FALL PROTECTION PROGRAM (FPP)

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1910 / 1926 OSHA Fall Protection

Purpose and Scope

According to OSHA, falls are the number one cause of work-related fatalities in the United States.  The purpose of this program is to ensure compliance with local, state, and federal regulations regarding fall protection under OSHA 1910 / 1926 standards, as well as to protect employees, students, and contractors who are authorized to work from height hazards. This program aims to mitigate workplace accidents and incidents by establishing a protocol for affected individuals to recognize and address fall hazards in order to protect themselves and others. This program applies to walking or working surfaces 4 feet or greater above a lower level.  Protection shall be provided for all students and staff who are exposed to potential height hazards at St. Lawrence University.

Standards

OSHA 29 CRFR 1910 – General Industry Standards

  • 1910.21 Walking Working Surfaces
  • 1910.22 General Requirements
  • 1910.23 Ladders
  • 1910.27 Scaffolds and Rope Decent Systems
  • 1910.140 Personal Fall Protection Systems
  • 1910.67 Vehicle-Mounted Elevating and Rotating Work Platforms (Aerial lifts)

OSHA 29 CFR 1926 – Construction Standards

  • 1926.451 General Requirements
  • 1926.453 Aerial Lifts
  • 1926.454 Training Requirements
  • 1926.502 Fall Protection Systems Criteria and Practices
  • 1926.1051 General Requirements for Stairways and Ladders

Definitions

  • Active Fall Arrest System: Equipment used to arrest an individual experiencing a fall from a working level. The primary components are: the anchorage, connectors from the anchorage (such as a lanyard) to the individual, and a full body harness.
  • Anchorage/Anchor Point: Secure point of attachment for lifelines, lanyards or deceleration devices.
  • Authorized Person: A person assigned by the employer to perform duties at a location where the worker will be exposed to the fall hazard.
  • Competent Person/Individual: One who is capable of identifying existing and predictable hazards in the work environment and has the responsibility to inspect fall protection systems for certification purposes.  Persons/individuals are deemed competent through training and hands on experience to possess knowledge about all aspects of the fall protection program and equipment.
  • Dangerous Equipment: Equipment (such as boilers, fuel storage tanks, heavy mechanical systems, etc.) which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment,
  • Designated Area: a space which has a perimeter barrier erected to warn employees when they approach an unprotected side or edge and serves to designate an area where work may be performed without additional fall protection. Designated areas cannot be erected less than 15 feet from an unprotected side or edge and are only allowed for work of a temporary nature such as maintenance of roof top equipment. A designated area must be surrounded by a rope, wire, or chain supported by stanchions.
  • Deceleration Device: any mechanism, such as a rope grab, rip-stitch lanyard, specially woven lanyard, tearing or deforming lanyards, automatic self-retracting lifelines/lanyards, etc., which serves to dissipate a substantial amount of energy during a fall arrest, or otherwise limit the energy imposed on an employee during fall arrest
  • Floor Holes: Openings measuring less than 12 inches but more than 1 inch in its least dimension, in any floor, platform, or other work surface through which materials may fall or which may present a trip hazard.
  • Floor Opening: are openings measuring 12 inches or more in its least dimension, in any floor, roof, platform or other working surface through which a person may fall (examples include skylights, hatchways, stair or ladder openings, pits, or manholes).
  • Guardrail System: A barrier erected to prevent employees from falling to lower levels.
  • Harness: An array of straps secured around a wearer in a manner that distributes the fall arresting forces over the thighs, shoulders, and pelvis, and contains the provisions to be attached to a lanyard, lifeline, or deceleration device.
  • Lanyard: A flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body/belt harness to a deceleration device, lifeline, or anchorage point.
  • Leading edge: the edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered to be an “unprotected side and edge” during periods when it is not actively and continuously under construction.
  •  Lifeline: a component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), and which serves as a means for connecting other components of a personal fall arrest system to the anchorage.
  • Roof: The exterior surface on the top of a building. That does not include floors or formwork which, because a building has not been completed, temporarily becomes the top surface of a building.
  • Roofing Work: The hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. 
  • Safety Monitoring System: A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards.
  • Shock Absorbing Lanyard: A lanyard with an energy absorbing capacity.
  • Snap Hook:  a connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object. Snap hooks are generally one of two types:

1. The locking type with a self-closing, self-locking keeper which remains closed and locked until unlocked and pressed open for connection or disconnection; or

2. The non-locking type with a self-closing keeper which remains closed until pressed open for connection/disconnection. (Prohibited as of January 1998)

  • Toe Board: A low protective barrier that will prevent the fall of materials and equipment to lower levels and provide protection from falls.
  • Unprotected Sides/ Edges: Any side or edge (except at entrances to points of access) of a walking/working surface, e.g., floor, roof, ramp, or runway where there is no wall or guardrail system at least 39 inches (1.0 m) high.
  • Warning Line System: A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, or body belt, systems to protect employees in the area

Roles and Responsibilities

  • Environmental Health and Safety

The department of Environmental Health and Safety (EHS) has the primary responsibility for program administration and development, including:

  • Developing trainings and performing audits
  • Inspection of fall protection equipment semi-annually
  • Inspection of jobsites periodically
  • Reviewing incidents and hazards associated with fall protection
  • Working alongside supervisors and administrators to ensure such requirements are met
  • Collecting and reviewing contractor fall protection safety plans
  • Reviewing this policy on an annual basis and updating as necessary
  • Supervisors

Supervisors overseeing work involving the need for fall protection in any capacity are responsible for the following:

  • Comply with all fall protection requirements
  • Identify all fall hazards and activities in any given scope of work
  • Ensure all affected employees are properly trained and equipped to perform job tasks prior to assignment
  • Ensure all fall arrest equipment and systems are maintained in accordance with manufacturer’s instructions
  • Verify contractors are utilizing proper fall protection while working on SLU property
  • Stop work and inform EHS of any unsafe work practices or upon inspection of faulty equipment
  • Employees

Employees conducting work involving the need for fall protection are responsible for the following:

  • Comply with all fall protection requirements laid out in this program
  • Maintain all Personal Protective Equipment (PPE) required to work from heights
  • Inspect all fall protection equipment prior to use
  • Attend and complete all training requirements necessary to work from heights
  • Report all jobsite hazards and damaged equipment to supervisor
  • Report all falls and accidents immediately to supervisor

Fall Protection Requirements

General Industry (1910)

SLU is classified as a General Industry employer and as such any employee on a walking or working surface 4 feet or greater above a lower level with unprotected sides or edges must utilize proper fall protection.  With the exception of the 6-foot requirement (SLU employees must utilize the 4 foot requirement), SLU employees must follow all Construction Industry fall protection requirements that pertain to the work they are doing, as outlined below.

Construction Industry (1926)

All SLU employees preforming construction type activities must utilize a form of fall protection when working 4 feet or greater above a lower level.  Contractors must utilize a  form of fall protection when working 6 feet or greater above a lower level. Scaffolds used during construction by contractors requires fall protection to be used at 10 feet or more above a lower level.

Every scenario involving a fall hazard must be evaluated on a case-by-case basis to determine the ideal method of protection for employees working in that area. Consider the following when evaluating fall protection measures:

  • Can the hazard be eliminated by bringing work to ground level
  • Can guardrails be erected and used
  • Fall restraints to prevent a person from reaching a fall hazard
  • Fall arrest equipment which stops a fall once it occurs
  • Administrative controls which use work practices to signal or warn an employee of a fall hazard

General Industry Fall Hazards

Loading Docks

Loading docks and other open sided floors greater than 4 feet above the ground must be protected through the use of a chain or standard guardrail system. The guardrail or chain may have removable sections to provide access for loading, but rails or chain must remain in place when access is not required.

Floor and Wall Openings and Holes

For stairway openings, standard railings shall be provided on all exposed sides except at the stairway entrance. A wall opening of 4 feet or more above an adjacent surface shall be guarded.

Open Sided Floors or Platforms

An open sided floor or platform or a runway that is 4 feet or more above the ground level shall be guarded by a standard railing on all open sides except for the entrance. If equipment or materials could fall and create a hazard, then the railing system must include a toe board on each side.

Open Pits, Tanks, or Spillways

Covers or guardrails should be used to protect employees from open pit, tank, and spillway hazards.

Construction Industry Fall Hazards

Arial Lifts and Self-Powered Work Platforms

Body harnesses must be worn with a lanyard or a self-retracting lifeline when working from all elevated mobile work platforms. The point of attachment must be the anchor point of installation and designated by the equipment manufacturer.

Scissor lifts and telescoping lifts that can only move vertically only require fall protection if the lift is not protected by a proper guardrail system.

Aerial lifts cannot be moved while the boom is in an elevated working position and the operator is inside of the lift platform.

Covers

Covers shall be capable of supporting at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any time.

Excavations

For excavation sites where holes are 6 feet deep or greater, the dig site must be protected by a fence, guardrail system, or other form of barricade to ensure workers and pedestrians are protected from fall hazards. 

Holes

Covers, guardrails, or fall arrest systems should be in place over any hole 4 feet or greater where a pedestrian or employee may be walking or working.

Leading Edge

Each employee who is constructing a leading edge 6 feet or more above levels shall be protected from falling by guardrails systems, safety net systems, or fall arrest systems.

Exception: when the supervisor can demonstrate that it is infeasible or creates a greater hazard to use these systems, the supervisor shall develop and implement a fall protection plan which meets the requirements of OSHA 1926.502 (k).

Protection from Falling Objects

Employees are required to wear relevant PPE including a hard hat when exposed to an area that may have falling objects. The following measures shall also be taken:

  • Erecting of toe boards, screens, or guardrail systems to prevent objects from falling from higher levels
  • Erecting of a canopy structure so that those objects would not go over the edge if they were accidentally displaced
  • Barricading of the area to which objects could fall and prohibit employee access to that area

Sloped Roofing Work

Any employee operating on a roof, either low slope or high slope with unprotected sides and edges, and a height of greater than 6 feet from a lower level is subject to appropriate fall protection requirements.

Unprotected Sides and Edges

Each employee on a walking/working surface with an unprotected side or edge which is 4 feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

Fall Protection Systems

Guardrail System (preferred method)

  • Top rail is between 39” and 45” above the walking/working level
  • Mid rail installed halfway between walking surface and top rail
  • Both top and mid rails should be constructed of materials at least one quarter inch in thickness or diameter
  • Toe boards are required for all guardrails on elevated working platforms where employees or pedestrians below are at risk of being struck by falling objects from above
  • Toe boards should be at least four inches in height
  • A high visibility warning line made of rope, chain, or wire should be constructed around all sides of the roof work area

Personal Fall Arrest Systems

Three main components make up the personal fall arrest system, including the PPE the employee wears, the connecting devices, and the anchorage point.

PPE and Connecting Devices

  • Full body harnesses are required
  • Employees must tie off at or above the D-ring of the harness (except when using lanyards three feet or less in length)
  • Harness and Lanyards must have been inspected prior to use, with a thorough documented inspection within the past 6 months
  • Connecting devices can be a rope or webbed lanyard or a retractable lifeline
  • Only locking snap hooks may be used for connection
  • Lanyards and vertical lifelines need a minimum breaking strength of 5,000 pounds
  • The length of a single lanyard should not exceed six
  • Lifelines should be protected against cuts and abrasions

Anchorage

In some cases, structural building components that can be used for anchorage may be preexisting. In the event a temporary anchor must be installed, the following should be considered:

  • Structure must be capable of withstanding at least a 5,000-pound static load
  • Abrasion resistant straps should be used around sharp edges and corners
  • Anchor points should be at a worker’s shoulder height or above to limit a free fall to less than 6 feet
  • Reusable temporary anchors must be compatible with worker’s fall protection equipment
  • Roof anchors must be removed from service upon completion of job
  • Once subject to fall arrest forces, roof anchors must be removed from service and disposed of

Complete System

  • System should be set up where an employee could not fall a distance greater than 6 feet
  • A fall arrest system subject to impact must be removed from service and discarded
  • Fall arrest systems should be visually inspected prior to each use with a more thorough, documented inspection every 6 months
  • Personal fall arrest systems should not be attached to guardrails or hoists

Inspection

Prior to each use, the affected employee shall conduct a visual inspection of each fall arrest system component.  Every 6 months, a more thorough inspection shall be performed and documented by EHS. Supervisors should ensure that employees are regularly inspecting their fall protection equipment and that it is stored properly.  If any components of the fall protection equipment are found to be damaged, the impacted gear must be removed from service and tagged out immediately. The following fall protection components should be regularly evaluated.  Please contact EHS for a more comprehensive list of inspection criteria.

  • Webbing
  • “D” rings/Back Pads
  • Attachment of Buckles
  • Tongue/Grommet
  • Tongue Buckle
  • Friction and Mating Buckles
  • Lanyard Inspection Hardware
  • Web Lanyard
  • Rope Lanyard
  • Shock-absorbing Lanyard
  • Self-Retracting Lanyard/Lifeline

Ladders

The following guidelines shall be met regarding ladder usage on campus:

  • Visually inspect ladder prior to each use
  • When not in use, ladders should be chained against a wall, or laying down horizontally
  • Ladders should be stored out of extreme weather elements
  • Ladders deemed unsafe should immediately be tagged out and placed out of service
  • Use the 4x1 rule: For every 4 vertical feet a ladder extends upward, the base should be placed an additional foot away from the building. (12’ up means 3’ out)
  • Ensure 3 points of contact at all times while climbing
  • Never shift a ladder while standing on it
  • If possible, have a co-worker hold the base of the ladder while working
  • Never lean ladder against cables or wire
  • Ensure ladder locks are secure

Training

All employees who are required to work or may be exposed to fall hazards must be appropriately trained.  Training will vary based on exposure level, but should consist of the following:

  • OSHA fall protection review
  • Fall hazards relevant to a certain work area(s)
  • Procedures for proper use, inspection, and maintenance of fall protection systems and equipment
  • Relevant work and emergency contact information

Contractors

It is the responsibility of the SLU supervisor overseeing any given project or required maintenance to verify that all contractors working above 6 feet are following all applicable guidelines and standards under OSHA 1926.  Contractors who are not utilizing proper fall protection will stop work until the correct safety measures are implemented.  Failure to comply may result in dismissal from work on campus.

Contacts

Environmental Health and Safety:

Pat Gagnon, Assistant VP of Safety & Security & Emergency Management
(315) 229-5555, pgagnon@stlawu.edu

Suna Stone…… Chemical Hygiene and Environmental Compliance Officer (315) 229-5105 smcmasters@stlawu.edu

Dean Manley…… Coordinator, EHS  (315) 229-5339 dmanley@stlawu.edu

Safety and Security:

Dispatch…… (315) 229-5555  security@stlawu.edu

Reviewed By                                                           Date

Nick Ormasen, Dean Manley

02.13.23