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Your Regularly Scheduled Program
by Bob Babin

Fall protection systems are a safety requirement whenever workers are exposed to dangerous fall hazards. Over the last fifteen years, the safety professionals have realized the value of these life-saving systems and installed them in many critical areas, but the task doesn’t end with the initial installation. Regularly scheduled inspections are also important to ensure proper maintenance, performance and compliance.

The recently released ANSI Standard Z359.2-2007, which defines “Minimum Requirements for a Comprehensive Managed Fall Protection Program”, includes several recommended procedures for establishing such a program. This article will discuss their recommendations as well as cover some of the recommendations of the fall protection equipment manufacturers.

Changes Coming in April
Before we delve into the specifics of maintaining your particular program, let's keep in mind that the most general and important techniques and requirements are safety constants, but some of the small details may be subject to change this year. OSHA is currently planning to release their revised Fall Protection Standards for public comment in April. Several people have expressed their concerns over the OSHA process for implementation. The implementation process is going to take some time before the regulations are enacted. When their new policies are introduced to the public, the new standard will initially be released for public comment, a period during which the Standard is not enforced. The “Call for Public Comments” period, which should last approximately sixty days, is a “recess” during which anyone can offer opinions for or against the Standard, as well as their recommendations for modification. Once comments are received from the general public, OSHA will assemble the public comments and consider the recommendations they receive and will attempt to adapt its policy accordingly. This is likely to be a controversial topic, so I think we can all expect the review process to take some time, although OSHA’s stated goal is to have the new Fall Protection Standard enacted in 2008. In other words, the new OSHA Standards will not be enacted immediately upon implementation. The review process must be completed prior to enactment.

Keeping it all together
Managing fall protection equipment requires good planning and coordination. Assuming you have already assessed and equipped the areas where you need fall protection, let’s move on to the training, inspection and maintenance requirements.

Everyone who uses the equipment should be properly trained. The training requirements should include the following:

1. Respect the need for the equipment.
Users must know that the policy of your company includes mandatory usage. A recent death occurred at an Illinois elevator where an employee failed to hook up to an existing fall protection system and a strong wind knocked him off a hopper car resulting in his tragic death. Policies must be announced, documented, and enforced. Warning signs should be prominently displayed where necessary.

2. Training is mandatory.
Users should be familiar with the equipment and know how to use it. Every fall protection system, including such simple items as handrails, requires some common sense. Most people already know enough to respect guardrails on staircases, so let’s address personal fall arrest systems. Regardless of the type of system in question, the manufacturer of the system should provide thorough instructions for its usage and maintenance. Since many people fail to read or simply ignore instructions, it seems prudent to provide basic instructions in a classroom atmosphere.

3. Inspect regularly.
All fall protection equipment should be inspected on a regular basis according to the manufacturer’s guidelines. Those guidelines will typically require a thorough inspection of the entire system by a competent person trained to carefully scrutinize every component. These services are available from every reputable fall protection manufacturer.

4. Know your lifeline systems.
Fall arrest systems including a safety harness and a lifeline are typically used for accessing the confined space inside bins or silos, cleaning rail cars, and traversing tall surfaces like rail cars and trailers. Regardless of the type of system employed, training is very important. These are the key points:

  • How to choose the right size and type of harness, and which D-Ring to use for fall arrest.
  • How to properly adjust a harness.
  • Proper hook up procedures
  • What to do after a fall arrest
  • Maintenance
  • Daily Inspections
  • Annual Inspections

Three items should be inspected before every usage of the system. The harness should be inspected for tears in the webbing, frayed or broken threads, and proper fit to the user. The self-retracting lifeline should be checked to determine if the fall arrest indicator is visible (this is a small red warning indicator attached to the snap hook). Finally, the system itself should be inspected, to be certain it's in good operating condition.

Training help is available
Training is required on an annual basis, preferably by a certified instructor or by a video produced by a certified instructor. The training should include emergency procedures for post-fall arrest procedures. After a fall arrest, the victim may be unconscious or otherwise disabled. Keep in mind that not all falls are caused by slips, trips or simply miss-stepping. The victim may have had a health problem that caused him to fall, such as an epileptic seizure, heart attack, stroke, diabetic seizure, etc. Emergency health care may be necessary, and in the interest of expediency, task assignments for notifying the proper emergency services should have already been planned long before the accident occurs. Rescue and retrieval procedures should be thought out and a written plan developed in advance for such an emergency.

Managing your fall protection program requires good planning. Help should be available from the manufacturer of your equipment, such as the managed Fall Protection Services offered by Fall Protection Systems, Inc.

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