The Scenario
A few years ago, I was called into an industrial client by their Corporate Environmental Health & Safety (EHS) Department to do Personal Fall Protection (PFP) Training for a group of employees. On the day of the training the Plant EHS Coordinator told me the employees would be using Personal Fall Protection (PFP) for the first time.
I asked which type the employees to be trained were going to use. She said they would be using a Fall Arrest System (FAS), which would include an anchorage, a shock absorbing lanyard, and a body harness. Hearing that it was FAS made me somewhat alarmed. I was alarmed as FAS does not prevent falls, but arrests a fall by stopping an employee before hitting the floor. When the FAS arrests a fall it causes shock to a human body, and trauma from hanging in a harness. For these reasons FAS is usually only used as a last resort form of fall protection.
We got the training to a good start until I showed a slide of a drawing with a human character using the FAS equipment as described to me by the coordinator. This drawing demonstrated the FAS equipment would need 18.5 feet to be effective to prevent the employee from hitting the floor after a fall. The supervisor of the group sheepishly raised his hand and I called on him. He said, “Well Tom the fall hazard we are training for is at most 12 feet from the anchorage.
Now We Got a Big Problem
I replied, “Well we got a big problem if your anchorage is only 12 feet off the plant floor. An employee who has fallen will hit the floor. The FAS will be completely ineffective as you can see in this diagram. Your FAS has a lanyard that is 6 feet long, a shock absorber that needs another 3.5 feet to stop a fall, the human in this diagram is 6 feet tall, and you need a 3 feet safety factor above the floor. Your employee will be injured long before the fall is arrested. For your system to save someone in a fall you must have 18.5 feet! I would suggest we complete the training and then we can go look at what you have out there.”
The Problem
About an hour later the supervisor took me out to his lab area where his technicians worked on prototype equipment in development. As we entered the large lab area he pointed to a mezzanine above the work area. Standard guardrails and toe guards protected employees from falling off the mezzanine. The anchorage above the guardrail system along the edge of the mezzanine did indeed appear to be about 11-12 feet off the ground. In the middle of the guardrail system was a 6-foot gate.
Next the supervisor, told me, “Two weeks ago we had a Corporate EHS Audit. A lift tuck was lifting a pallet to the mezzanine with the gate open. The Corporate EHS Auditor saw employees on the mezzanine and reported we had a fall hazard. The auditor merely said, “Put Personal Fall Protection on those guys!” Online I purchased what Fall Protection I thought would work. I also asked someone to get training in here.”
I replied, “Let me get this straight. You put Fall Protection on your employees after a Corporate EHS Auditor made an off-hand comment? Did anyone perform a Hazard Analysis? Next you had to just order equipment yourself. It also looks like you merely picked a ceiling I-beam to be the anchorage. Are you a competent person to make that choice? You must have the knowledge, skills, or training to make a choice like that!”
The supervisor just shrugged his shoulders and said, “I just did what EHS told me, and I thought the anchorage looked safe.”
I thought to myself but did not say, “You cannot blame the supervisor, without direction most people just picture a FAS when they think of fall protection. So that is why he bought it. Up until an hour ago he had no fall protection training. What the heck kind of EHS Department do they have here? No real Hazard Assessment and use of the Hierarchy of Controls, no direction on the PFP equipment, or on the anchorages! This is unbelievable! Heads would role in my old Company for such dereliction of duties!”
Sorry, Not Hired to Fix This – There is a Liability Issue
I left the supervisor with this statement, “My recommendation to you is to get your EHS Department back here and do a comprehensive Hazard Assessment. If they will not do it, get somebody else in here to do it.”
“Next, using a methodology called the Hierarchy of Controls we find safe solutions to your hazard. Just looking at the situation I can think of several options including PFP with some modifications to your plan. Personal Fall Protection specifically a FAS, presents new hazards to the situation. We leaned those in the training we just conducted. Any competent Safety Professional will tell you; FASs are the last thing we want to do to protect employees, certainly never the first! You cannot use the system you have purchased for this application, look at other options. You have spent a lot of time and money on this, and it is in my opinion the wrong course of action. If you use this system you could kill someone or have a very seriously injured employee!”
I have not been back to that customer, so I am not sure what they did do.
I Advise Using the Hierarchy of Controls – As Any Safety Professional Would!
In my opinion the process the customer should have followed would go something like what follows. A Fall Hazard becomes apparent when the gate is opened in the Guardrail System on the mezzanine. The employees cannot be exposed to a fall of 11 feet. The Hierarchy of Controls describes a systematic approach to controlling or eliminating hazards to protect our employees from danger. The Hierarchy of Controls will be used below to protect the employees.
First, we merely want to look at just eliminating the hazard. Can we change the process so that the hazard just does not exist? As in our customers scenario above, can we just stop storing material on the top of the mezzanine? No one would ever go on the mezzanine to be in danger. This is an example of the Elimination Solution. I would call the Elimination Solution an example of the classic “Low Hanging Fruit” solution. The Elimination Step and is always the most desirable and easiest to implement.
In my experience, most industrial plants that I have ever been in have some unwritten rule that says, “If we have a mezzanine we must put stuff on it.” If that is the case, elimination will not work. We then move on to simply trying to negate the hazard by putting something in place (like a guard) or modify the environment in some other way to protect the employee(s). In this case, possibly some sort of sensor that if an employee(s) comes within 6 feet of the edge of the mezzanine the gate automatically closes. With the gate closed the employees cannot fall. Engineering Controls are this type of fixe to control hazards, so that they do not pose a danger to employees.
Third, sometimes Engineering Controls can be impracticable due to their complexity and cost. That is the case above. We then move to looking at ways we can change the method or process of the work. A classic example in ergonomic situations is having the employees rotate work. The hazard is the dose or exposure to repetitive motions. Job rotation may lower the exposure of the hazard to safe levels. In the case above we might make a plant rule that says, “No one may go within 6 feet of an exposed edge where a fall of more than 4 feet could occur!” Administrative Controls are these types of fixes to safety problems. In my experience Administrative Controls are seldom the only fix to a safety problem. However, they are useful and sometimes required in combination with the other types of controls. AS an example. almost anything you do will require training of the employees. Training is an Administrative Control.
Fourth, In the Elimination Step let us say we do make a Plant Rule to keep people 6 feet from any exposed edge. Does that guarantee employees will follow that rule and always be safe? In and of itself, probably not! A serious injury or fatality is quite possible because the exposed edge of the mezzanine remains exposed. It is very likely that an employee(s) will fall someday over the edge. Again the classic line, “It is not a matter of if a fall will occur, only a matter of when will we have a fall,” certainly applies here. Protecting employees is our primary objective! We have not yet fully protected the employees. Since we have mostly ruled out the the above steps we must look at our last line of defense, Personal Protective Equipment (PPE). Any sort of Personal Fall Protection, including Fall Restraint Systems and Fall Arrest Systems are forms of PPE. PPE is always the last control we want to consider as the hazard still exists. PPE is always considered a band aid covering a hazard.
If They Were My Customer
If the customer asked me to help him with this problem I would have completed a comprehensive Hazard Assessment. I would have used the Hierarchy of Controls to give them my final recommendations to protect their employees. These recommendations are:
- A Plant Rule or Work Rule that would say something like this, “No one may be on the mezzanine in the Prototype Lab Area without wearing a functional Fall Restraint System when the guardrail system has an open gate!”
- Contact a reputable supplier of Fall Protection Equipment to get the best advice on the purchase the Fall Restraint Systems.
- If not already in place the plant will need to implement and follow a written Fall Protection Policy.
- Training for all employees using any form of Personal Fall Protection, especially for the new employees in the Lab Area that will be using Personal Fall Protection.
- Training for all employees in the new plant rule concerning the Lab Area Mezzanine.
I hope this article demonstrates how the Hazard Assessment and the Hierarchy of Controls should be practiced. If you have any questions or comments, please let me know. More articles may be found on my website or LinkedIn Profile Page that you may find interesting. If I can be of service either by just bouncing something off me or asking my assistance please do under no obligation! Your feedback is very much appreciated on anything, especially this article. Thank you!
Tom “Fitz” Fitzgerald
Health & Safety Advocate, Trainer, and OSHA Outreach Trainer
920-901-8860
fitz@safetyfitz.com
www.safetyfitz.com
