Fall Protection (Part 1)

S22. Fall Protection
The purpose of this program is to prevent work-related injuries resulting from falls. The prevention of these incidents will accomplished by the use of fall prevention and fall arrest methods, the training of effected employees and aggressive enforcement by all levels of management.
22.1 This policy applies to all company employees who may be exposed to fall hazards in the course of their daily activities. This program also applies to non-site personnel, visitors or any individual on site exposed to a fall hazard. Unless otherwise specified, fall protection is required at elevations of 6 ft. or greater for the following work activities. Examples of areas were employees may have to be protected include but are not limited to the following:
leading edges, hoist areas, holes in walk surface, framework and reinforcing steel, ramps, runways, and other walkways, excavations, working over dangerous equipment, roofing work on low or steep sloped roofs, precast concrete construction, wall openings, scaffolds, and aerial lifts.
22.2 In addition to the responsibilities previously outlined in the Site Safety Program, the site safety coordinator or designated competent person for fall protection will be responsible for the training of all effected company employees and enforcement of the company policy. Competent persons must be able to recognize, warn and communicate with employees that may be exposed to a fall. Also, a competent person must be designated and assigned the task and be able to accomplish the following while workers are exposed: recognize fall hazards, warn employees if they are unaware of a fall hazard or is acting in an unsafe manner, not have another assignment that would take monitors attention from monitoring the function.
22.3 The instructor shall be adequately trained in the fall protection system in use and shall be responsible for training all potentially exposed employees during the new employee orientation. In the event a new system is employed, additional training on this system will commence immediately for all effected employees. Training will include, at a minimum: the company fall program requirements, identification and elimination of fall hazards on the job site, safe work in hazardous areas, hazards associated with working near fall hazards, selection, use, care and inspection of fall protection equipment.
All training must be documented in the following manner:
a) The date of training.
b) The employees printed name and signature.
c) The printed name and signature of trainer.
d) Testing results (if any).
22.4 Retraining will occur when the employer has reason to believe that any effected employee who has already been trained does not have the understanding and skill required under employee training, the employer shall retrain each such employee. Circumstances where retraining is required include: changes in the work place were previous training is obsolete, changes in the type of fall protection systems or equipment were previous training is obsolete, inadequacies in an employee knowledge or use of fall protection system or equipment indicate that the employee has not retained the training provided.
22.5 All field personnel will be held accountable for the enforcement and compliance with this program. Documented safety inspections, repeat discrepancies, accident investigation and implementation of accident investigation recommendations will provide the criteria for effectiveness of enforcement.
22.6 Hazard Identification and Elimination: Compliance with fall protection requirements will be a mandatory item for all documented safety inspections. Fall protection inspections will focus on the following hazards: scaffolds, ladders, steel erection, roofing, floor holes, open sided floors, and aerial lifts. The hazard identification process shall begin in the pre-bid phase with review of the scope of work, blue prints and drawings. Where feasible, pre-planning will be accomplished to prevent employees from being exposed to fall
hazards.

The following pre-planning steps must be considered:
a) Order and install stairways with the guardrails already attached.
b) Request the designer/architect specify proper anchor points for fall arrest systems.
c) Do not cut opening in the floors or ceilings until the material is being installed, eliminating the need for hole covers. Attach All guardrails on open sided floors before employees are allowed to work on that level.
d) Install stairs, guardrails, and other fall protection equipment early in the construction phase.
e) Require subcontractors to install fall protection systems on horizontal industrial steel prior to installation.
f) Maximize on ground assembly of structure or equipment.
g) Plan for the utilization of aerial lifts for all steel erection and concrete pre-cast erection.
h) Controlled access zones are not allowed for leading edge operation at company locations. The work method employed Will include a horizontal lifeline behind the leading edge, designed for multiple employees, with retractable lanyards attached for employees working on the leading edge. Equipment used will not allow employee to travel into the fall zone of a leading edge. When no other above-mentioned methods have been implemented a safety monitoring system shall be put in place.