Despite the best efforts of safety professionals working to decrease fatalities from falls in the U.S., the trendline is not heading in the right direction.
While the number of serious injuries with days missed from work is decreasing, fall fatalities have been increasing since 2009, according to the U.S. Bureau of Labor Statistics.
This data has led the ANSI/ASSP Z359 standards committee to grapple with the essential question: How can we influence standards to change that?
During a past ANSI/ASSP Z359 Fall Restraint Forum in Chicago, four members of the full and subcommittee discussed how the standards are evolving and highlighted specific sections of the Z359 standards that safety professionals should review to improve their organization’s fall protection programs.
- Thom Kramer, P.E., CSP, LJB Inc., is a safety professional and structural engineer with 26 years of experience who specializes in the assessment and design of fall protection systems and fall protection program development. He is a former chair of the Z359 committee, president of the International Society for Fall Protection and a member of ASSP’s Board of Directors.
- Dan Henn is vice president of operations for Reliance Fall Protection. Since 2003, he has been manufacturing, developing and testing fall protection products and is the current chair of the Z359 committee.
- Kevin Denis has worked in the fall protection industry for more than 30 years and is currently providing technical services to Werner Fall Protection. He is the owner of Work-at-Height, vice chair of the Z359 full committee and chair of the Z359.2 subgroup (fall protection program requirements).
- Adam Rubin, CSP, has 13 years of experience as a safety professional, specializing in the construction industry. A former member of the Z359 committee, Rubin is vice president of safety for Buckeye Partners.
Here are 10 key lessons safety professionals can take away from their discussion.
Key Lesson 1: Conduct More In-Depth Assessments Using Z359.2
Consult the Standards: See Z359.2-2023 Minimum Requirements for a Comprehensive Managed Fall Protection Program, Section 6
While the first element any fall protection program should address is compliance, the recently revised Z359.2 standard requires that an organization take a deeper look, Denis says.
“The assessment is all about data collection. Good information coming in means good decisions going out,” Denis says.
Consider the following elements in your survey:
- Type of fall hazard
- Configuration of hazard
- Exposure
- Frequency
- Height
- Solutions
- Rescue
Your survey should follow the hierarchy of controls, identifying hazards that can be eliminated and substituted, then explore passive and active protections, identify fall restraint or fall arrest systems, and support PPE selection.
“Hazard assessment has this cascading effect through all aspects of your program. That’s why it’s important,” Denis says.
Key Lesson 2: Take a “Small Ball” Approach Using the Hierarchy of Controls
Consult the Standards: See Z359.2-2023, Section 7.1
The lack of focus on the hierarchy of controls has produced some negative outcomes, panelists say.
“We want to eliminate as many risk factors as we can to have the safest possible outcome,” Henn says. “Unfortunately, we often think of PPE as being the first line of defense when actually the opposite is true,” he explains, adding that the Z359 committee is focused on changing that perception.
Henn recommends taking a “small ball” approach to fall protection, and the focus on the condensed hierarchy in the Z359 standards is designed to do that, he says. This approach is akin to a baseball team advancing baserunners deliberately and methodically into scoring position, rather than relying on big hits to win games.
Safety professionals should take graduated steps through the hierarchy to secure successful fall protection without simply relying on single controls such as fall restraint or fall arrest systems.
Rubin offers this example: Steel is the backbone of most structures and the workers who connect steel are often considered the “heroes of the construction business,” he says. “But at the same time, they’re also at the most risk.”
He says construction companies can eliminate 60 to 70 percent of their risk by doing the first several layers of steel erection using equipment like boom lifts and telehandlers. However, adopting this approach requires a fundamental shift in perception away from accepting a fall as a fundamental risk to discovering ways of eliminating it during preplanning, Rubin explains.
Key Lesson 3: Involve Quality Control in Selecting Anchorages
Consult the Standards: See Z359.2-2023, Section 9.2
Anchorages are a key part of any fall restraint or fall arrest system, yet Kramer says they represent “the greatest variability in the fall protection system.”
“The fundamentals of Deming and quality is where you have greater variation, you have greater issues for challenges and bad circumstances,” Kramer adds.
Rubin recommends involving your quality control team by having them ensure the fall protection system is implemented correctly.
“Use your quality control group for more than just a finished product because your fall protection is a finished product, too, and it’s what employees will be tethered or anchored to,” he says.
Kramer recommends following Z359.2, Section 9.2 on anchorages to ensure the achorages you’re using remain certified as these pieces evolve.
Key Lesson 4: Anchorage Height Is Worth Its Own Lesson
Consult the Standards: See Z359.2-2023, Section 9.2
In addition to ensuring the quality of anchorages, you must address their height.
“Get your anchorages as high as possible,” Rubin says. “That should be everybody’s goal.”
Starting with a higher anchorage elevation will improve every measurable metric in fall arrest, Henn adds. It can improve fall protection dramatically.
Key Lesson 5: Use the Right Tool for the Job
Consult the Standards: See Z359.2-2023, Section 9.1 and other individual component standards
In most home improvement stores, you’ll find an aisle dedicated to different types of hammers, each with a specific purpose for a specific job. Fall protection is similar, except the selection is much greater and effectiveness depends on all of the components working together along with the person using their training and procedures.
At first, the range of options may seem overwhelming, but once you understand how the various pieces fit into different categories, the process becomes less intimidating, Denis says.
When it comes to selection between the thousands of different pieces of fall protection PPE, Denis says you have to do your research — talk to vendors, review manufacturers’ websites, discuss with the qualified person and watch videos. Remember to think beyond the individual harness and consider which lanyards and anchorages will best support your overall fall protection system.
“It’s going to take some effort to really understand which risk you’re trying to mitigate and which systems and products are appropriate for your situation,” Henn says. “Having a relationship with a distributor or manufacturer is critical to making those decisions. Give yourself the time and avail yourself of the resources.”
Key Lesson 6: Trust But Verify Products
Consult the Standards: See Z359.7-2019, Qualification and Verification Testing of Fall Protection Products
Every product manufactured according to the requirements in the Z359 family of standards must have a label indicating the standard (i.e., .11 for harnesses, .13 energy-absorbing lanyards, .14 for SRDs) and the version year.
As a safety professional, how do you confirm that a product’s credentials are authentic?
Denis suggests taking two key steps to “trust, but verify” the claims.
- Any product with an ANSI/ASSP Z359 standard number must go through an ISO-17025 accredited lab that follows the Z359.7 testing standards.
- Talk to vendors and manufacturers to understand their quality control steps. Most fraudulent or counterfeit products are ordered online and don’t come from the manufacturers, Denis says.
Key Lesson 7: Standardize Your Systems to Improve Quality
Consult the Standards: See Z359.2-2023, Section 9.1 and other individual component standards
As you adjust and replace parts or combine and reconfigure systems, the panelists recommend you standardize your fall protection components.
“Using a standard system that’s compatible with your fall protection system is absolutely crucial,” Rubin says. “Mixing and matching pieces is a recipe for a bad event.”
Standardizing systems around a single manufacturer can boost quality as well, Kramer says.
Finally, take care of your system parts as you install and dismantle systems and ensure they’re stored and cataloged properly.
“Your employees are putting their lives in this system’s hands so we want to take good care of it,” Rubin adds.
Key Lesson 8: Visualize the Fall Cycle
Consult the Standards: See Z359.2-2023, Section 8.2, and Z359.11-2021 Safety Requirements for Full Body Harnesses
“If we’ve availed ourselves of the hierarchy of controls and we’ve determined we have no choice but to tie off and use an active fall arrest system, we want to stop any fall that occurs as quickly as possible,” Henn says. “If we do that, we’re protecting the integrity of the user by applying less force to the body, the integrity of the system . . . and eliminating contact with objects in the path of the fall.”
Besides elevating an anchorage, Henn says you can achieve this by visualizing the fall cycle. Imagining what a fall will look like will help you determine:
- Is there sufficient clearance?
- Are there obstructions in the fall path?
- Are there swing fall hazards we need to consider?
“If we’ve done a good job with the assessment . . . hopefully we’ve taken care of that and that visualization becomes a spot check of measuring the quality of our safety process,” he says.
Key Lesson 9: Don’t Let Good Procedures Get Dusty (or Ditched)
Consult the Standards: See Z359.2-2023, Section 8
There’s a difference between having rescue procedures and practicing them, the panelists say.
“Sometimes we have a really good program but it’s on the shelf and it’s pretty dusty when you pull it off,” Rubin says.
To prevent this, he recommends 1) having rescue procedures; 2) understanding what they say; 3) having equipment in the right place, ready to go; and 4) practicing the procedures.
It’s important to remember that the procedures are not just part of a written program, workers must know how to apply them so they slow down long enough to assess the fall hazard.
Henn also offers this simple-but-vital guidance: Don’t dump the instructions. He recently showed a group of trainees how most fall fatalities start by removing a product from its package and throwing the package and instructions in the trash. While he admits that may be a little dramatic, the reality is that the instructions don’t often get into the hands of the people who need them most.
“If we can’t manage to put together a bookcase we get from IKEA without reading instructions how do we expect to use a complicated life safety system without them?” he asks.
Key Lesson 10: Training Must Include an “Observation of Performance”
Consult the Standard: See Z359.2-2023, Section 5
Training should always be tied to the assessment, Denis says, not a number of hours.
“Time is not a good measurement of the adequacy of training,” Denis says. “Fall protection training isn’t matured like a first-aid course where you know exactly what you’re going to get . . . it’s a lot more varied and intricate.”
Each item of PPE must be included in the training as well.
The key to the Z359.2 standard is an “observation of performance” training. “That’s where a person puts the harness on and experiences it, whether it’s wrapping a beam strap or connecting a beam slider or connecting a horizontal lifeline,” Denis says.
He equates it to learning how to drive by actually getting behind the wheel.
“Adults typically learn by doing. Experiential training is absolutely quintessential,” Rubin says.
His company has a fall protection simulator employees must go through before being issued equipment, and they must revisit it monthly.
Finally, Kramer suggests all safety professionals take these three steps:
- Consider alternatives to harnesses higher in the hierarchy of controls.
- When you use PPE, focus on the fit of the harness.
- Avoid or eliminate improvised anchorages.
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