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Growing a ‘Culture of Safety’ Mindset

What are the practices and standards that organizations should prioritize when protecting those working at height? An expert shares some insights.

For 12 years in a row, fall protection has topped OSHA’s annual Top 10 Safety Violations. In 2022, fall protection led the rankings with 5,260 citations. For comparison, the number two ranking, hazard communication, trailed behind with 2,424 citations. But let’s be real: statistics only go so far when it comes to tabulating the essentially incalculable human cost of workplace falls.

That’s why it’s critical that companies establish a culture of safety, according to Michael Tavis, who is the director of sales for the western United States and Canada at fall protection equipment maker FallTech. Tavis has been with FallTech for nearly eight years and has worked in construction for 30 years. 

Tavis is an engaged safety professional who has represented FallTech on ANSI’s national committee. When it comes to growing a culture of safety, Tavis says standards play a large role. He sat down with Occupational Health & Safety to discuss the topic at length.

OH&S Magazine: Let’s start with a fundamental question. Why is fall protection safety important in so many industry environments, such as industrial, manufacturing environments, construction and oil & gas? 

Tavis: Falls remain the leading cause of death outside of transportation. When you’re looking at a job site, falls are the number one driver of fatalities in our industry. And if you look more broadly, after fall protection being the number one cause of death, then there are ladders, scaffolding and fall protection training. 

Those are four areas within OSHA’s Top 10 that are associated with individuals working at heights. … So it’s clearly an issue that OSHA recognizes, and it’s something that we all work at trying to mitigate and improve. 

OH&S Magazine: While fall protection is clearly a concern, it’s fair to say that it’s often misunderstood. Why are falls a repeat problem, per OSHA’s Top 10, and why is fall protection misunderstood? 

Tavis: A lot of industries in our trade pay their employees by piece; they’re not hourly employees. So with regard to that, when you’re putting on safety equipment, it impedes productivity fundamentally because if you’re working safer, you’re typically going to be working a little more intentionally, a little slower, and the equipment itself may have restrictions on it. 

For example, if you connect an SRL to your body, you can’t walk as fast as if you’re not connected to an SRL. So, there are limitations with the equipment, and all of that impacts productivity. So, people can be resentful of the fact that using the safety equipment means they’re going to be working a bit slower, which in the end, can potentially cost them money. 

But what we take from that is to try and make the equipment as user friendly as possible and really focus on the user experience. We try and make our products as comfortable and usable as possible. So we spend a lot of time on the fitment of the product and doing our best not to impede productivity. 

OH&S Magazine: Knowing the importance of fall protection, what roles do the standards play in keeping workers safe? 

Tavis: OSHA is the statutory authority in the United States, so from the standpoint of occupational health and safety, OSHA is the enforcement authority, and ANSI would be considered best practices. There are scenarios where ANSI does work as an OSHA-like enforceable rule. That would be by letters of incorporation, or say, if it’s implicit in the standard. 

For example, if using a piece of ANSI-compliant equipment would have eliminated the fatality or reduced the severity of an injury, then that would fall under the OSHA General Duty Clause. So, in many cases, although ANSI is considered a recommended best practice, the employer is inherently taking on more liability if it fails to observe ANSI, because you can always argue that following ANSI would have potentially eliminated or reduced the severity of an injury. I think it’s always in the users’ and the company’s best interest to align themselves with best practices. That’s what we try to do. 

And the other thing is, we talked before about the user’s comfort, and a more comfortable employee is typically a safer employee. So, if you are producing safety equipment that people perceive as a nuisance and uncomfortable, they’re less likely to use it and use it consistently. If you’re really focused on the user experience, and you’re making sure that people are comfortable in what they do, they’re much more likely to use the product consistently. 

OH&S Magazine: In talking about standards, we mentioned compliance and best practices. How does an organization make that shift from simply being in compliance to fostering a proactive culture of safety? 

Tavis: In my experience, I think a lot of that happens when you connect the profit motive to the safety culture. I think that a lot of times, organizations perceive safety as a cost center of the business. But the larger the organization gets, the more risks only increase. So, if you focus on managing your experience modification rate, reducing incidents, and focusing on safety, it ultimately saves the company money. 

I have numerous instances of customers that we consult with on a regular basis where we show them how to implement safer procedures, safer practices and how, if they’re able to reduce their incident rates, they can save their company millions of dollars. As we know, their mod rate determines what they’re going pay in insurance, and if you look at it very precisely, that is essentially a measure of risk. 

So, if you are looking at safety from the standpoint of managing risk, and you’re able to manage risk to the point where you have a really competitive mod rate, then you will quite literally save money. It will also let you bid on projects that you might otherwise not be eligible for if your mod rate was in excess of whatever the threshold might be. Connecting that safety culture to the bottom line of the organization is key to making sure that you have a safety culture. 

OH&S Magazine: Going back to ANSI standards, are there any updates to the ANSI standards that safety professionals who need to watch out for fall protection should be aware of? 

Tavis: I think the latest iteration of the .14 standard; the Z359.14-2021 standard. The “2021” refers to the latest iteration of the dot 14 device standard. There have been some pretty significant changes to the testing and design requirements of the .14 device standard, and that is going to have a pretty big impact in the fall protection space for sure. 

The legacy standard categorized devices as Class A and Class B SRDs, and that focused on essentially the deceleration distance during an overhead drop for a Class A or Class B device. The new iteration’s Class 1 and Class 2 categories focus more on the potential risk or exposure. They’re more focused on, for example, if a user is anchoring off below the D-ring — that would be more of an application consideration. 

ANSI is trying to eliminate the misuse of product. When a user takes a Class A device or even a Class B device that’s not suitable for a leading-edge application, and then anchors it off at their feet, at that point they’re endangering their life, if they take a fall. What the ANSI committee is trying to do is correct that, and ensure that, when a user has a leading-edge fall hazard exposure, then they’re using suitable equipment for that application. 

The latest iteration of .14 is simplifying the process by essentially saying a Class 1 device is overhead only, and a Class 2 device is by default for leading edge or anytime you tie off below the user D-ring. So now what will happen is anybody that is tying off below their D-ring will be required to be in a Class 2 device, which is by default leading edge. And that should eliminate a lot of the misuse of products which is ultimately responsible for a lot of the fatalities with respect to fall protection. 

OH&S Magazine: Bearing that in mind, how can companies ensure that they’re providing their workers with equipment that meets the necessary standards? 

Tavis: It’s definitely a “buyer beware” market. Unfortunately, there’s no ANSI police, so it is essentially an honor system with respect to manufacturing. 

For example, you can have a company that manufactures soft goods, which would be something like lanyards and harnesses, and they might source the devices from a third party, so they’re not the manufacturer of record for the devices. Then you’ll have manufacturers like FallTech, for example. We make everything in-house, and even the products that we spec, we own the specification. So, from that standpoint, we’re actually manufacturing all of our products from top to bottom. 

So, there is a mix of true manufacturers, straight importers and resellers, and then companies who do some manufacturing but also do a lot of importing and reselling. 

The only way for a user to really determine whether or not their manufacturer is actually following ANSI is to look for the ISO credentials on the test reports. Now, a manufacturer is required to produce a declaration of conformity (DOC), and once the manufacturer produces the DOC, that DOC is required to come with the ISO credentialing agency. So that’s the third-party authority that legitimizes that document. And again, unfortunately, most manufacturers don’t produce DOCs, and of the ones that do, even fewer still actually include the credentialing agency stamp. 

If you really want to audit your fall protection manufacturer, you want to look at their DOC document, and within that DOC document, you want to identify the credentialing agency. At that point, you can audit the credentialing agency via its website and determine whether or not the document is legitimate.

This article originally appeared in the March 1, 2023 issue of Occupational Health & Safety.

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