This interview has been edited for length and clarity.
Falls are consistenly one of the leading causes of workplace injuries and fatalities. The recently updated ANSI/ASSP Z359.2 standard provides guidance on how to develop an effective fall protection program to prevent incidents and better protect workers at height.
Kevin Denis, chair of the ANSI/ASSP Z359.2 subcommittee, recently joined “The Case for Safety Podcast” and spoke with host Scott Fowler about the latest Z359.2 updates you need to understand.
Fowler: What is the purpose and scope of Z359.2?
Denis: This is a great standard to follow for any employer that has people who work at height and are exposed to falls from elevation. The intent is to provide direction to employers to protect their workers at height by managing their program, identifying fall hazards, developing adequate control methods, implementing training, and purchasing equipment and PPE.
Fowler: What are the major updates to the latest version of the Z359.2 standard?
Denis: There are editorial changes as well as content changes. The first change that readers will notice is that we moved away from the standard two-column format to a standard single page. This makes the document much more readable on mobile devices and tablets. Illustrations have moved to the inside of the document where they occur in the text. All of the sections have been reviewed and reorganized.
The first major content change relates to the hierarchy of controls. There's more succinct language that provides direction and requires employers to use of the hierarchy of controls, take steps to eliminate fall hazards and use passive control measures before automatically defaulting to PPE.
Before use and periodic inspections of fall protection equipment are now defined and requirements are written around them. These two categories of PPE inspection have always been in the standard, but there wasn't an adequate definition of what the differences were. Rope access content has been removed from Z359.2 since it is now included in the Z459.1 standard. Certain qualified person requirements have also been removed.
The unique training requirements for authorized persons, competent persons, qualified trainers, rescuers and program administrators are all now detailed in one section of the standard rather than repeating the content for each section. This makes the document easier to navigate and understand for users.
Fowler: How can Z359.2 help safety professionals and employers improve their fall protection systems?
Denis: Z359.2 provides direction for employers to identify and collect data on fall hazards, and offers solutions for mitigating risks using the fall protection hierarchy of controls. There are additional sections on how to properly inspect, store and maintain equipment, identify and certify anchorage, conduct incident investigations, and evaluate program effectiveness.
It’s also a road map to identify authorized persons, competent persons and qualified program administrators, and lists responsibilities for each of those roles. It also offers guidance on how to train those people according to your work site.
Fowler: What is the purpose of a fall hazard survey?
Denis: For me, the fall hazard survey is the most important section in the standard. It requires employers to get an education and collect data on each and every hazard that people will encounter.
Employers should ask themselves:
- How often is a certain hazard encountered?
- What is the duration of exposure for each employee?
- Where is the physical location?
- Are there conditions that make the risks higher or lower?
- Is there an effective rescue plan?
When an employer does a fall hazard survey, that information sets up all of the other sections of the fall protection program. It tells an employer very clearly what equipment is needed, what the training requirements are, how many authorized people there are and how many competent people are needed.
Fowler: What training should be involved in working at height and using fall protection equipment?
Denis: The information gathered during the fall hazard survey sets up the training needs assessment, which is used to identify what equipment is being used by each authorized person and train accordingly.
The standard requires that training include experiential exercises, which means that it must include physical hands-on activities where the authorized person has the opportunity to touch, wear and carry the equipment and feel how it's used. They should connect every piece together and understand fall distances and clearance estimates. It’s important to note that the standard doesn't require any training or equipment in excess of what is revealed in the survey.
Fowler: How can safety professionals and employers use the hierarchy of controls to address fall hazards?
Denis: The nice thing about the fall hazard hierarchy of controls is that it's universally applicable. It's a methodical process where an employer can look at a fall hazard and systematically work through the hierarchy of controls. If they do a good job on the fall hazard survey and they know the frequency, duration, exposure and location of those fall hazards, the right solution usually appears quite easily.
A problem in fall protection is that many times, people automatically default to harness-based systems. The hierarchy of controls empowers an employer to slow down, look at that fall hazard and determine if there is a creative way to eliminatate that task.
If there is any way you can accomplish the same task without having a person up at height, that's always the best solution. Many times, different processes or equipment can eliminate the hazard. If you can, have project planners, architects and engineers work at the design stage to relocate equipment and put up parapets and guardrails. Ask the people doing the work if there is another way that would prevent their exposure to the fall. Many times, you'll be surprised by the answer.
Using the hierarchy of controls always puts the best foot forward in regards to protecting the people exposed to fall hazards. It gives employers direction for every fall hazard to help them determine if hazards can be eliminated, if passive controls would be feasible, or if they need to move to the next step of travel restraint or fall arrest.
Fowler: Anything else you’d like to add about Z359.2?
Denis: The standard works for small and large employers alike. If an employer has people up at height, it provides direction to identify hazards and then train people accordingly. I can't stress how important the fall hazard survey is — that's the genesis of the entire program.
Workplace Falls are Preventable
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