Developing a Fall Protection Program

Understanding Regulations and Standards
The fall protection industry has been bombarded with regulations and standards. Understanding these requirements is key to ensuring a safe work environment.

The Occupational Safety and Health Act (OSHA) under Title 29 of the Code of Federal Regulations (29 CFR) assures and enforces safe and healthful working conditions for general industry and construction in the United States. Under the Act, employers have the duty of providing their workers with a place of employment free from recognized safety and health hazards. It’s the law.

The American National Standards Institute (ANSI) and the Canadian Standards Association (CSA) are organizations made up of manufacturers and consumers that establish product performance standards for fall protection safety. Meeting the standards indicates that products pass accepted testing procedures. The standards are not enforceable as law: however, many OSHA regulations are adopted from ANSI standards.

Application of regulatory requirements depends on the specific location, industry and operation of the workplace. In the event of an inspection, the company will be assessed on how well its operation meets the regulatory requirements of each particular job. Employers should obtain copies of the regulations that apply to their work activities and begin a fall protection regulations file.

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Hazard Identification
A well-conceived fall protection program begins with identification of all fall hazards in the workplace. As a general rule, any time a worker is at a height greater than 4 feet (1.2m), a fall hazard exists according to OSHA. Where a fall hazard exists, there are two acceptable options: (1) eliminate the hazard, or (2) provide protection against it. Ideally, it is best to totally eliminate the hazard. Since that is often not possible, however, other measures such as the wearing of personal protection equipment (PPE) are required

Written Fall Protection Plan
Following hazard identification, a written program should be developed specifying how to deal with each hazard. If standardized safe-work practices and operating procedures can eliminate the hazard, then such procedures should be specified. Where hazard elimination is impossible, the plan should state what fall protection measures are to be used, how they are to be used, and who is responsible for overall supervision and training. This program need not be elaborate, but should cover the basic elements of the plan. The program needs to be clearly conveyed and understood by all participants.

Product Selection

The employer must know the types of fall protection products that are available, and decide which would be most suitable for the workplace. Because all work environments differ, it is impossible for the manufacturer to determine exactly which fall protection products will provide maximum protection for each job. By understanding how fall protection products operate and knowing the differences in product functions, the employer can select products that are best suited for its workers

Training
All workers must be trained in the proper use of fall protection equipment before using any fall protection products. Workers must be able to identify potential fall hazards, determine which products to use in specific work environments, demonstrate proper anchoring procedures, etc. Employees must also learn inspection and maintenance procedures and the proper wearing of fall protection equipment.