In January of this year I wrote an article titled “A Better New Year?” The article described fatality statistics in the construction industry. If you will recall, in 1997 there were almost 700 fall related deaths which means that, on average, there were at least two deaths per workday attributed to falls! OSHA statistics indicate that typically 19 per cent of these fall fatalities were from scaffolds; in other words, approximately every two workdays a worker dies due to a fall from a scaffold.
Needless to say, there’s room for improvement. The Federal Occupational Safety & Health Administration, (OSHA), has addressed this concern in both Subpart M, Fall Protection, and Subpart L, Scaffolds, by issuing standards that set the minimum requirements for fall protection for exposed workers. While there are a number of methods for minimizing fall hazards, Personal Fall Protection Systems and Guardrail Systems are two of the most common methods that are used. Interacting with these two methods is another aspect of fall protection that is equally important as the hardware, and that is training.
Remembering that fall protection has been required for users of scaffolds since at least 1971, (and certainly before that if you choose to comply with the American National Standards Institute (ANSI) standards), it should be amazing that any scaffold users fall from scaffolds. And yet, we haven’t figured it out yet. Users are still falling in spite of all the requirements. Erectors are falling too. Again, using the OSHA statistics, 11 per cent of scaffold fall fatalities are erectors. That works out to about one erector every three weeks who dies falling off a scaffold. Seems to me that this fact would be good justification for addressing fall protection for erectors.
Safety on the jobsite is based on a number of assumptions. The first assumption is that the standards, regulations, guidelines, and practices are correct and accurate. The second assumption is that the regulations are enforced equally, accurately, and correctly. The third assumption is that those responsible for enforcement are knowledgeable and properly trained. The fourth assumption is that workers are properly trained, knowledgeable, and conscientious. The fifth assumption is that the equipment is designed, manufactured, installed, and used correctly. The sixth assumption is that the first five assumptions aren’t necessary for jobsite safety. Therein lies the problem. If any of the first five assumptions is considered invalid, and consequently not met, safety is compromised and fatalities occur.
Are we assuming too much? Is it possible that the standards are inadequate and that these standards somehow cause fatalities instead of preventing fatalities? As far as I know, there is no evidence of inadequacies in the standards; therefore we are not assuming too much in expecting the standards to be minimum expectations for behavior.
It may be too much to expect equal enforcement of the standards but that has more to do with how often we choose not to meet the standards. In the case of fall protection, we may choose not to employ fall protection measures for a variety of reasons, some valid, some not. Obviously, to say fall protection for erectors cannot be done is the easy answer to a complex question. On the other hand, requiring workers to tie off without a thorough analysis of the situation is equally as hazardous. Consequently, proper evaluation and accurate enforcement of the fall protection standards requires trained personnel, which leads to the third assumption.
How can we expect proper enforcement if we don’t give the enforcers proper training and tools. Is it reasonable to expect anyone to have a thorough knowledge of all the standards, especially when we (that’s all of us) don’t provide funding for the training? How well do you know the standards? Do you know how many there are? I believe that the individual charged with the implementation of compliance with the standards and regulations has a formidable job! In fact, to assume that any individual can master all the standards is unrealistic.
Assuming that the workers are properly trained is a huge assumption that is rarely fulfilled. The evidence shows that we have a long way to go in getting the worker to use proper fall protection, in getting the scaffold erectors to understand proper fall protection techniques, and getting owners to cooperate in providing the hardware so that fall protection can be provided. What’s the evidence? A death every two workdays.
The fifth assumption, that the equipment is designed, manufactured, installed and used correctly assumes many things. While fall protection equipment typically is designed and manufactured to a high degree of sophistication and reliability, improper installation and use can, and does, negate those qualities. Since the user may be untrained, the installation, and therefore the use, of the equipment may be wrong. If all that is wrong, then the potential for death greatly increases, proving that the best efforts by some can easily be negated by the incompetence of others.
Finally, assuming that proper standards, proper enforcement, proper training, and proper equipment are not necessary, is the biggest mistake. We are all in this together, whether we like it or not. What have you done this year to ensure that the standards are accurate, the implementation of those standards is accurate, that those charged with the implementation have the training and tools to do so, that the workers are properly trained, (as required by the standards,) and the equipment is used properly? Good fall protection equipment is useless in the hands of untrained users; good fall protection standards are useless in the hands of untrained users. So, how are we doing?
