The Most Overlooked Aspect of Fall Protection
Employers should understand that by choosing a fall arrest system, they are obligating themselves to develop a rescue plan and corresponding rescue training.
- By Scott Mirizzi, Nolan Miller, P.E., C.S.P.
- Jul 01, 2011
Imagine the relief of a fallen worker when he realizes a fall arrest system has worked, saving him from a life-threatening plummet. Now imagine the panic that sets in when the worker realizes there is no rescue plan in place. This doesn't have to -- and shouldn't -- be the case. Ideally, the fallen worker will, instead, be comforted by watching a well-coordinated rescue plan spring into action.
In the course of their work, fall protection consultants see many different approaches to protecting workers. Unfortunately, one common observation is that even the most proactive companies tend to minimize or blatantly ignore the need for fall protection rescue. In fact, many in the industry believe rescue is the most overlooked aspect of fall protection.
While some rescue scenarios can be complicated, many times an effective rescue can be accomplished simply by using a portable ladder. The simplest plan is often the best; it just needs to be thought through in advance so that the right people and equipment are ready when needed.
Please remember that 911 is not the only answer to fall protection rescue. One organization's rescue plan required fallen workers to reach their mobile phones and call 911 themselves. A medical emergency, trauma during the fall, or simply a circumstance where a worker couldn't reach his phone renders this plan ineffective. And, depending on the circumstances and capabilities of your local rescue services, engaging external rescue resources may not get a fallen worker down in time to prevent serious injury or death.
How quickly do you need to rescue a fallen worker? An exact amount of time is not provided in OSHA regulations. Published OSHA guidance1 says only that employers must provide for prompt rescue in the event of a fall. Unfortunately, prompt is not defined.
So ask yourself, how long would I want to suspend in a full-body harness? In a recent webinar poll on this topic, 100 percent of the participants said they wouldn't want to suspend longer than 15 minutes.
Because OSHA regulations don't provide specific time requirements, we can look to science for guidance on how long a worker can remain suspended without serious injury. In 1987, a study was performed at Wright-Patterson Air Force Base to determine the effect of motionless suspension on the body. Motionless suspension can come from a medical condition that led to the fall, trauma during or after the fall, or simple fatigue during suspension. The physically fit military test subjects terminated the tests between 3.5 and 60 minutes, with mean times ranging from 17 to 28 minutes. Although the data don't provide one distinct timeframe, they do show two things: (1) hanging vertically in a harness can cause negative medical effects in a short timeframe, even in the absence of other trauma, and (2) the body's tolerance to suspension trauma varies significantly.
Now, the question becomes: Do you plan for the low, the high, or the mean of the data? Although official OSHA regulations don't provide a specific time, an OSHA Safety and Health Information Bulletin from March 2004 states that "research indicates that suspension . . . can result in unconsciousness, followed by death, in less than 30 minutes." Because no exact time is stated in the regulations, organizations cannot be cited on that factor alone. But there is a precedent for citation based on inappropriate or ineffective rescue plans.2 If a compliance officer sequences the events after an incident and determines negligence in planning or action, citations may result.
The ANSI Z359 standards address rescue in greater detail than OSHA regulations. In ANSI Z359.2, the standard also calls for prompt rescue and encourages at least verbal contact with the fallen victim within six minutes. The standards also calls for written rescue procedures for all active fall protection systems, as well as detailed descriptions of the procedures for summoning rescue services. For information from ANSI about specific rescue equipment and systems, reference ANSI Z359.4.
It is ideal to consider rescue before fall protection solutions are selected and implemented. Doing this allows you to consider options that eliminate rescue, such as engineering controls and fall restraint systems. Employers should understand that by choosing a fall arrest system, they are obligating themselves to develop a rescue plan and corresponding rescue training. These factors should be considered when initially selecting abatement solutions.
If you still need to create a rescue plan or modify one for an existing system, answer these questions first.
1. Who performs the rescue? Rescue procedures should involve both internal and external resources. At a minimum, workers on site need a plan to assess and rescue the fallen worker while the outside experts are responding. Engaging with your local rescue providers during the planning process can be extremely beneficial. When asked to attend a fall protection meeting for a system on a downtown high-rise building, the rescue chief estimated the pre-incident discussion would help orient the crews and save them at least 20 minutes. That translates to getting a fallen worker safely to the ground 20 minutes sooner.
2. Where might rescue be performed? It is important to consider how workers on your site are exposed to fall hazards. These exposure points will vary depending on the industry and environment of the work. You may have all hazards documented through a fall hazard survey or risk assessment, or you might have an inventory of active fall protection systems and equipment. Any of these resources can provide a starting point for locations where rescue is necessary.
3. What equipment do we need? The types of fall arrest systems being used within your organization can impact the rescue equipment needed and the procedures required to rescue a fallen worker. This is vitally important in rescue planning because the type of fall arrest equipment will indicate where the worker will be after the fall. For example, if a worker falls while using an SRL in an overhead position, he will still be close to the original work location. On the other hand, if vertical lifelines anchored to horizontal lifelines are used, a worker could be at a distance from his initial location due to swing fall or system deflection.
Also, keep in mind that the more system types you have, the greater the need for rescue options. For assisted rescue, it is best to keep it as simple as possible. For example, a rescue plan for hazards where the workers are only a few feet off the working surface could simply involve bear-hugging the worker's legs and cutting him or her down. Similarly, a ladder or aerial lift might be an option.
4. How can we perform rescue here? The final item in pre-work is to determine which methods you want to use to get a fall victim to the ground. OSHA lists self-rescue as an option, although it can be dangerous to rely on it completely. How effective are self-rescue systems if the worker is unconscious or unable to move? If a medical incident triggers a fall or trauma is experienced during the fall, self-rescue may not be possible.
Also, when a rescuer is making critical decisions and actions in an intense rescue situation, it is helpful to have the fall arrest line and the rescue line separated on different sides of the victim's body. If the harnesses used in your facility have only a single dorsal D-ring (no chest or shoulder D-ring), this type of assisted rescue may not be ideal.
Once the pre-work is addressed, specific procedures can be created to address each fall protection system. Specific items to include in your rescue procedures are:
- Type of rescue system
- Location of rescue anchorages
- Equipment needed
- Attachment to fallen worker's harness
- Required training
- Specific actions to achieve successful rescue
But even the best rescue procedures will be ineffective if they sit on a shelf or in someone's office. To ensure workers are prepared to execute a rescue if necessary, a coordinated program should confirm that workers are properly trained and rescue procedures are reviewed prior to system use.
After a fall incident occurs, it is important to bring the fallen worker to the ground safely and quickly. That is unlikely to happen without the forethought used to develop and maintain rescue plans. While these proactive steps are critical, it is also important to evaluate all aspects of fall protection after the rescue. What could have prevented the fall? What could have worked better during the rescue? Were the procedures properly followed -- or did we just get lucky?
Don't get caught halfway protecting your workers. If you spend the time, money and resources to protect a worker who goes through a fall, you must take the next steps to ensure his safety. Rescue is not an afterthought or a good idea; it's an essential part of the planning and execution of your fall protection program.
1. 29 CFR 1926.502(d)(20) and 29 CFR 1910.140(c)(21)
2. OSHRC v. East Texas Coating
This article originally appeared in the July 2011 issue of Occupational Health & Safety.
Scott Mirizzi, PE, CSP, is a fall protection consultant who serves as a project manager with LJB Inc. (www.ljbinc.com). He helps clients improve fall protection programs through risk assessment, abatement design, training, and system commissioning.
Mr. Miller is a structural engineer and safety consultant with 20 years of experience. With a thorough knowledge of OSHA regulations and safety standards, he has focused his career on providing fall protection consultation and design services. He has experience in fall hazard risk assessments, abatement design, system inspection and certification, program evaluation, and fall protection training. Mr. Miller also has extensive experience in analyzing structures for appropriate loading and modifying them to meet clients’ needs. He holds a bachelor's degree in civil engineering.