Railroad cars can exceed 15 feet in height and present a very unstable walking surface, which is why in many countries the use of fall protection equipment is mandatory for workers at grain facilities and other places where trains are loaded and unloaded.
A quality fall protection program not only makes fall protection equipment and systems available to employees, but provides them with detailed instruction on how to properly select, operate and maintain them.
Specific written procedures for the pre-use inspection, attachment to, and use of each specific fall protection system must be developed and made available to all workers at the work site, along with a written rescue plan required in the event that a fall is arrested. Workers should be required to follow the written procedures provided and to use all fall protection equipment and systems provided by regulations, manufacturer’s instructions and the employer.
It is imperative that there is full documentation of the worker training as well as the acquisition, inspection, maintenance and retirement of all fall protection equipment and systems.
A fall protection program must be documented in the manner of a formal policy, which should contain sufficient detail to ensure that all workers performing work where fall protection is required and used can do so in a safe manner. Specific subjects should include:
- hazard assessments and recommendations;
- fall protection equipment and system selection and approval;
- specific written procedures;
- documented, formal and practical training;
- issuance and control; and
- maintenance of the equipment and systems along with the program’s periodic re-evaluation.
Fall protection hazard assessments and recommendations for improvements and corrections are really the first steps toward proper fall protection equipment and system selection. Ensuring hazards are identified, assessed and evaluated is vital in order to select “the right tool for the right job.”
An on-site assessment by a qualified person or persons is required in the hazard evaluation process and should include assessing risk factors such as location, frequency and severity of exposure. Once hazards have been recognized and evaluated, a proper fall protection system can be selected, designed and installed. The equipment and systems must be designed and installed to protect workers from falling or, in the event of a fall, minimize the degree of injury. They also must meet any existing governmental safety standards or be approved by a qualified person who may be the program administrator or engineer designated to oversee the task. The type of fall protection systems approved, in most cases, have specific applications and will have some limitations for use.
To remain in use, equipment and systems must be maintained in accordance with all manufacturer instructions and the company fall protection program. Repair and replacement parts must be manufactured, approved and, in most cases, installed by the manufacturer. Any interchange of fall protection parts from one approved device to another should be approved by the manufacturer or design engineer of the fall protection system.
All fall protection equipment must be inspected by the user before each use. It also must be inspected periodically, at least on an annual basis, by a qualified person other than the user. A program may specify more frequent, detailed inspections that are more stringent than the regulations the program falls under. In addition, each engineered, permanent fall protection system will require re-certification as specified by the design engineer, installer, applicable standard or regulation at least annually.
Specific written procedures also must be reviewed annually for correctness, applicability, reliability, regulatory compliance and other legal considerations. The procedures must be authorized by the program administrator and comply with the fall protection program and its policies.
A program should include an approved list of all components and approved devices, including the manufacturer’s name and model numbers, and must be readily available. As equipment changes or is updated, revisions may be necessary on a regular and frequent basis. The list must be used for all purchasing activities, as standardization of equipment is essential in standardizing the program, including the procedures and training.
The program administrator must have the necessary training, educational background and practical experience to adequately perform his or her job. This includes field experience on specific training in fall protection and rescue. In addition, refresher training is necessary on an ongoing basis.
All users of fall protection equipment and systems must receive and participate in both classroom and practical, hands-on training. Practical training should include exposing the user to some type of task scenario and be done only after the in-class theory requirements have been satisfied. For this type of training evaluation, the training personnel must practically evaluate each trainee thoroughly and determine proficiency.
Documentation of the practical training must be provided and followed. Usually, this will be a step-by-step procedure or guide detailing every aspect of the training requirements. Practical training is required for each fall protection system and will include using the specific make and model of equipment the worker will be utilizing at each location.
For the program to succeed, persons who are not trained or qualified to use fall protection equipment or systems must be prevented from doing so.
When fall protection equipment is issued, the physical characteristics of employees who use it must be taken into consideration to ensure correct sizing, etc. Control is established and maintained through the use of a fall protection equipment log. If workers are issued personal fall protection equipment, they must be instructed to keep the equipment under their control to prevent unauthorized use by others.
MAINTENANCE AND STORAGE
Proper maintenance of all fall protection equipment and systems must include proper inspection, cleaning and storage. A visual inspection must be performed on every piece of fall protection equipment before and after each use. Equipment not regularly used, such as rescue equipment, must also be periodically inspected. Inspection procedures will differ depending on the types of fall protection equipment and systems used, whether the inspection is being performed in the field during its use or during annual recertification.
Only manufacturer/factory trained and authorized personnel shall replace or repair the fall protection equipment or system. Substituting parts, even if those parts are from the same manufacturer of devices, must never be done without approval of the manufacturer or design engineer. Maintenance should only be performed by those formally trained to do the work.
Improper storage of fall protection equipment is the leading cause of equipment damage and retirement. Personal fall protection equipment must be stored in such a manner that the equipment does not become damaged or distorted. Proper storage includes:
- Making sure the fall protection equipment does not have other equipment or mechanical devices stored on top of it;
- Protecting the hardware against dust, direct sunlight, heat, extreme cold, excessive moisture and damaging chemicals; and
- Protecting the equipment from mechanical damage by using a storage area where damage from tools or equipment is prevented.
Consideration should be given to having workers demonstrate their competency in fall protection inspection, fitting, use and performance of the rescue procedures.
Where workers are issued their own fall protection equipment, the policy should clearly state that workers are solely responsible for keeping their equipment clean and in good repair. Additionally, they are responsible for reporting defects found in any equipment or system.
In summary, the fall protection program must be the responsibility of a single administrator, inspections must be performed, and proper records must be maintained. A program evolves systematically by first assessing to determine the needs and then selecting and standardizing the equipment and systems based on the needs. Once the equipment and systems are standardized, specific written procedures may be developed and, finally, a formal, documented fall protection training program may be delivered and provided on an ongoing basis.
Wayne Donnelly is president of New Heights Industries Inc., Winnipeg, Manitoba, Canada.