Although the numbers and types of fall hazards may vary greatly throughout industry sectors, no facility is without fall hazards. (New Pig photo)

Before the Fall: Recognize Fall Hazards and Conduct Training to Prevent Incidents

Even if a fall hazard isn't specifically addressed, if it can be identified, plans need to be made to mitigate the hazard and prevent employee injuries.

Until recently, general industry employers were required to use guardrails to prevent fall from height incidents. Updates to the Walking/Working Surfaces Rule in 2016 still require employers to identify fall hazards throughout their facility. But like construction activities, general industry employers may now choose whatever methods they feel will best prevent fall from height injuries or deaths.

With this greater flexibility comes the renewed responsibility to mitigate fall hazards wherever they may occur, by whatever means is necessary to prevent incidents. The rule revisions also add new, specific verbiage about training and the employer’s duty to have fall protection and protection from falling objects.

Fall Hazards
A fall hazard is any circumstance or condition that may cause an employee to fall to a lower level or fall on the same level. Although the numbers and types of fall hazards may vary greatly throughout industry sectors, no facility is without fall hazards.

For low-risk facilities, such as a call center without production, manufacturing or distribution operations, fall risks may be very minimal. In facilities that are built to established engineering codes; stairways, skylights, and windows are already likely to have guardrails and other safety measures in place. When this is the case, fall hazards may be limited to slips and falls to the same level in parking lots, sidewalks, hallways, and entrances. But employers are still responsible for identifying each fall hazard and documenting what measures are in place to prevent incidents.

Manufacturing and other industry sectors, especially those with production and distribution operations, are likely to have many different types of fall hazards, including falls from height, falls to the same level, and falling object hazards. Fall hazards must be identified for all walking and working surfaces throughout the facility, as well as any areas that employees may use to gain access or egress to those areas. This includes ladders, aisles, stairs, ramps, scaffolds, roofs, runways, dockboards, and step bolts.

Some fall hazards, such as stairways, dockboards, scaffolds, ladders, and stepbolts, now have specific fall protection requirements. But, even if a fall hazard isn’t specifically addressed, if it can be identified, plans need to be made to mitigate the hazard and prevent employee injuries.

Duty to Have Fall Protection
Employers must protect employees who are exposed to fall hazards and falling object hazards (29 CFR 1910.28). Protection can take several different forms and may include a combination of procedures, equipment, devices, and/or systems that are used to prevent a fall or the effects of a fall.

The duty to have fall protection standard covers 14 types of fall hazards, including some that may go overlooked, such as: hoist areas, holes, dangerous equipment, pits, ladders, billboards, and low-slope roofs. It also covers other walking-working surfaces with unprotected sides or edges that are 4 feet or more, as well as walking-working surface hazards that are not otherwise addressed.

Fall hazards can be protected by using guardrails, handrails, floor markings, safety net systems, personal fall protection or arrest systems, travel restraint systems, positioning systems, or other effective means. For low-slope roofs, employers may create a "designated area" that is identified by warning lines that allow employees to work in that area without fall protection devices.

With the increased flexibility to choose the best method of preventing falls, instead of relying solely upon guardrails, OSHA has made the presumption that at least one of the methods listed in the rule will fit an employer’s needs. However, if none of the methods listed in the standard are feasible or if they present a greater hazard, employers must establish why the methods are not feasible and develop a fall protection plan that is compliant with the OSHA construction standards for fall protection planning and training.

The duty to have fall protection now also encompasses employees who may be injured from an object falling from heights [29 CFR 1910.28(c)]. When this hazard is present, employees must be provided with head protection. Employers must further protect workers by using toeboards, screens, guardrails, or canopies to prevent falling objects from injuring anyone working on a lower level. If these methods are not feasible, areas can be barricaded to prevent access to the area.

All employees who are exposed to fall from height hazards or who will use personal fall protection systems must receive training prior to their exposure to a fall hazard (29 CFR 1910.30). The training rule is performance based and, in most cases, mirrors the training requirements in the construction fall protection standard (29 CFR 1226.502).

It is OSHA's belief that effective employee training is "one of the most critical steps employers can take to prevent employee injuries and fatalities." To be effective, OSHA requires a number of criteria to be met, including the need for training to be understandable [29 CFR 1910.30(d)]. This means that no matter what training method is used—classroom, hands-on, video, computer-based, or any other method—the employee must be able to comprehend what is being taught, regardless of barriers such as language or the inability to read.

Employees must be taught how to recognize fall hazards and what procedures are to be followed to minimize those hazards. When personal fall protection systems are used, the correct use, installation, inspection, operating, maintenance, and disassembly procedures must be taught. This includes functions such as hooking-up, anchoring, tie-off techniques, and equipment storage.

Training does not need to be site specific, but it must address the actual types of fall hazards that employees may encounter, as well as the plans, procedures, and practices that need to be followed to prevent incidents. To help ensure this, training must be conducted by a qualified person who has "a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project" [29 CFR 1910.21(b)].

If an employer has reason to believe that an employee has not understood training or cannot correctly demonstrate the skills that are required to protect him from a fall hazard, he must be retrained. Retraining is also required when there are changes in the workplace or to a fall protection system [29 CRR 1910.30(c)].

Falls continue to be a leading cause of workplace injuries and deaths. Recognizing fall hazards, establishing plans and procedures to protect against falls, and providing effective training are proven ways to help prevent incidents and improve workplace safety.

This article originally appeared in the July 2017 issue of Occupational Health & Safety.

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