Steps to Using Fall Protection Properly: Part 1
I was recently on a visit with one of our new customers to speak with his workers on fall protection basics. This company purchases our harnesses with 3 D-Rings, and their orders are split between the Comfort MAXX and the Construction MAXX Harness. Before I speak to workers, I like to get a strong understanding of their business, trade, and type of jobsite activities. As I listened, I started to realize that none of the workers needed a harness with side D-Rings. Because of the large purchases of harnesses with side D-Rings, I naturally assumed there would be positioning for formwork and connecting rebar, but there wasn’t. So why the need for side D-Rings?
As we discussed the topic, I discovered that the side D-Rings were being used as lanyard keepers. With one end of the lanyard attached to their back D-Ring, the workers would insert the other end (the rebar hook of their lanyard) into the side D-Ring. I asked the safety director if he and his workers knew that there are lanyard keepers about a foot above the side D-Rings, on both sides. These lanyard keepers are designed to break away, they are legitimate and they are ANSI specified. “Why aren’t your workers using the lanyard keepers?” I asked.
His response was, “Because my guys need the belt, and the side D-Rings come with the belt.”
Not a lot of manufacturers produce a belted harness that does not come equipped with side D-Rings. Since I’ve been down this road before, I knew it was not my place to criticize the logic. So, when I trained the group, I made sure to explain the importance of the breakaway lanyard keeper. I explained the potential tripping hazards that using side D-Rings as the lanyard keeper can cause.
This situation of misused products is not uncommon. It takes place in a variety of jobsites, for a variety of reasons.
I wonder how many of the 5,190 workers killed on the job in 2016 died as a result of inexperience, lack of training, or misuse of equipment? A deeper dive into these numbers reveals how important it is that workers know the equipment they are handling and the safety equipment they rely on to keep them safe.
Misuse of equipment not only compromises the effectiveness of the equipment, but sometimes it creates added hazards in the workplace. Some hazards wouldn’t even exist in the first place if it wasn’t for the misuse of the product.
For a manufacturer who works very hard to produce equipment that is reliable at all times and lasts out in the field, we don’t like to see it misused, or even worse, prompt hazards. That’s why this month’s article is going to focus on the steps companies can use to make sure that they are selecting the proper equipment.
Fall Protection: It’s All About the Hierarchy
If I said to you, “Fall protection is not one-size-fits-all,” what is the first thing you would think of? A harness? Maybe it’s more than that. Fall protection should be applied to jobsite applications as well. Your workers absolutely MUST be familiar with the job site application and the equipment they are using.
This is where the hierarchy of fall protection comes into play – Eliminate, Passive Controls, Fall Restraint, Fall Arrest and Administrative Controls. We must also know the basic jobsite applications performed. For example, is the worker in fall arrest, positioning, suspension or any of these combined? It makes a difference.
When it comes to the hierarchy of fall protection, I am happy to report that many companies have made great progress and understand how to execute a job hazard analysis. Once the hazards are identified, the hierarchy can be applied. If this can all be written out, then the company is doing its part to take care of its workers.
Fall Protection: Analyzing Applications
The next step is analyzing the applications thoroughly with as much attention as was given to identifying the hazards. This involves the worker’s activity around those hazards. From the positioning of materials, mixing mortar, assembling a hoist, set up or breakdown of machinery, everything until the last worker walks off the jobsite and the work is completed needs to be analyzed. The deeper the dive into the work that is taking place on the jobsite, the better.
Fall Protection: Know the Equipment
Once we go through the process of identifying, eliminating and controlling potential fall hazards, we move to the next step: the equipment being used. This is true for the machinery and equipment being used to do the job as well as the safety equipment used to protect.
Equipment selection is critical to everyone who will be using it. There are several questions that need to be asked before you invest and place equipment on the jobsite. First and foremost, does the equipment you plan to use meet the required standards? Is it OSHA compliant? This can be determined by reviewing the labels and instructions on the equipment, which is something every safety director, supervisor and competent person on the jobsite should do for themselves. Too many times I have seen a supervisor fall prey to an aggressive salesperson and not actually check the product personally.
Is the equipment suitable for the task? A great example would be to use fall restraint instead of fall arrest while workers are on the rooftop. Why allow the workers to be exposed to a fall when you don’t have to?
In addition, you have to consider the clearance distance from the potential fall all the way to the ground. A good example would be to select a self-retracting lifeline instead of a lanyard because there are objects, such as cross beams, lower level and equipment within 15 feet of where the worker might fall.
Is the equipment compatible with all other equipment on the jobsite? It is possible that one component might not work with the others. The solution is to make sure that components are designed specifically to work with one another. As long as they are labeled ANSI Z359, the components are already designed to meet a specific requirement. Consequently, the components should be compatible with all other ANSI Z359 designed products. This designation is not only provided on the label of each product but should also be included in the instructions. If you are ever in doubt, you need to confirm this by contacting the manufacturer. Instructions and declarations of conformity are located on the Malta Dynamics website.
Fall Protection: Inspection and Maintenance
Once you are certain that the equipment is appropriate for the intended use, it needs to be regularly inspected and maintained. OSHA requires, by law, that all equipment have two levels of inspection. Companies are required to perform a detailed inspection by a competent person – at least once per year. Equipment should also be checked before each use. If the equipment is damaged due to the work environment or activity, additional inspections are most likely required.
The inspection of your equipment and how it is used is so critical to the success of your company’s fall protection program. Here are some simple common-sense considerations:
• Are the selected anchor points and where you have placed your anchor adequate for any potential impact or load forces?
• Are the anchors placed overhead (or as close to overhead as you can get), or are they at the worker’s feet?
• Are the lanyard keepers being used properly to avoid tripping hazards?
Inspecting your equipment and using the equipment go hand in hand. These two elements are so vital to a well-formed fall protection plan. Executing the fall protection plan involves training the workers accordingly. After all, the best game plan in the world is useless if the players don’t know how to execute it. To execute a well-formed fall protection plan, you have to invest in training your workers. This is, at the end of the day, what compliance is all about – training. Training should encompass the plan, equipment, proper usage and inspections.
Until workers are comfortable with the equipment, they tend to avoid using it. Language barriers and avoiding embarrassment both contribute to a poor safety culture. To overcome this, employers have to install a training program that ensures workers know the proper way to use the equipment. Lastly, good employers provide training programs tailored to their specific job tasks and environment.
Ken Hebert Bio
Ken Hebert is the Co-Founder and National Sales Manager of Malta Dynamics and a customer-focused professional who has spent over 20 years in the safety and training industry. To view the safety products his company has created to help keep people safe, visit Malta Dynamics’ website at maltadynamics.com. To receive his free e-newsletter or to speak with Ken about technical safety issues or about Malta Dynamics products, Ken can be reached at firstname.lastname@example.org or call 832-683-6218.