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Fall Protection

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Fall Protection Program Summary

This program provides information regarding fall hazards and appropriate means of protection.

Roof view

This program applies to personnel working in a fall hazard situation (i.e. four feet or more to the next lower level at Virginia Tech) in construction and general industry applications, regardless of location. Fall hazards include, but are not limited to:

  • Unguarded edges, such as roofs;
  • Construction activities, including scaffolding;
  • Holes or openings in floors or walls;
  • Working above dangerous equipment;
  • Working near pits;
  • Fixed ladders with ladder safety systems; and/or
  • Aerial lift operation.

For fall hazard and protection information regarding the following, refer to the specific Environmental Health and Safety Program or OSHA regulation.

Departments must ensure that a competent person is designated to provide oversight for all activities involving fall hazards and that personnel using a fall protection system have been properly trained and are following established safety requirements. 

Departments providing Personal Fall Arrest Systems (PFAS) to personnel working in fall hazard situations must ensure that they are in good condition, used correctly, and properly maintained. 


Fall Protection Online Program

Introduction

Personnel shall use effective fall protection systems when working in any situation that presents a foreseeable exposure to a fall hazard. The purpose of this program is to provide guidance for the selection of fall protection systems and the proper use of personal fall arrest systems (PFAS) for work activities involving fall hazard situations. Guidelines are based upon OSHA regulations and industry best practices. 

Each department with personnel who work at heights, or who are expected to use a personal fall arrest system, must designate a competent person to provide oversight for related activities, such as inspection of equipment, evaluation of site conditions, and selection of appropriate fall protection methods. Departments must also ensure that any personnel using personal fall arrest systems are properly trained in safe use and recognition of related hazards.

For the purpose of this program, "work at heights" refers to work locations that are four feet or more above the next lower level, and which are not guarded by an approved means. Unguarded work locations more than four feet above the next lower level must be evaluated by a competent person to determine appropriate fall protection. 

One exception to the fall protection requirements exists where "employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed." The basis for this exemption is that personnel will be exposed to a fall hazard for a greater period of time while installing a fall protection system than they would perform the inspection. It is also assumed that the inspector will be able to perform the inspection without going near the danger zone. Inspections made while construction operations are underway must be done under the same fall protection requirements as workers.

This program focuses on common fall protection systems used by Virginia Tech personnel regardless of location. Where the use of traditional means of fall protection is not feasible or creates a greater hazard, departments should consult with Environmental Health & Safety or their designated safety representative (if applicable).

Responsibilities

Environmental Health & Safety is responsible for developing, implementing, and administering the Fall Protection Program. This involves:

  • Training all operators in the associated hazards and general safe work practices.
  • Maintaining centralized records of training and certification records.
  • Providing technical assistance to university personnel.
  • Evaluating the overall effectiveness of the program on a periodic basis.

Departments are expected to maintain a safe and healthy living, learning, and working environment for faculty, staff, students, and visitors to Virginia Tech.

Departments must identify fall hazards in the area, or tasks involving work at heights, and ensure personnel are properly trained to use fall protection equipment provided.

A designated responsible person(s) to coordinate the requirements of this program with employees is recommended. Designated persons must attend Environmental Health and Safety Fall Protection User training.

  • Employees using personal fall arrest systems must attend Environmental Health and Safety Fall Protection User training and use the equipment in a safe and responsible manner. 
  • Employees must report all falls involving personal fall arrest systems to their supervisor and remove the equipment from service. 
  • Where personnel are working in an area where potential fall hazards exist, but workplace policy does not permit employees to be exposed, Environmental Health and Safety Fall Hazard Awareness level training is required.

Contractors must comply with all local, state, and federal safety requirements, and assure that all of their employees performing work on Virginia Tech properties have been suitably trained and are provided with appropriate personal protection. Contractors must also comply with the requirements outlined in Virginia Tech's Contractor Safety Program. Contractors working at heights, or exposed to a fall hazard situation, on-campus must coordinate such work with their project manager to assure both parties are informed and work activities are coordinated, where necessary. Access to any roof on campus, for example, must be coordinated due to chemical/biological exhausts, RF, noise hazards, fall hazards, and the use of anchor points. Refer to the Roof Access Policy for more information.

Fall Protection Training

Competent persons and personnel who will be using personal fall arrest systems must attend Fall Protection User training offered by Environmental Health & Safety prior to being assigned such responsibilities.

Training will address the following topics:

  • Recognition and nature of fall hazard situations in the work area;
  • Fall hazard evaluation to determine feasible controls;
  • Various types of fall protection systems that may be used;
  • Components of a personal fall arrest system; and
  • Inspection of personal fall arrest systems.

Refresher training is required every 3 years, or under the following conditions:

  • There are changes in the workplace that make previous training obsolete;
  • There are changes in the types of fall protection systems or equipment used that render previous training obsolete; and/or
  • There are inadequacies in the employee's knowledge or use of the fall protection system or equipment that indicate a lack of understanding or skill.

Personnel may also need training in the following areas, if applicable:

Personnel who have existing or potential fall hazards in their work area must complete Fall Hazard Awareness level training. This training is intended to inform personnel of existing fall protection systems that are in place, and must not be overridden. For example, personnel accessing building roofs, which have a sufficient parapet wall around the perimeter, must complete awareness level training to understand the expectations and limitations of existing systems.

Fall Hazards

Fall hazard recognition

At Virginia Tech, a fall hazard exists whenever there is an unguarded working surface more than 4 feet above the next lower level (regardless of whether the work being conducted falls under general industry or construction). This includes work conducted from ladders, roofs, scaffolds, aerial lifts, work above dangerous equipment or areas which may be hazardous if fallen into, such as pickling or galvanizing tanks, degreasing units, unguarded machinery or electrical equipment, a body of water, or other similar situations.

Generally, a permanent means of protection, such as a guardrail system or parapet wall at least 39 inches high, is installed to provide safe access for personnel who must work above or in the vicinity of such hazards; however, where appropriate fall protection does not exist, or where personnel may need to bypass the installed system, other means of protection must be implemented. The designated competent person is responsible for identifying such hazards, evaluating the situation, requiring a feasible means of protecting personnel, and ensuring that the protective system is effective. For assistance, contact Environmental Health & Safety at 540-231-2341. 

Note: Access on many roofs is restricted due to potential respiratory exposures from chemical fume hood exhausts. For more information, refer to Roof Access.

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Fall hazards

Employers are required to provide protection for each employee exposed to a fall. There are many potential fall hazard situations in the workplace that require the implementation or installation of a fall protection system, whether permanent or temporary. Fall hazards are created when there is a fall distance of 4 feet or more to the next lower level. Common fall hazards on campus are listed below where one or more fall protection options must be implemented.

OSHA also defines requirements for dock boards, runways, working above dangerous equipment, repair/service/assembly pits, outdoor advertising, rope descent systems. For more information, visit 29 CFR 1910.28, or contact Environmental Health and Safety at (540) 231-2341.

Fall Protection Options

When selecting a means of fall protection for any given hazard, the hierarchy of controls should be considered in order of elimination first, passive fall protection systems next, then active fall protection systems or administrative controls last. There may be situations where more than one control measure is necessary to reduce the risk of a fall. 

Existing building-specific fall hazard conditions and available fall protection information is available in the Roof Access Program

Removing the fall hazard, or the hazardous work practice or task is the most effective control measure for eliminating the risk of falls from heights. It should always be considered first.  Examples include relocating gauges or valves to ground level, installing gutter guards to reduce or eliminate routine maintenance, using extended pole saws, trimmers, or light bulb changers, or the use of drones for inspections of elevated surfaces. 

Passive fall protection options should be considered next, and include those where the hazard is isolated or separated from personnel. Examples include:

Guardrails

OSHA-compliant guardrails or parapet walls of sufficient height (on roofs) provide a permanent means of fall protection, which are sufficiently provided that they are not misused (i.e. leaning through or over guardrails or walls which could result in a fall). Guardrails may be temporarily installed for the length of the project, or permanently installed where access is more frequent. Openings in walls greater than or equal to 30 inches in height and at least 18 inches wide require a guardrail system or other appropriate means of protection. 

Covers

Holes (i.e. a gap or open space in a floor, roof, horizontal walking-working surface, or similar surfact that is at least 2 inches in its least dimension) must be effectively covered.

  • Covers must be capable of supporting, without failure, at least two times the maximum intended load (personnel, equipment, materials, etc.) that may be imposed on the cover at any one time.
  • Covers used for temporary protection, such as on construction projects, shall be secured in place and marked with the word "Hole" or "Cover" to identify the potential hazard. 
  • Close roof hatches (unless guarded on all sides by a guardrail system) when on the roof to eliminate fall hazards. 

Fall restraint

Fall restraint systems involve securing the person to an anchorage using a lanyard short enough to prevent the person's center of gravity from reaching the fall hazard. Examples include:

Travel restraint systems

Travel restraint systems consist of an anchorage, anchorage connector, connecting device (ex. lanyard), and the body harness to eliminate the possibility of a person from going over the edge of a walking-working surface. 

Positioning systems

Positioning systems are used on vertical surfaces, such as window cleaning, climbing poles, or working on rebar to prevent the worker from free-falling more than two feet. 

Ladder safety systems

Where Ladder Safety Systems are provided for fixed ladders extending more than 24 feet, or as provided on new installations after November 19, 2018, personnel must be trained on the proper use of the system. 

Fall arrest

Fall arrest systems are designed to stop a person after a fall has begun. Systems must reduce the fall force to less than 1,800 lbs. Determine the fall clearance distance when selecting components and the arrangement of a personal fall arrest system.

Personal fall arrest systems

Personal Fall Arrest Systems consist of an appropriate anchor point, connecting device, and full-body harness. Only trained personnel may use such systems. Anchor point selection is critical, and there are several permanent options available across campus depending on the location. Where anchor points are not provided, certain structural members may be used provided they will support the maximum intended load in the event of a fall. 

Safety nets   

Safety nets may also be used to prevent falls to the next lower level; however, they typically are not a feasible option for fall hazard situations on campus.

Work practices or procedures that signal or warn personnel to avoid approaching a fall hazard include the use of designated areas, warning lines, or safety monitor systems. Personnel using these systems must have training on the requirements of properly implementing the option. Administrative controls are the least desirable option and should be considered only when other passive or active systems are not feasible.

Designated areas (work on low-sloped roofs)

OSHA regulations permit the use of designated areas in general industry applications (e.g. maintenance work/activities) when work is being performed at least 6 feet but less than 15 feet from the roof edge, and guardrail systems, safety net systems, travel restraint systems, or personal fall arrest systems are not available. Work must be both infrequent and temporary. All requirements for establishing a designated area must be met in order to use this control.

Warning lines

Warning lines may be used on flat or low-sloped roofs during construction activities to establish an area where work may be performed without additional fall protection within the area. Where work must be performed outside of the warning line, additional fall protection means must be implemented. 

Safety monitor system

Safety monitor systems shall only be considered when all other fall protection options have been deemed infeasible. Other feasible options may include the use of scaffolding or aerial lifts. 

Definitions

Anchor point: A secure point of attachment for equipment such as lifelines, lanyards, deceleration devices, and rope descent systems. 

Authorized: An employee who the employer assigns to perform a specific type of duty, or allows in a specific location or area.

Competent person: An individual who has been trained to identify hazards related to scaffolding, or working conditions that are unsafe, unsanitary, hazardous, or dangerous for employees, and who has the authority to have these hazards eliminated or controlled.

Connecting device: A flexible line used to secure a body harness to a lifeline or directly to a point of anchorage. 

Deceleration device: (Shock-absorber) any mechanism which serves to dissipate energy during a fall. 

Deceleration distance: The additional vertical distance a falling person travels, excluding lifeline elongation, before stopping, from the point at which the deceleration device begins to operate.

Designated area: A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.

Fall arrest: A system used to stop a fall from heights and decrease the impact of forces on a body to minimize the extent of injury. It consists of an anchor point, connecting device (i.e. lanyard or fall limiter with shock absorber), and full body harness. 

Fall hazard: Any condition on a walking-working surface that exposes an employee to a risk of harm from a fall on the same level or to a lower level.

Fall protection: Any equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall.

Fall restraint: Equipment used to keep a person from reaching a fall point, such as the edge of a roof or the edge of an elevated working surface. 

Free fall: The act of falling - before the personal fall protection system begins to arrest the fall.

Free fall distance: The vertical distance a person falls before the fall arresting system begins to arrest the fall.

Guardrail system: A barrier erected along an unprotected or exposed side, edge, or another area of a walking-working surface to prevent employees from falling to a lower level.

Hardware: Buckles, D-rings, snap-hooks, and associated components which are used to attach parts of the personal fall arrest system together. 

Harness: Equipment that has straps that secure around the person wearing it in a manner to distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders, with a means for attaching the harness to other components of a personal fall protection system.

Hole: A gap or open space in a floor, roof, horizontal walking-working surface, or similar surface that is at least 2 inches in its least dimension.

Lifeline: A component of a personal fall protection system consisting of a flexible line for connection to an anchorage at one end so as to hand vertically (vertical lifeline), or for connection to anchorages at both ends so as to stretch horizontally (horizontal lifeline), and serves as a means for connecting other components of the system to the anchorage.

Low-slope roof: A roof that has a slope less than or equal to a ratio of 4 to 12 inches, vertical to horizontal.

Lower level: A surface or area to which an employee could fall (ex. ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials, water, equipment, and similar surfaces and structures, or portions thereof).

Opening: A gap or open space in a wall, partition, vertical walking-working surface, or similar surface with dimensions that are at least 30 inches high and at least 18 inches wide, through which an employee can fall to a lower level. If the inside bottom edge of the opening is less than 39 inches above the walking-working surface, and the outside bottom edge of the opening is 4 feet or move above the next lower level, fall protection is required.

Personal fall arrest system: A system used to arrest an employee's fall. It consists of an anchorage point, connectors (i.e. lanyard or connecting device), and a body harness. 

Positioning system: A system of equipment and connectors that, when used with a body harness, allows an employee to be supported on an elevated vertical surface, such as a wall or window sill, and work with both hands-free.

Retractable lifeline: An automatic tensioning line that pays out and retracts a line at a certain speed and locks or brakes when the speed is exceeded. A type of connecting device. 

Qualified person: One who by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project. 

Self-retracting lifeline/lanyard: A deceleration device containing a drum-wound line that can be slowly extracted from, or retracted onto, the drum under slight tension during normal movement by a person. At the onset of a fall, the device automatically locks the drum and arrests the fall.

Shock-absorbing lanyard: A design that elongates during a fall to significantly reduce fall arresting forces. Also known as a deceleration device. 

Snap-hook: A self-closing device with a keeper, latch, or another similar arrangement which will remain closed until manually opened. 

Travel restraint system: A combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support that a person uses to eliminate the possibility of a person going over the edge of a walking-working surface.

Unprotected sides and edges: Any side or edge of a walking-working surface (except at entrances and other points of access) where there is no wall, guardrail system, or stair rail system to protect an employee from falling to a lower level.

Walking-working surface: Any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area in which work may take place without the use of other means of fall protection.

Warning line: A barrier erected to warn employees that they are approaching an unprotected side or edge, and which designates an area in which work may take place without the use of other means of fall protection.


Frequently Asked Questions

Yes. Persons who work near potential fall hazards of 4 feet or more must attend this training.

Class length: 1 hour

Available online: Yes

When is refresher training required? Every 5 years.

Please refer to the online class schedule for more information.

Individuals who climb ladders that incorporate ladder safety devices (e.g., fall protection) must attend this training. It is recommended that all personnel who use general purpose ladders also attend this training (or the supervisor must assure the employee knows how to use this equipment safely).

Class length: 1 hour

Available online: Yes

When is refresher training required? Every 5 years.

Please see the online class schedule for more information.

Regardless of who owns the equipment or tools used by an employee while on the job, it must be in good condition and in proper working order. Good condition would also include any required safety features of the equipment/tool. Departments permitting employee-owned equipment/tools to be used while on the job are responsible for ensuring it is safe. If the person is injured while on the job because of defective, improper, or sub-standard equipment, it is still work-related. It is our goal, and everyone's obligation, to reduce hazardous conditions in the workplace.

Suspension trauma occurs when the leg straps of a personal fall arrest harness constrict the flow of blood through the veins, resulting in blood pooling in the lower extremities. Lack of motion in an upright position is the main cause. When blood pools in the lower extremities, the heart and brain do not get sufficient blood to function properly, which results in fainting. If the person were standing, the fainting (in a horizontal position) would correct the situation by allowing the pooled blood in the legs to reach the heart - now on the same level. When a person is suspended in a harness and loses consciousness, the harness keeps the person in an upright position and the situation does not correct itself. The longer a person is suspended in an upright position, the higher the risk for suspension trauma and possibly death. Prompt rescue is imperative.

Travel Restraint Systems (TRS) consist of an anchorage, anchorage connector, lanyard (or other means of connection), and a body harness that is used to eliminate the possibility of an employee going over the edge of a walking-working surface. They must be capable of sustaining a tensile load of at least 5,000 pounds.


Documents


Contact Information

Robin McCall-Miller, Occupational Safety Program Manager

Phone: 540-231-2341
Email: rmmiller@vt.edu