4 Things to Know About the Building Owner’s Duty to Provide Fall Protection
Fall protection was OSHA’s most cited violation in 2024. And 2023. And each year since 2010. In the same time span, the U.S. Bureau of Labor Statistics (BLS) has reported an average increase in fatal falls each year.
Fall protection is a top priority for many building owners, employers, and safety teams, but managing a comprehensive fall protection program can be challenging for even the most seasoned safety professionals. This article will highlight the four main components of managing a robust safety program that will protect workers from falls and, hopefully, prevent injury and fatality from occurring at your facility.
1. Identify fall hazards and evaluate how to control them.
The first step in creating a comprehensive fall protection program is to identify all the existing fall hazards in the facility. For best practice, fall hazard assessments should be conducted with at least three specific employees present: the safety manager, the maintenance manager, and a frontline maintenance worker. The safety manager should know minimum OSHA requirements, ANSI guidelines, and corporate safety policies. The maintenance manager should know what work must be performed around the facility, how often, and who will perform those tasks. Lastly, the maintenance worker can provide valuable insight into how those tasks are actually performed, what current safety equipment/procedures are being utilized, and help foresee any issues with incorporating new safety equipment/procedures.
If an organization is interested in efficiently identifying fall hazards and configuring solutions to protect their workers, it is recommended to invite a representative of a fall protection manufacturer to join the facility’s team during their assessment. Fall protection specialists stay up to date on the latest OSHA regulations and ANSI guidelines to advise building owners. Furthermore, they can advise building owners on the pros and cons of various solutions, usually while the assessment is being conducted.
Once hazards are identified, it is essential to evaluate both the probability and the severity of the risk (see graphic below). Assessing hazards according to a risk matrix helps prioritize risk mitigation work. Depending on the hazard, adding control measures can decrease the severity of the risk enough to lower the risk score, even if the probability remains unchanged.
2. Eliminate or control hazards.
After completing the fall hazard assessment, the next step is to identify solutions that will eliminate or control the fall hazard. Building owners should refer to the Hierarchy of Fall Protection Controls when selecting the most effective solution to protect workers. The Hierarchy goes in descending order in the effectiveness of preventing injury from falls:
1 – Hazard elimination
2 – Passive fall protection
3 – Active travel restraint
4 – Active fall arrest
5 – Administrative controls
When evaluating solutions, we should only let the feasibility of a solution, not the cost, determine a decision to progress to a lower level on the Hierarchy.
First, we should attempt to modify how or where the work is being performed to eliminate the fall hazard completely. For example, investing in drop-down light fixtures to avoid workers climbing on ladders to change lightbulbs.
If modifying the work is infeasible, the building owner should attempt to modify the workplace to help prevent a fall. For example, adding perimeter guardrail around a roof’s edge. Guardrail is an extremely effective fall prevention method, as it requires no training and no annual inspection. Also, installation can be straightforward, as many manufacturers offer non-penetrating guardrail options that are compliant with OSHA guardrail requirements.
If modifying the work environment is infeasible, then active travel restraint or fall arrest solutions should be explored, in that order. Active travel restraint is when a worker attaches a connection device to their body harness shorter than the distance from their anchorage to the edge of their walking working surface. This equipment setup restricts the user’s movement so they cannot accidentally fall off their work area. And while this solution offers promising effectiveness in preventing a fall, it requires the utmost vigilance that the user is using their equipment properly.
Active fall arrest is when a worker attaches a shock-absorbing connection device to their body harness and attaches to a nearby anchorage. Active fall arrest does not prevent a fall from occurring but simply mitigates injury if a worker falls. When active fall arrest equipment is used, it is best practice to utilize overhead anchor points whenever possible. Overhead anchorages limit the amount of freefall a user will experience and, in the case of a self-retracting lifeline (SRL), can also significantly decrease the distance required to decelerate the fall victim. Foot-level anchorages should only be used when there is no overhead structure available. Per the latest update to ANSI Z359.14, foot-level anchorages require Class 2 SRLs as they are specifically designed to withstand the extra forces that the equipment will experience.
Administrative controls sit at the bottom of the hierarchy, as there are no means to prevent a fall or mitigate injury. A safety monitor system is an example of administrative control, where one worker is dedicated to visually observing the worker at-heights and communicating when they get too close to the edge of their walking working surface. Solutions like this should only be used in emergencies or when installing more effective fall protection solutions.
3. Train workers on the control.
No matter what fall protection equipment or solutions are decided upon, the employer must train employees to use the equipment properly. Improper use of fall protection can be as dangerous as not using the equipment at all.
Before workers can be exposed to fall hazards, employees must be put through Authorized Person training. This is likely part of initial or onboarding training, typically four- or eight-hour programs. Authorized Person training must, at a minimum, educate workers on the fall hazards in the work area, the procedures to be followed to minimize those hazards, and the correct use procedures of provided equipment. Employers should conduct frequent fall protection training, as it is statistically one of the most common injuries that occur in the workplace. In the spirit of combating one of the deadliest hazards in the workplace, there really is no such thing as “too much” fall protection training. However, OSHA mandates retraining to occur whenever a change occurs in the work environment (e.g., new equipment installed or provided) or when an employee displays a gap in understanding of fall protection policies.
Additionally, every organization must designate at least one Competent Person. The Competent Person is the primary facilitator of an organization’s fall protection program. This training must be certified by a third-party ANSI-accredited trainer, and the certification must be refreshed every two years. The Competent Person is responsible for approving any modifications or additions to the fall protection program, conducting annual equipment inspections, and training employees on the fall hazards in their facility.
4. Document policies and procedures.
Finally, documentation is the final component of managing a comprehensive fall protection program. Really, a fall protection program is simply a collection of documents that organize the company’s fall protection procedures and policies, inspection logs, anchor certifications, and all employee training.
One method of documenting policies and procedures is to note where the company’s policies align with OSHA and ANSI guidelines and the areas where they may exceed those minimum requirements. Remember, OSHA minimums are just the federal government’s baseline expectations to ensure worker safety in the event a bad-faith employer does not hold that same interest. It is recommended that organizations seek to exceed minimum requirements to ensure they provide workers with every resource feasible to protect them from injury and fatality.
Two types of fall protection equipment inspections are required by OSHA: pre-use and annual inspections. Pre-use inspections are performed by the user each time they are about to use their fall protection equipment. While these inspections do not have to be documented each and every time they occur, their existence should be documented in the fall protection program and reviewed in employee trainings.
All fall protection trainings conducted by the organization or third-party visitors must also be documented. The fall protection plan should note who in the company is designated as an Authorized Person and the designated Competent Person(s). Companies should also document when routine fall protection trainings occur and which employees were in attendance.
Documentation is not only required by OSHA for many aspects of any safety program, but it also can help limit a building owner's or employer’s liability. In the rare event an unauthorized user was injured from a fall incident or an employee willingly defied the fall protection program, an organization would need proper documentation to prove their attempts to avoid such behaviors.
Conclusion
Falls are a prevalent hazard in almost every industry. It is the third leading cause of fatality in the general industry and the leading cause among construction companies. However, there have never been more companies and resources available to concerned safety departments that wish to keep their workers safe from falls. If the diligent work of crafting a comprehensive fall protection program is performed, it can provide an organization with a practical roadmap to protect its workers.
It is only fair that if we ask workers to risk their lives to perform essential jobs, we must provide them with the means to perform those jobs safely. Companies can help organizations that need assistance at any stage in developing their fall protection programs, whether it’s initial development, evaluating the program for improvement, training employees, or providing turnkey fall protection solutions. Together, we can save lives.
