Page 1 of 13 Sect: 1.0 Purpose The purpose of the fall protection program is to: o Ensure all work areas are free from uncontrolled fall hazards. o Ensure all employees are properly trained in fall prevention and protection. o Ensure fall prevention systems are inspected and monitored to ensure effectiveness. 2.0 Scope Each employee at risk of falling to a lower level shall be protected using guardrail systems, safety net systems, or personal fall arrest systems. 3.0 Regulatory References This is primarily intended to satisfy the following regulatory requirements: o 29 CFR 1926.501, 1926.502, 1926.503 4.0 Responsibilities 4.1 Management Ardent Management is responsible for the following: Ensure that the HSE Management System adequately addresses Fall Protection and that the policy is reviewed annually and revised as necessary. Provide Fall Protection training for all employees. Provide leadership and support for employees in communicating their responsibility to stop the work when unsafe conditions or behaviors are discovered or suspected. Provide resources to address and correct Fall Protection related issues. 4.2 Supervision Ardent Supervision is responsible for the following: Understand and enforce the Ardent. Provide guidance to employees for recognition and control of fall related hazards. Identify and designate a competent person responsible for identifying fall hazards. Make every effort to schedule construction activities to avoid working in or near a leading-edge zone. Provide guidance to employees in selecting the appropriate fall protection equipment. Instruct employees in the proper method of donning harness and attaching lanyards. Instruct employees in the care and inspection of fall protection equipment. Identify and designate a competent person responsible for development and implementation of a fall protection plan where required. Provide immediate on-the-spot training for all employees regarding fall hazards when necessary. Report all fall-related Accidents and Near Miss events. Lead or participate in Incident Investigations as required. Maintain all documentation required by this program.
Page 2 of 13 Sect: Enforce rules and enforce discipline as necessary for and Plan violations. Develop Fall Rescue Plan and assure that any required rescue equipment is available on site for prompt rescue in the event of a fall. 4.3 Employees Ardent Employees are responsible for the following: Participate in and understand Fall Protection training. Follow safety rules and guidelines regarding Fall Protection. Participate in JSA and hazard recognition activities. Make every effort to identify fall related hazards during daily JSA s. Stop the work and immediately inform your supervisor if you believe a fall hazard exists that has not been previously identified and/or for which control measures have not been implemented. Barricade any unsafe condition. Follow and use all fall protection requirements and PPE. Proper care and inspection of fall protection equipment. 5.0 Policy It is the policy of Ardent to take all practical measures possible to prevent employees from being injured by falls. We will take necessary steps to eliminate, prevent, and control fall hazards. We will comply fully with the OSHA Fall Protection standards. The highest priority is given to the elimination of fall hazards. If a fall hazard cannot be eliminated, effective fall protection will be planned, implemented, and monitored to control the risks of injury due to falling. All employees exposed to potential falls from heights will be trained to minimize the exposures. Fall protection equipment will be provided and its use required by all employees. Supervisors will be responsible for implementation of a fall protection plan for their jobsite. In the event an incident (accident or serious near miss) occurs relating to fall protection, a through investigation will be completed and will contain the following: o Complete review of the current being utilized. o Corrective actions derived from the investigation. All recommended corrective actions will be implemented immediately to prevent similar incidents. All employees working at heights above 4 feet must remain 100% tied off. Fall arresting, descent control, and rescue equipment shall be approved and used in accordance with the manufacturer s recommendations. The fall protection plan shall provide for the prompt rescue in the event of an employee fall or assure that employees are able to rescue themselves.
Page 3 of 13 Sect: All harnesses and lanyards must meet the requirements contained in ANSI standards. While working on a host s property, protection for fixed stairways, ladder openings, hatchway openings, man holes, skylights, ramps, and platforms must not be compromised. Requests to make any changes or modifications shall not take place without direct permission from the host employer. 6.0 Hazard Recognition & Control 6.1 Hazard Identification The supervisor on each jobsite will be responsible for identifying fall hazards on their jobsite. The supervisor will evaluate each situation or work procedure where employees may be exposed to a fall of 4 feet or more. The supervisor will be responsible for developing a plan to eliminate the exposures, if possible, or to select the appropriate fall protection systems and/or equipment. A fall protection plan must be prepared by a qualified person for the specific work site. 6.2 Hazard Control 6.2.1 Engineering Controls Personal Fall Protection Guard Rail Systems Positioning Devices Warning Line Systems Floor Opening Covers 6.2.2 Administrative Controls Controlled access zones Safety Monitoring System Employee training Audits Inspections Supervision Signs
Page 4 of 13 Sect: 7.0 Fall Protection Required The following are examples of situations were fall protection would be needed. This listing is by no means complete, and there are many other situations where a fall of 4 feet or more is possible. It should be noted that ladders and scaffolding are not included in this list because other OSHA standards and other requirements of our safety program cover them. In any case, the requirement for fall protection shall be determined without regard for PPE used. Ardent employees may be required to utilize vehicle mounted platforms, scaffolding and ladders to access work areas. The method utilized is dependent upon numerous factors which include the height of the work area, amount of work to be performed at the location, and the accessibility by vehicle mounted platforms. In all cases, the Ardent supervisor shall develop a fall protection plan for each situation and the Ardent employees shall be trained in the use of the equipment, the potential fall hazards, and the proper fall prevention techniques. 7.1 Wall Openings - Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 4 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 meter) above the walking/working surface must be protected from falling by using a guardrail system, a safety net system, or a personal fall arrest system. Chute wall openings from which there is a drop of more than 4 feet must be guarded. Temporary wall openings shall be guarded. 7.2 Holes - Personal fall arrest systems, covers, or guardrail systems shall be erected around holes (including skylights) that are more than 4 feet above lower levels. Creating floor holes into which persons can accidentally walk on shall be protected by a cover that leaves no openings more than 1 inch wide. The cover shall be securely held in place to prevent tools or materials from falling through.
Page 5 of 13 Sect: 7.3 Leading Edges - A leading edge as defined by CFR 1926.500(b) is: 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 placed, formed or constructed Ardent employees are prohibited from performing or assisting in any type of leading edge work. Per CFR 1926.502(k), leading edge work may be performed in the absence of conventional fall protection measures. Thus, Ardent management has determined that employees working in or near leading edge work will be governed by the same safety requirements as individuals engaged in leading edge work. Ardent s site supervisor will make every effort to schedule work activities to avoid working in or near a leading-edge zone. If working in or near a leading-edge zone is unavoidable, the following requirements will apply: A third-party safety professional will prepare a site-specific Fall Protection Plan addressing leading edge work safety. The third-party professional will be selected by an Ardent Regional Safety Coordinator, or by the company s HSE Director. The third-party safety professional will be required to demonstrate his or her qualifications through verbal interviews and work references regarding leading edge fall awareness experience. Ardent s site supervisor will designate those employees permitted to access leading edge work areas. All other employees will be prohibited from such work areas. Designated employees will attend an initial 30-minute safety meeting addressing the site-specific Fall Protection Plan mentioned in the 1 st bullet in this series. All designated employees will actively participate in Job Safety Analysis each morning prior to mobilizing to their respective work areas. The JSA s will focus on hazard recognitions and hazard avoidance associated with leading edge work conditions. Employees working in a leading-edge work area lacking guard rails, safety nets or personal fall arrest systems, will be provided protection through the implementation of a Safety Monitoring System as described under the Fall Protection Systems section of this document 7.4 Excavations - Each employee at the edge of an excavation 6 feet (1.8 meters) or more in depth shall be protected from falling by guardrail systems, fences, barricades, or covers. Where walkways are provided to permit employees to cross over excavations, guardrails are required on the walkway if it is 6 feet (1.8 meters) or more above the excavation. 7.5 Hoist Areas - Each employee in a hoist area shall be protected from falling 4 feet or more by guardrail systems or personal fall arrest systems. If guardrail systems (or chain gate or guardrail) or portions thereof must be removed to facilitate hoisting operations, as during the landing of materials, and a worker must lean through the access opening or out over the edge of the access opening to receive or guide equipment and materials, that a personal fall arrest system must protect employee.
Page 6 of 13 Sect: 7.6 Ramps, Runways, and Other Walkways - Each employee using ramps, runways, and other walkways shall be protected from falling 4 feet or more by guardrail systems. 7.7 Offshore Operations Fall protection must be used when working on the boat landing or Plus 10 level when not protected by hand rails. 8.0 Controlled Access Zones A Controlled access zone is a work area designated and clearly marked in which certain types of work may take place without the use of conventional fall protection systems, guardrail, personal arrest, or safety net to protect the employees working in the zone. Controlled access zones, when created to limit entrance to areas where leading edge work and other operations are taking place, must be defined by a control line or by any other means that restrict access. Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions, and each must be: o Flagged or otherwise clearly marked at not more than 6-foot (1.8 meters) intervals with high-visibility material o Rigged and supported in such a way that the lowest point (including sag) is not less than 39 inches (1 meter) from the walking/working surface and the highest point is not more than 45 inches (1.3 meters) --nor more than 50 inches (1.3 meters) when overhand bricklaying operations are being performed from the walking/working surface o Strong enough to sustain stress of not less than 200 pounds (0.88 kilonewtons). Control lines shall extend along the entire length of the unprotected or leading edge and shall be approximately parallel to the unprotected or leading-edge Control lines also must be connected on each side to a guardrail system or wall. When control lines are used, they shall be erected not less than 6 feet (1.8 meters) nor more than 25 feet (7.6 meters) from the unprotected or leading edge, or half the length of the member being erected, whichever is less, from the leading edge. 9.0 Fall Protection Systems When there is a potential fall of 4 feet or more, one or more of the following means of providing protection shall be used: 9.1 Guardrail Systems - Guardrail systems must meet the following criteria. Topsails and midrails of guardrail systems must be at least one-quarter inch (0.6 centimeters) nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for top rails, it must be flagged at not more 6 feet intervals (1.8 meters) with high-visibility material. Steel and plastic banding cannot be used as top rails or mid-rails. Manila, plastic, or synthetic rope used for top rails or mid-rails must be inspected as frequently as necessary to ensure strength and
Page 7 of 13 Sect: stability. The top edge height of top rails, or (equivalent) guardrails must be 42 inches (1.1 meters) plus or minus 3 inches (8 centimeters), above the walking/working level. When workers are using stilts, the top edge height of the top rail, or equivalent member, must be increased an amount equal to the height of the stilts. Screens, mid-rails, mesh, intermediate vertical members, or equivalent intermediate structural members must be installed between the top edge of the guardrail system and the walking/working surface when there are no walls or parapet walls at least 21 inches (53 centimeters) high. When mid-rails are used, they must be installed a to a height midway between the top edge of the guardrail system and the walking/working level. When screens and mesh are used, they must extend from the top rail to the walking/working level and along the entire opening between top rail supports. Intermediate members, such as balusters, when used between posts, shall not be more than 19 inches (48 centimeters) apart. Other structural members, such as additional mid-rails and architectural panels, shall be installed so that there are no openings in the guardrail system more than 19 inches (48 centimeters). The guardrail system must withstand a force of at least 200 pounds (890 newtons) applied within 2 inches of the top edge in any outward or downward direction. When the 200-pound (890 newtons) test is applied in a downward direction, the top edge of the guardrail must not deflect to a height less than 39 inches (1 meter) above the walking/working level. Mid-rails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members must withstand a force of at least 150 pounds (667 newtons) applied in any downward or outward direction at any point along the mid-rail or other member. Guardrail systems shall be surfaced to protect workers from punctures or lacerations and to prevent clothing from snagging. The ends of top rails and mid-rails must not overhang terminal posts, except where such overhang does not constitute a projection hazard. When guardrail systems are used at hoisting areas, a chain, gate, or removable guardrail section must be placed across the access opening between guardrail sections when hoisting operations are not taking place. At holes, guardrail systems must be set up on all unprotected sides or edges. When holes are used for the passage of materials, the hole shall have not more than two sides with removable guardrail sections. When the hole is not in use, it must be covered or provided with guardrails along all unprotected sides or edges.
Page 8 of 13 Sect: If guardrail systems are used around holes that are used as access points (such as ladder ways), gates must be used, or the point of access must be offset to prevent incidental walking into the hole. If guardrails are used at unprotected sides or edges of ramps and runways, they must be erected on each unprotected side or edge. 9.2 Personal Fall Arrest Systems - These consist of an anchorage, connectors, body harness and deceleration device. If a personal fall arrest system is used for fall protection, it must do the following: Limit maximum arresting force on an employee to 1,800 pounds (8 kilonewtons) when used with a body harness Be rigged so that an employee can neither free fall more than 4 feet (1.8 meters) nor contact any lower level Bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 meters) Have sufficient strength to withstand twice the potential impact energy of an employee free falling 4 feet, or the free fall distance permitted by the system, whichever is less. The use of body belts for fall arrest is prohibited and a full body harness is required. Personal fall arrest systems must be inspected prior to each use for wear damage, and other deterioration. Defective components must be removed from service. Ardent s Full Body Harness Inspection Form can be found in the Appendix A of this document titled Full Body Harness Inspection Form, document number O-SS-FRM- 0105. Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse. All lifelines and anchorage points shall support 5,000 lbs. 9.3 Positioning Device Systems - Body harness systems are to be set up so that a worker can free fall no farther than 2 feet (0.6 meters). They shall be secured to an anchorage point capable of supporting a least twice the potential impact load of an employee's fall or 5,000 pounds (13.3 kilonewtons), whichever is greater, unless it is part of an engineered system.
Page 9 of 13 Sect: 9.4 Safety Net Systems - When employed, safety nets must be installed as close as practical under the walking/working surface on which employees are working and never more than 30 feet (9.1 meters) below such levels. Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear, damage, and other deterioration. Safety nets shall be installed with sufficient clearance underneath to prevent contact with the surface or structure below. Items that have fallen into safety nets including, but not restricted to, materials, scrap, equipment, and tools must be removed as soon as possible and at least before the next work shift. 9.5 Warning Line Systems - Warning line systems consist of ropes, wires, or chains, and supporting stanchions and are set up as follows: Flagged at not more than 6-foot (1.8 meters) intervals with high-visibility material Rigged and supported so that the lowest point including sag) is no less than 34 inches (0.9 meters) from the walking/working surface and its highest point is no more than 39 inches (1 meter) from the walking/working surface Stanchions, after being rigged with warning lines, shall be capable of resisting, without tipping over, a force of at least 16 pounds 71 newtons) applied horizontally against the stanchion, 30 inches (0.8 meters) above the walking/working surface, perpendicular to the warning line and in the direction of the floor, roof, or platform edge The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kilonewtons) and after being attached to the stanchions, must support without breaking the load applied to the stanchions as prescribed above Shall be attached to each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in the adjacent section before the stanchion tips over. Warning lines shall be erected around all sides of roof work areas. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 meters) from the roof edge parallel to the direction of mechanical equipment operation, and not less than 10 feet (3 meters) from the roof edge perpendicular to the direction of mechanical equipment operation. When mechanical equipment is not being used, the warning line must be erected not less than 6 feet (1.8 meters) from the roof edge. 9.6 Covers - Covers located in roadways and vehicular aisles must be able to support at least twice the maximum axle load of the largest vehicle to which the cover might be subjected. All other covers must be able to support at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time. To prevent incidental displacement resulting from wind, equipment, or work
Page 10 of 13 Sect: activities, all covers must be secured. All covers shall be color coded or bear the markings "HOLE" or "COVER." 9.7 Safety Monitoring System shall be used only when conventional fall protection systems are not practical or present a greater risk to employees and only as part of a Fall Protection Plan. The site supervisor will designate a competent person to monitor the safety of employees. Per CFR 1926.502(h) the safety monitor shall: Be competent to recognize fall hazards. Warn an employee when it appears that the employee is unaware of a fall hazard or acting in an unsafe manner. Be on the same walking/working surface and within visual distance of employees being monitored. Be close enough to communicate orally with employees being monitored. Have no responsibilities beyond the safety monitoring responsibilities. To be designated as a competent employee, an employee must have at least (1) hour of current (60 contiguous minutes) fall protection training, as verified by training records on file at the employee s local Ardent office. 9.8 Protection from Falling Objects - When guardrail systems are used to prevent materials from falling from one level to another, any openings must be small enough to prevent passage of potential falling objects. No materials or equipment except masonry and mortar shall be stored within 4 feet (1.2 meters) of working edges. Excess mortar, broken or scattered masonry units, and all other materials and debris shall be kept clear of the working area by removal at regular intervals. Barricades should be erected to keep employees from entering, and to keep objects that may fall, away from the edge of a higher level. 9.9 System Components & Materials - Ardent Services does not purchase or install guardrail systems, safety nets or materials used to cover openings in temporarily or permanently working surfaces. Ardent Services does purchase personal fall arrest systems (full body harnesses) and on rare occasion, horizontal life line systems. Full body harnesses - including connectors, body harness, deceleration devices and self retracting lanyards will be purchased from reputable authorized safety supply vendors. Full body harnesses will come complete with documentation from the manufacturer indicating that harnesses follow all applicable sections of OSHA 1910/1926 and ANSI Z2359.1-1992
Page 11 of 13 Sect: D-Rings must be a minimum of 2 ¼ inches inside diameter and/or cannot apply pressure to the snap hook gate. Horizontal Lifelines - will only be purchased as an engineered system and the system will be certified by a registered professional engineer. 10.0 Incident Investigation All fall protection incidents involving Ardent Employees or subcontract employees shall be reported immediately to the onsite manager and/or the business unit manager. The onsite supervisor will either lead or participate in the incident investigation and will inform the Ardent business unit if he/she requires assistance from the Corporate HSE Director. The onsite supervisor will be responsible for completing and providing all required documentation including all resolutions or corrective actions. As a minimum, Ardent s supervisor shall follow Incident Investigation and Reporting procedures established in the latest revision of Ardent s Incident Investigation Program, HSE Manual Section E.2, document O-SS-SPP- 0038, and the latest revision of Ardent s Incident Reporting & Recordkeeping Program HSE Manual Section E.3, document O-SS-SPP-0039. The following shall apply: All fall incidents resulting in injury or loss of consciousness of an employee and fall incidents where no injury is obvious shall be investigated. All failures in fall protection systems or other control methods not resulting in an actual fall but with the potential for allowing a fall (e.g., near miss) shall be investigated. An investigation shall be initiated no later than 48 hours following the incident. The investigation team shall include at least one person knowledgeable in the work area and fall protection systems involved. A report shall be prepared following the investigation that includes the following minimum information: 11.0 Training o o o o o Date of incident Date investigation began Description of the incident Factors contributing to the incident Recommendations resulting from the investigation All Ardent Employees shall receive Fall Protection training. This training shall be conducted by a qualified/competent person capable of recognizing the hazards associated with the types of fall hazards likely to be encountered and procedures for controlling such hazards. All craft employees and supervisors will complete this training prior to any assignment that has the potential of exposing them to fall hazards.
Page 12 of 13 Sect: 11.1 Training Content Content includes: The nature of fall hazards in the work area The use and operation of controlled access zones and guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems The correct procedures for equipment and materials handling and storage and the erection of overhead protection Employees role in fall protection plans. Fall Rescue and Self Rescue techniques. Fall Hazards and fall protection equipment used. 11.2 Personnel Training All Ardent employees assigned to job tasks or work sites where fall hazards exist shall receive Fall Protection training. In addition, all employees shall receive Fall Protection training as part of the Short Service Employee Program. This training shall occur within the first 180 days of employment. See the latest version of Ardent s Short Service Employee Program, HSE Manual Section B.5, document O- SS-SSP-0010. Also, all Ardent employees shall receive Fall Protection training as part of the Toolbox Safety Meeting Program. See the latest version of Ardent s Toolbox Safety Meeting Program, HSE Manual Section B.6, document O-SS-SSP- 0011. 11.3 Training Frequency All craft employees and supervisors will complete this training prior to any assignment that has the potential of exposing them to fall hazards. Fall Protection training as part of the Short Service Employee Program shall take place within the first 180 day of employment. Fall Protection training shall also be refreshed annually as part of the Toolbox Safety Meeting Program. Retaining will be instituted under the following conditions: Whenever the is revised due to changes in Ardent s policy or regulatory compliance. Whenever jobsite conditions affecting fall protection requirements change. Whenever fall protection equipment is changed other than replacements. Whenever an employee exhibits a lack of understanding or skill required to complete the work safely. In the event retraining has not taken place due to any of above, a refresher course will be completed every three years.
Page 13 of 13 Sect: 11.4 Training Documentation All training shall be documented to include: o Name of person trained o Date of training o Signature of person providing the training o Date training was deemed adequate 12.0 Reporting and Recordkeeping 12.1 Reports All fall protection related incidents shall be reported. 12.1.1 Incident Report - All fall incidents resulting in injury or loss of consciousness of an employee and fall incidents where no injury is obvious shall be recorded as Incidents on an Ardent Incident Report. 12.1.2 Near Miss Reports All failures in fall protection systems or other control methods not resulting in an actual fall but with the potential for allowing a fall shall be recorded as near miss events on an Ardent Near Miss Report 12.1.3 Full Body Harness & Lanyard Inspections-Quarterly inspections will be documented on the Full Body Harness Inspection Form found in Appendix A of this publication. 13.0 Attachments 13.1 Appendix A, Full Body Harness Inspection Form, document number O-SS-FRM- 0105.