQUIRING FALL PROTECTION Unprotected Sides and Edges Our employees must be protected when they are exposed to falls from unprotected sides and edges of walking/working surfaces (horizontal and vertical surfaces) which are 6 feet or more above lower levels and shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. We know that OSHA has determined that there is no safe distance from an unprotected side or edge that would render fall protection unnecessary. Leading Edges Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. We Page 10 of 15
Excavations At a jobsite that may have excavation edges that will not be readily seen (i. e., concealed from view by plants, etc.) and when the excavation is 6 feet or more deep we protect these excavations by: 1) Guardrails In addition, walls, pits, shafts, and similar excavations 6 feet or more deep will be guarded to prevent employees from falling into them by: 1) Guardrails and/or fences Erecting Precast Concrete We presume that it is feasible and will not create a greater hazard to implement at least one of the conventional fall protection systems for our precast concrete erection work. When our employees are erecting precast concrete members 6 feet or more above a lower level they must be protected from falling by: 1) Guardrails or personal fall arrest systems Wall Openings Employees who are exposed to the hazard of falling out or through wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches above the walking/working surface must be protected from falling. We protect our employees from falls out or through wall openings by the following methods: 1) Guardrails or personal fall arrest systems Walking/Working Surfaces Not Otherwise Addressed We realize there will be situations that are not covered by our written safety plan, for which we have the duty to provide fall protection. All employees exposed to falls of 6 feet or more to lower levels must be protected by a guardrail system, safety net system, or personal fall arrest system except where specified otherwise in Part 1926. Page 11 of 15
7 PROTECTION FROM FALLING OBJECTS Employees potentially exposed to injury from falling objects are required to wear a hard hat, and shall be protected by on of the following measures, designed and installed per OSHA 1926.502 (j), as determined by the competent person: Erect toeboards, screens, or guardrail systems to prevent objects from falling from higher levels. Erect a canopy structure and keep potential fall objects far enough from the edge of the higher level so that those objects would not go over the edge if the were accidentally displaces. Barricade the area to which objects could fall, prohibit employees from entering the barricaded area, and keep objects that may fall far enough away from the edge of a high level so that those objects would not go over the edge if they were accidentally displaced. 8 TRAINING REQUIREMENTS Under no circumstances shall employees work in areas where they might be exposed to fall hazards, do work requiring fall protection devices, or use fall protection devices until they have successfully completed fall protection training program. The training program includes classroom instruction and operational training on recognition and avoidance of unsafe conditions and the regulations applicable to their work environment for each specific fall hazard the employee may encounter. A Foreman, the Manager of Safety, or a contracted consultant/trainer gives the training program. A competent person qualified in each aspect of the program must cover the following areas: A. The nature of fall hazards in the work area. B. The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used. C. The use and operation of guardrail systems, personal fall arrest systems, safety net system, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used. D. The role of each employee in the safety monitoring system when this system is used. E. The limitation on the use of mechanical equipment during the performance of roofing work on low-sloped roofs. Page 12 of 15
F. The correct procedures for handling and storage of equipment and material and the erection of overhead protection. G. The role of employees in the written Fall Protection Plan. H. The standards contained in OSHA 29 CFR 1926, subpart M, Fall Protection. The Foreman, Manager of Safety, or a contracted consultant/trainer will identify all current and new employees who require training, and will schedule the classroom instruction for those employees. Training on the above components will occur both in the classroom and on the job site, as appropriate. Classroom training will cover written policy/procedures on fall protection and include a training video on the subject. Job site instruction will include demonstration of and practice in wearing fall protection equipment and any instruction necessary for a specific job. Certification of Training The Program Administrators will verifiy compliance with the training requirements of this plan via the Fall Protection Training Record. The Manger of Safety shall maintain a record of the latest training certification for each employee, and that record shall contain: Retraining 1. The date(s) the training was conducted 2. The name, title, and qualifications & signature of person conducting training (i.e. Competent Person) 3. The name, job title & signature of person being trained, and 4. A brief summary or outline of the information that was included in the training session Documented refresher training shall be provided at least annually, and shall be documented with the appropriate note that is refresher training. In addition to annual refresher training, documented retraining shall be provided, and documented as retraining, under the following circumstances: 1. Changes to the workplace, which renders the initial training (or previous refresher training or retraining) obsolete. Page 13 of 15
2. Changes in the types of fall protection systems or equipment to be used, which renders the previous training obsolete. 3. Inadequacies in an effected employee s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill. The Manager of Safety or the site Foreman has the responsibility of determining when an employee who has already been trained does not have the understanding and skill required by the training program Interim Training Where warranted, a competent person in the form of short tool box meetings provides interim training with the employees in the work area. Topics for these training meetings are determined by the type and scope of the job itself, and the need for safety information identified by the employees or perceived by the competent person. All interim training meetings shall be documented Enforcement Constant awareness of and respect for fall hazards, and compliance with all safety rules are considered conditions of employment. The jobsite Foreman, as well as individuals in the Safety and Project Management Department, reserve the right to issue disciplinary warnings to employees, up to and including termination, for failure to follow the guidelines of this program. 9 ACCIDENT INVESTIGATION, REPORTING AND ANALYSIS All accidents that result in injury to workers, regardless of their nature, are investigated and reported. It is an integral part of any safety program that documentation takes place as soon as possible so that the cause and means of prevention can be identified to prevent a reoccurrence. In the event that an employee falls or there is some other related, serious incident (e.g., a near miss) occurs, this plan will be reviewed to determine if additional practices, procedures, or training need to be implemented to prevent similar types of falls or incidents from occurring. Page 14 of 15
10 FALL PROTECTION PLAN AUDIT The fall protection plan shall undergo an annual management audit to evaluate the plan s effectiveness and the need for revision and upgrade. Management shall evaluate the input of the competent person and other representatives of supervision along with feedback from the employees. This information will be used to gauge the effectiveness of the plan and incorporate necessary improvements. Page 15 of 15