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Fact or Fiction

By | Fall Protection, Guardrail, Resources, Safety Hazards, Scaffolding, Scaffolding Platforms | No Comments

Fall protection is a huge topic these days what with people falling down and falling from heights.  And since scaffolds are, by definition “any temporary elevated platform,” the issue of fall protection is significant, especially since most scaffold fatalities are due to falls from heights.  It doesn’t have to be this way.  Scaffold suppliers have this really cool product called a guardrail that when used properly, will keep you from falling.  And if you don’t like that, you can always use other stuff to keep from falling to your death.

As you may already know, there are basically two choices when addressing fall protection from scaffold platforms: a guardrail system and personal fall arrest systems.  While not specifically addressed in many safety standards, fall restraint can also be used as a form of fall protection.  Other options are available for fall protection from places like open sided floors and roofs, options that include safety nets, monitoring systems, warning lines and fall protection plans.  It should be noted that lots of safety folks don’t like some of those options since they require workers to behave and we all know that doesn’t always happen.

Experience has indicated to me that when it comes to fall protection, everybody is an expert.  I’m not sure if that is because people fall, making them instant experts, or they think it’s no big deal to “tie off.”  So let’s look at some of these issues and sort out the fact from the fiction.

  1.  Fall protection is required when you are more than 6 feet above the level below.  Fact and fiction!  It depends on the applicable code.  Codes require fall protection at heights ranging from 4 feet to 30 feet.  So find out what the rule is where you are working (or hanging around).
  2. Most workers on construction sites, both commercial and industrial, often use personal fall protection equipment.  Fiction.  Very few workers use personal fall protection equipment.
  3. Many workers wear personal fall protection equipment.  Fact.  Luckily very few workers use it.
  4. Anchors for personal fall protection systems must hold 5,000 pounds.  Fiction.  If the anchor is designed by a qualified person, it must have a safety factor of 2.
  5. If you hook your lanyard (the other end of the rope that is attached to your harness) to an anchor, the anchor must be designed.  Fact.  You cannot guess at the strength of the anchor; if the anchor is not part of a system designed by a qualified person (see #4) the anchor must hold at least 5,000 pounds.  Guessing is not allowed although it appears everybody does it.
  6. The maximum force on the body is limited to 1,800 pounds.  Fact.  This means you better not fall too far before your fall is arrested.  That’s a fancy way of saying that when you reach the end of your rope, the force on your body better be less than 1,800 pounds or there will be two of you.  Incidentally, if the force on your body is limited to 1,800 pounds why does the anchor have to hold 5,000 pounds?  After all, if you pull on one end of the rope with 1,800 pounds, doesn’t the anchor on the other end only have to pull with a force of 1,800 pounds?  Hmmmm-what’s with that?
  7. The 5,000 pound anchor requirement is based on extensive scholarly research and testing. Fiction.  It’s based on the strength of ¾ inch manila rope which is actually 5,400 pounds.  It was lowered to 5,000 pounds in the US federal construction standards to agree with the US federal general industry standards.  So much for science.
  8. You cannot free fall more than 6 feet.  Fiction (sort of).  You can free fall as far as you would like, according to a US federal OSHA Letter of Interpretation.  It’s just that when you get to the end of your free fall, the load on your body cannot be more than 1,800 pounds.  (Now you know how bungee jumping works.)
  9. 100 percent tie off is the same as 100 percent fall protection.  Fiction.  Anybody can do 100 percent tie off; just look at any construction site.  Workers tie off to all sorts of ridiculous stuff.  Like the guy that ties off to the step ladder he is on!  One hundred percent fall protection is easy for scaffold users, but not leading edge scaffold erectors.
  10. I cannot use a scaffold for an anchor.  Fiction.  Some scaffolds make very nice boat anchors.
  11. I can use a scaffold as an anchor.  Fact.  When designed by a qualified person (and perhaps a qualified Professional Engineer) a scaffold can be used as an anchor for a personal fall protection system.
  12. It is difficult to provide adequate anchorage for leading edge erectors and still comply with all the fall protection standards.  Fact.  It’s really tough to get a scaffold to hold 5,000 pounds.  It’s really tough to limit the free fall distance for erectors to 6 feet when they have nothing above them to tie to.  If we waived certain regulations for scaffold erectors, we would eliminate some of the excuses.  For example, is it really necessary for scaffold erectors to have an anchor that can hold 5,000 pounds?  Is it really necessary that the system have a 2 to 1 safety factor.  After all, as long as he/she doesn’t fall to a certain death have we not succeeded?  Something to think about.
  13. Horizontal lifelines are easy to install and use.  Fiction.  While they may be easy to install, they are not easy to use.  The problem with horizontal lifelines is that people never use them.  That’s right; they install them, and hook off but luckily never use them.  If they used them they would be terribly disappointed in the performance of the line.  There is a reason horizontal lifelines are to be designed by a qualified person.  Did you know that an anchor on a horizontal lifeline can see a load of 25,000 pounds if it is not designed properly?  What do you suppose that would do to the scaffold?
  14. All safety consultants and compliance officers are experts in fall protection design and installation.  Fiction.
  15. All scaffold users are experts in fall protection design and installation.  Fiction.
  16. All scaffold erectors are experts in fall protection design and installation.  Fiction.

So much for fall protection– I still think the easiest fall protection is:  Don’t fall.  But then perhaps there’s more fiction in that statement than fact!

Help, I’m Falling!

By | Aerial Lifts, Fall Protection, Mast Climber, OSHA Standards & Regulations, Resources, Scaffolding Platforms | No Comments

Fall protection for aerial lift operators and users, while straightforward in my mind, seems to be a mysterious phenomenon that bewilders the minds of many and produces myths worthy of aNew Yorkbest selling novel!  Fortunately, there is no need for it to be this way.  Admittedly, the Federal Occupational Safety and Health Administration, OSHA, standards that apply to aerial lifts can be a bit confusing, to say the least.  However, once explained, it becomes rather clear as to what is expected of aerial lift users.  Besides the standards, a more basic concept can be applied to fall protection for aerial lifts; that concept is, simply put, what’s the best way to keep users from falling?  You can’t get much more basic than that.  Let’s look at this concept first, and then look at the US OSHA standards to see why they are the way they are.

 

The American National Standards Institute, ANSI, has a number of classifications for the group of equipment known as aerial lifts.  In construction, the four most common types include “Boom Supported Elevating Work Platforms,” “Manually Propelled Elevating Aerial Platforms,” “Self-Propelled Elevating Work Platforms,” and “Mast-Climbing Work Platforms.”  On the jobsite, this equipment is also known as boom lifts, scissors lifts, and mast climbers.  The significance of all this is that boom lifts respond very differently to the requests of the operator than either the scissors lift or the mast climber.  The platform of a boom lift is supported by a single column type strut or beam.  This strut can be vertical, horizontal and any angle in between.  Scissors lifts, as the name suggests, have interlocking diagonal struts that allow the platform to raise and lower vertically directly above the base support.  Mast climbers, as the name suggests, has vertical struts/masts that allow the platform to raise and lower vertically by climbing the mast or masts.  The advantage of the boom lift is that the platform can go up and out, and in some cases, up, out, down and under, while the scissors lift platform and mast climber platform primarily only go up and down, similar to an elevator in a building.   These varying characteristics dictate the type of fall protection that is required.

 

The dynamic motion of a boom lift creates the phenomenon not unlike a catapult.  The boom can store sufficient energy during movement that it can literally launch the operator up and out of the basket.  Scissors lifts and mast climbers don’t develop this type of force and consequently is not normally a concern for fall protection.  What all this means is that on scissors lifts and mast climbers we want to keep the worker from walking/falling off the platform while on boom lifts we want the worker not only to be protected from walking off the platform but also from being launched from the platform.  This means the first line of protection on all lifts is the guardrail system.  For boom lifts it is also necessary to restrain the employee so he/she never leaves the platform.  A fall restraint system is required to do this.  Therefore, on boom lifts, not only is there a guardrail system to protect the employee but also an anchor to hook the fall restraint system to.  Please note that it is a restraint system, not a fall arrest system that is used.  We don’t want to have to catch you after you have been launched but rather to keep you from ever launching!

 

How does this approach to fall protection fit with the applicable regulations, you ask?  Well, first and foremost, comply with the manufacturer’s instructions.  These machines are sophisticated devices and the manufacturer is the authority on fall protection for his/her specific device.  The manufacturer may require more protection than I described above.  For example, scissors lifts may require the occupant to utilize personal fall arrest equipment attached to the specified anchor.  The manufacturer may require other safety devices that are not required by the OSHA standards.  If this is the case, you are expected to comply with those requirements provided they are more restrictive than the OSHA standards.  This brings us to the standards.

 

Aerial lifts are addressed in Subpart L of the Construction Industry Standards, specifically section 29 CFR 1926.453.  These standards are exclusive to aerial lifts.  (Note that the Scaffold General Requirements, 29 CFR 1926.451, do not apply to aerial lifts, as clarified in the first sentence of that section.)  Because OSHA standards cannot reference standards that are not in existence at the time of issuance, 29 CFR 1926.453 references ANSI Standard A92.2-1969 which was the applicable standard in 1986 when the revised scaffold standards were first proposed.  This 1969 standard does not reflect the multitude of machines that have been developed since then; unfortunately OSHA is stuck with this limitation.  Fortunately, OSHA recognizes this limitation and allows that equipment manufactured and used in compliance with more current standards will be recognized to be in compliance with 29 CFR 1926.453.  (See Non-Mandatory Appendix C of the OSHA Scaffold Standards for a list of those standards.)  This leads us specifically to Standard 29 CFR 1926.453(b)(2)(v) which requires that “a body belt shall be worn and a lanyard attached to the boom or basket when working from an [extensible or articulating boom platform] aerial lift.”  A note follows this regulation pointing out that a belt cannot be used for fall arrest but can be used for tethering.  Remember from the discussion above, that if you are properly anchored to the basket of a boom lift, you will never leave the basket and consequently will not be exposed to the forces of a fall.  It should be obvious from all this that if you do not anchor yourself properly you will leave the platform or basket and then we will have to catch you.  In that case you better be wearing a harness or you will probably kill yourself.  Bottom line, use short lanyards when using a boom lift so you never leave the basket.

 

Guardrail systems are used to keep workers from walking/falling off the platform or out of the basket.  Personal fall restraint is required to keep you in a boom lift.  Comply with the manufacturer’s recommendations no matter what type of aerial lift you are using; those requirements may be more restrictive than the OSHA minimum standards.  And a couple of final thoughts:  A 6 foot lanyard used with a restraint belt is a killer, a 6 foot lanyard used in a basket will still allow you to get launched; keep that in mind when you idly hook off so you “look good.”  And if you’re the truck driver loading the boom lift on the truck, watch out—you have a better chance than anybody of getting launched.