A Guide to Managing the Risks of Working at Height

There were 7,014 Occupational Safety and Health Administration (OSHA) violations related to fall protection in 2019. That same year, 298 workers died because of a fall. More than 20% of those people were working in the construction segment when the incident occurred. There are two ways a person can be injured due to a fall on a construction jobsite:

• A person could fall from their work location
• An object could fall from above onto someone below

Protecting a Person from Falling

For years, the industry has been aware of fall protection for workers at height. “At height” is generally the definition of a work location where a person could be at risk of falling. In the construction industry, that height is 6 feet.

When working on scaffolding, it is 10 feet. A worker at height uses active fall protection, passive fall protection or some combination of the two. A personal fall arrest system (PFAS) is comprised of three components:

• Anchorage (a secure point of attachment for equipment)
• Body wear (equipment designed to be worn on the torso or waste of a person that distributes fall arrest forces and has a means to attach to other components of a PFAS)
• Connecting device (a device used to connect parts of the fall protection system together)

The products are designed to work together to prevent a fall from occurring or, in the event of a fall, to prevent severe injury to the body by arresting the fall. Passive fall protection products are static, nonmoving barriers that prevent encounters with an edge, such as warning lines, guardrails and safety monitoring products. Examples of passive fall protection equipment include cable chokers, rebar chain assembly, lanyards and self-retracting lifelines (SRLs).

The active fall protection category of products includes certain SRLs, such as those designed specifically to accommodate SRLs for leading edges (edges made up of varying substrates that are in between working surfaces), SRL lanyards, harnesses, lanyards, horizontal lifelines (HLLs) and cable chokers.

100% Tie-Off

However, having all the fall protection equipment in the world won’t save a life unless workers at height understand what fall protection fits their application, how to inspect the equipment prior to use, and are adequately trained on how to use the equipment. Often, jobsite workers encounter dangerous situations when moving from one location to another while working at height. Maintaining 100% tie-off allows the worker to remain connected and protected at all times.

In 2017, OSHA mandated the 100% tie-off regulation for fall protection of workers at height. OSHA states that, when the employer can demonstrate that it is infeasible or it creates a greater hazard to use guardrail systems, safety net systems or PFAS, the employer must develop and fully implement a fall protection plan that meets the requirements of 29 CFR 1926.502(K).

Specifically, OSHA 29 CFR 1926.501(b)(1) addresses unprotected sides and edges, and states that each employee on a walking/working surface (horizontal or vertical) with an unprotected side or edge which is 6 feet or more above a lower level, shall be protected from falling by the use of guardrail systems, safety net systems or PFAS.

In certain instances, however, 100% tie-off may not be feasible, given the specifics of a unique work environment, such as when the employer can demonstrate using fall protection equipment poses more of a risk than not using it. The employer is still required to develop a fall protection plan that meets the requirements of 29 CFR 1926.502(k)(5), which calls for documentation of the reasons why the use of the equipment is not possible or is hazardous to the workers’ safety. Components include:

• Warning line systems 29 CFR 1926.502(f)—A barrier erected on a roof to warn employees they are approaching an unprotected side or edge, designating an area in which work may take place without the use of guardrail, body belt or safety net to protect employees in the area.
• Controlled access zone 29 CFR 1926.502(g)—When used to control access to areas where leading edge and other operations are taking place. The controlled access zone shall be defined by a control line or by any other means that restricts access.
• Safety monitoring systems 29 CFR 1926.502(h)—The employer shall designate a competent person to monitor the safety of other employees. The employer also must ensure that the safety monitor complies with OSHA requirements.
• Fall protection that provides 100% tie-off and includes leg lanyards and SRLs—100% tie-off is beneficial considering work tasks, such as moving from an aerial lift basket onto the roof of a building for steel erectors working on a beam.

ANSI/ASSE Z359.2-2017, which addresses the minimum requirements for a comprehensive managed fall protection program, recommends (5.2) Authorized Person Training, with (5.2.2.2) practice training that “shall include instruction and performance assessments of the following … principles of 100% fall protection and how to remain protected while transferring from one fall protection system or structure to another.” Interpreted, this means all authorized persons shall be trained on 100% tie-off.

Dropped Objects Are Hazardous, Too

Tying off a worker to an anchor point is vital for preventing injuries and fatalities. Increasingly, there is greater awareness of the danger caused by tools that fall from a worker at height, onto infrastructure or other people located below. In fact, every 10 minutes, a dropped tool on a jobsite injures someone.

In addition to making sure they are tied off when working, it is important workers take precautions when it comes to securing their tools from a fall. Like people, tools can also be tied off to an anchor point. In most cases, the anchor is the worker’s body; tools are tethered to a belt worn by the worker. Or tools are tethered to storage and transport equipment when they are being lifted to a workstation at height.

When used at height, tools should be tied off with tethers appropriate for the tool’s weight. Tethers should never be overloaded beyond the manufacturer’s published weight rating. They are to be used in accordance with all other manufacturer instructions and should be as short as practical to prevent swing hazards and impact with persons working below if dropped.

Until recently, it was much more difficult to tie-off tools 100% of the time. And there were brief periods when a tool was being transferred from one location to another when a risk of a drop was present because the tool was not connected to anything.

Keeping everyone and everything 100% tied off when working at height is imperative to the team’s safety. The fall protection equipment market continues to advance the concept with intuitively designed products that make 100% tie-off easy to comply with on the job.