Page 34 - OHS, FebruaryMarch 2023

FALL PROTECTION Is Your Fall Protection Program Falling Short? Consider these three areas to improve your program. BY STEVE CROCKER OSHA’s 2022 list of top-cited standards has been released, and fall protection remains at the top of the list for the 12th consecutive year. According to Bureau of Labor Statistics data, fatalities caused by falls from elevation continue to be the leading cause of death for construction employees, accounting for over one-third of the 1,008 preventable fatalities in 2020.1 As those deaths were preventable so too were the $31 million in OSHA fines received by construction businesses in 2021 for violations of the duty to have fall protection standards. Advancements in fall protection technology paired with a heightened focus on a business’s safety program should cause the number of citations, injuries, and fatalities from falls to decrease. Successful fall protection programs do more than simply aim to comply with standards and protect your employees. A proactive program can help to lower your Total Recordable Incident Rate or Experience Modification Rate, keeping your insurance costs in line while helping you better compete. There are three key areas to consider when optimizing your fall protection program: 1. Training Consider your fall protection training curriculum. Is your training content relevant and appropriate for each role? Does it address hazards present during the tasks performed by your workers? Design your programs to provide individuals with focused and relevant information. Doing so allows your training content to be more easily absorbed and implemented by the worker. Next, consider how that training curriculum is being delivered. Maintaining a regular cadence of training is important, but you must also ensure that you are delivering content in an engaging manner. For example, consider adding a hands-on component to your training rather than gathering folks in a conference room to present a PowerPoint. Get the trainees into their harnesses and have them look at the lanyards and anchor points. Programs that include this type of physical, active participation often help learners better retain the presented information. You can also make the content more relevant to the trainees by explaining the “why” behind each requirement. Remember, effective safety cultures require employee buy-in. Providing the rationale behind your program components rather than demanding compliance helps secure participation. And, of course, maintaining thorough documentation detailing when the training occurred and who participated is also a requirement. Lastly, consider who is delivering your training and their qualifications. Construction standards require a competent person to perform training.2 This means that in addition to being qualified by any other means, your designated fall protection trainer must have completed Competent Person training that properly credentials them to supervise, implement and monitor fall protection program. Ensure your trainer can identify hazards, has the authorization to execute the session and possesses the right soft skills for delivery. 2. Inspections Regular inspections are crucial to ensuring that fall protection systems are in proper working condition. OSHA’s fall protection systems criteria and practices standard (1926.502) states that “personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and defective components shall be removed from service.”3 An OSHA letter of interpretation states that, “OSHA believes it is critical to inspect equipment before each use; otherwise, employees may use defective equipment which could result in loss of life in the event of a fall.”4 It also clarifies that equipment must be inspected by an employee who has been trained by a competent person to perform the inspection. Also, standard 1926.502 states that personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse. Your fall protection program should include equipment inventory management. This process will assign a unique identifier to each piece of equipment, the brand, type of equipment, its inspection history, when it was first used and when it was decommissioned. Compliance and adherence to inspection protocols do not guarantee a safer work environment. Your safety program must also foster a safety culture where all employees feel empowered to stop working in unsafe conditions. 3. Oversight Program Does the manager of your fall protection program have visibility into all the potential hazards on the construction site? A single individual who is familiar with the hazards on the jobsite should oversee the full fall protection program and design it in a way that allows for flexibility, given hazards on the jobsite that may change from day to day. After building this program, this person should identify how each person will bring this plan to life on the job site. Sometimes, the fall protection program manager will travel to each location to oversee the program. In other cases, they may create the program and, in turn, train supervisors at each specific job site to help implement and maintain the program. Steve Crocker is the senior vice president and general manager of U.S. construction for Wesco International. He has been with Wesco for over 30 years, holding progressive leadership roles in sales and operations in both Canada and the United States. REFERENCES 1. www.bls.gov/data/ 2. www.osha.gov/competent-person 3. www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.502 4. www.osha.gov/laws-regs/standardinterpretations/2003-12-18 34 Occupational Health & Safety | FEBRUARY/MARCH 2023 www.ohsonline.com