Fall Prevention: Compliance is Not a Control

The key ingredient when working at heights is to not start work until it is safe to do so and create a workplace where your employees feel free to speak up if they feel the right controls are not in place.

• By Jose Moreno
• Jun 01, 2019

As a safety professional, how often have you observed someone working at heights who is not properly protected from a fall? Before approaching the individual, it is important to think about the conversation you are about to have to alert them of the hazard. This conversation is critical to achieve a successful outcome. More importantly, the safety culture that exists in your organization will have a huge impact on the outcome of that conversation and whether it will be received in positive or negative manner. Does your company have a culture that is receptive to both giving and receiving coaching in a respectful manner?

The statistics are a stark reminder that there is a need for change in how the industry views fall protection. Researchers from the NIOSH Fatality Assessment and Control Evaluation Program¹ found that between 1982 and 2015, 42 percent of fatalities were related to fall incidents in the construction industry. Of those fatalities, 54 percent had no access to fall protection equipment and 23 percent had access but chose not to use it. Twenty percent of the worker deaths that occurred in that span were in their first two months on the job.

Change can only begin when you manage the safety culture existing in your organization. While it is understood that there are regulations that govern workplace safety, it is important to recognize that compliance is not a control to create safe work. The best way to create safe work is to manage controls, which is accomplished by changing to a culture that understands safety begins with you. The "safety cop" mentality is counterproductive in trying to instill a positive safety culture. Culture shifts begin when the workforce understands that safety is a personal choice rather than a condition of employment. Having this mindset is a critical component to employees protecting themselves from falls and other incidents.

Changing the way workers view fall prevention starts by having a focus on safe work practices. When working at heights, begin by having employees perform a thorough Job Safety Assessment (JSA) and identify hazards associated with the job they will be doing. This includes understanding what fall protection equipment is needed and having the training on how to use it properly. Without the necessary equipment and hazard recognition training, workers are at an immediate disadvantage and are more likely to perform unsafe work.

In the unfortunate circumstance that a fall incident occurs, rather than point blame at the worker, focus efforts on what may have failed him or her. Sometimes employers decide to discipline the worker, and in some cases, the employee is terminated because he failed to follow safe working procedures. Certain instances do require this course of action when safety rules are intentionally not followed, but an opportunity to gather critical information is missed when the individual who was involved in the safety infraction is not included in the incident investigation. Remember, the ultimate goal is to prevent a similar incident from occurring again. Allowing the involved individual to take ownership of the incident investigation often provides useful data that can lead to safer work practices.

Focus on 'What,' Not 'Who'
Focusing on "what" failed a worker during a fall safety incident is important in order to create a culture in which employees feel safe reporting incidences or near hits, leading to safer work. Often, incident investigations only focus on the "who," pointing blame on why someone didn't follow safety protocols. However, the most important thing an organization needs to focus on are the precursors existing in the workplace that may be causing workers to be unsafe.

Time pressure, lack of safety training, complacency, and fatigue are often some of the key factors that can lead to accidents. Having a continuous improvement mindset on how to mitigate these common factors is vital in creating a safe work environment.

The key ingredient when working at heights is to not start work until it is safe to do so and create a workplace where your employees feel free to speak up if they feel the right controls are not in place. Have employees take the time to assess the job and ask themselves these questions:

• "Do I have a good understanding of the task at hand?"
• "Do I have the right safety training to perform the work?"
• "Am I the best person to do the job?"
• "Am I empowered to stop the job if something doesn't feel right or look right?"
• "Do I have the right safety equipment and a good understanding of the hazards associated with the work before I start?"

Employers have an enormous responsibility when it comes to creating a safe workplace. They are required to provide a place of employment that is "free from recognized hazards that are causing or are likely to cause death or serious physical harm," as stated in the General Duty Clause of the OSHA Act of 1970.

Creating a safe workplace is a two-pronged approach. Safety starts with the top leadership of an organization leading by example, not merely being spectators while expecting workers to work safely, but rather they must be visible, engaged with the work, and be active participants in promoting safety. The second and most critical factor for safety is to have the authority to stop work. Stop work authority is central for establishing a safe workplace. Many fall incidents are prevented when individuals know that they can stop the job at any time if they feel that the work is unsafe to perform.

Employers must understand that fall prevention is much more than compliance. Fall prevention is a team effort that requires all forms of leadership to each have a stake in the process to prevent incidents. The way to do that is to get involved. Show interest in your personal safety and the safety of others. Train employees to understand that safety is their personal responsibility. Have everyone get involved in improving safety in the workplace, from the top down. By doing so, you will see a positive change in your safety culture that could lead to fewer safety incidents.

Atlas Field Services (AFS) has been a vital partner for a public utility company in California in the implementation of its Essential Controls program for vegetation management. The program is built on the premise of "never start a job if controls are not present." The tool was developed for the workers by the workers to use in the field prior to starting work. The controls are broken down by five focus areas when felling a tree, working aloft, performing an uncontrolled drop/controlled drop, and working near high-powered lines. Each control contains thought-provoking questions that are designed to be put into place prior to starting work. If all controls are not present, then work is not started. AFS field safety consultants work closely with the utility and the vegetation management contractors to ensure the tool is being utilized in the field. The consultants also perform safety observations of the work, document their findings, and provide coaching and guidance to the contractors to ensure that safe work is created. This partnership has improved worker safety in the field in a high-risk industry by ensuring that tree workers get a safe start to perform work.

Reference
1. https://www.cdc.gov/niosh/face/default.html

This article originally appeared in the June 2019 issue of Occupational Health & Safety.