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“Fall protection is one of the most misunderstood concepts in the construction industry,” says Daniel Paine, president of Innovative Safety, LLC, a construction and industrial safety consulting firm based in Unionville, CT. “Some people think fall protection just means to work safely, and to others it means a safety system that stops you from falling.” Fall protection begins with a plan, and it starts in the design stages, according to Paine. And the American National Standards Institute (ANSI) is changing its fall protection standards. While some of these standards may be more stringent than OSHA requires, the injured plaintiff in a lawsuit can cite ANSI standards as the standard of the industryand those standards will hold up, Paine says. ANSI documents currently contain two fall protection codes. One is Standard Z359, for industrial applications, and the other is Standard A10.32, for construction. Paine says the two will eventually complement each other, but that hasn’t happened yet. Protection by Design “That is new,” says Paine. “These standards have an impact at the design stage. You have to get rid of fall hazards by designing them out or by managing them.” For example, he says, the designer of a structure should warn the contractor about potential instability of the structure during construction. The engineer, or other designer, must tell the contractor where and when fall protection measures will be needed. That covers a range of measures, such as platforms with guardrails, safety nets, and anchorage points for fall arrest systems. Next, during construction, you need a written plan for fall protection. The general contractor, says Paine, needs to require a written safety plan from all subcontractors on the job. And that plan is a written series of logical steps that describe in detail the specific practices, equipment, and means and methods to be used to protect employees against fall hazards. The general contractor should sign off on those plans. “As long as you have a job hazard analysis and have determined your means and methods for handling falls, you’re most of the way home,” says Paine. “You also need to have employees who are trained to recognize hazards, and how to use fall protection measures and equipment to mitigate them. And you need to have a rescue plan. It may be to call 911. But, there should be access to the site for emergency equipment. You may have to create that access. When you use 911, Paine says, you should go to the people at the fire department and hospital, and tell them where your site is. You can even show them the access to it. “Your first solution needs to be to eliminate as many fall hazards as possible, including changing your erection sequences to do this,” says Paine. “For those fall hazards you cannot eliminate, you need to manage. Your first solutions to consider should be passive fall protection solutions. Those are the least challenging. Passive fall protection solutions do not require the wearing or use of personal fall protection equipment. Examples include safety nets, guardrails, work platforms, aerial lifts, or other means and methods that protect an employee from a fall hazard. Active fall protection systems require the use of personal fall protection equipment and are divided into three categories: fall restraint systems, positioning, and fall arrest systems. All three systems require the worker to wear a harness, a connector, and to have an anchorage. Fall restraint systems utilize a harness, a connector, and an anchorage, and are designed to prevent the employee from reaching a fall hazard, such as an edge or a hole. Positioning is the act of supporting the body with a positioning system for the purpose of working at heights with hands free. The fall-arrest system is an assembly of components and subsystems used to arrest a person in free fall. That system must always include a full body harness and connecting means between the harness and the anchorage or anchorage connector. Such connecting means may consist of a lanyard, an energy absorber, fall arrester, lifeline, self-retracting lifeline, or suitable combination of these. Changes in Equipment Changes in active fall-protection equipment include a new strength requirement for the gate/keeper on the hook of all fall-protection equipment, says Paine. Formerly, the keepers on these 5,000-pound hooks were required by OSHA to accept a 220-pound test load. The new standard requires a 3,600-pound test load. “Most manufacturers now offer the 3,600-pound keeper, but there is obviously a whole lot of equipment of the 220-pound variety still in the field,” says Paine. “Should someone fall, and the keeper on the hook is found to be at fault, the failed keeper will obviously be a liability problem.” Fall arresting equipment will probably change in another respect. “When conducting dynamic fall-protection equipment tests using a rigid weight, there is a need to compensate for the fact that a human is not used,” says an article by Gravitec Systems, Inc., published in By Design, a technical publication of the American Society of Safety Engineers. “Historically, a multiplier of 1.4 has been used to compensate for the energy-absorbing qualities of the human body in rigid weight tests. This standard has been applied by all testing agencies, governing bodies, and standards organizations.” Now, recent testing by Gravitec Systems indicates that the 1.4 multiplier may need to be reduced. Reduction of the 1.4 multiplier to reflect current fall-protection technologies, says the By Design article, entails increasing the rigid weight used in dynamic performance drop tests on energy-absorbing lanyards and other fall-arresting devices. If that 1.4 multiplier is reduced in the United States, it would change the standard by which all energy-absorbing lanyards and fall-arresting devices are designed. In Canada, says Paine, the Canadian Standards Association has already moved to a 1.1 multiplier. “In the US, the industry and standards-writing people are looking at the multiplier,” says Paine. “They have drafted standards that would change the equipment dramatically. One possible change is that you would have multiple ratings on shock-absorbing lanyards. We might need different kinds of fall-arresting systems for different kinds of people.” That, he says, would be a drastic change. Daniel C. Brown owns TechniComm, a communications business in Illinois. GEC - March/April 2008
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