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When is fall protection required?

Employees in a general industry setting that are exposed to a fall of 4 feet or greater, fall protection is required (OSHA 1910).  In a construction setting, if an employee is exposed to a fall of 6 feet or greater, there needs to be fall protection (OSHA 1926).  In both of these situations, the employer needs to determine what system is best suited for the application.  Solutions would include eliminating the hazard completely, fall prevention, or fall arrest.  Employers would typically like to eliminate fall hazards completely.  If there is a hole or opening that a person can fall through, simply closing that hole, if possible, would be the best choice.  Areas, such as roof tops, where there is a parapet or wall that is less than 42 inches in height, a guardrail system will work.  In situations where an employee must access an area near a fall hazard, a fall prevention or restraint system can be used to prevent the employee from reaching the hazard.  There are situations where an employee must work in an area where an exposure to a fall hazard cannot be eliminated.  Examples would be roofs with slopes greater than 4/12 or 18.4 degrees, or narrow walkways with no railing or protective edges.  Therefore, an employer must use a fall arrest system.


What is the difference between fall prevention and fall arrest?

Fall prevention – These are systems put in place to keep someone from being exposed to or reaching a fall hazard.

Fall arrest – These systems are installed in areas where an authorized person’s exposure to a fall cannot be prevented.  These systems are manufactured and installed to sustain a load of 5,000 lbs per employee attached or to maintain a safety factor of at least two as designed by a qualified person.  Also, they are rigged such that an employee can neither free fall more than 6 feet or contact any lower level (OSHA 1910.66 and OSHA 1926.502)


What is the difference between a qualified person, a competent person, and an authorized person?

Qualified person – This person shall be responsible for supporting the fall protection program.  Their role is as a technical resource to all people involved in a fall protection program.  The qualified person shall be knowledgeable of applicable fall protection regulations, standards, equipment and systems, physical sciences, engineering principles, and mandatory requirements for fall protection equipment and systems used by their employer (ANSI Z359.2).

Competent person – This person shall be responsible for the immediate supervision, implementation, and monitoring of the managed fall protection program.  The competent person is typically a supervisor or foreman who is experienced in fall protection and in a position of authority.  This person shall be knowledgeable regarding fall protection equipment and systems used by their employer and will supervise and monitor the requirements of the fall protection program. (ANSI Z359.2).

Authorized person – Where fall protection is required, the authorized person shall have a working understanding of and follow the employer’s policy and procedures and the instructions of the competent person regarding the use of fall protection.  The authorized person shall properly use, inspect, maintain, store, and care for their fall protection equipment and systems (ANSI Z359.2).


Do I need to comply with ANSI standards?

ANSI standards are technically considered voluntary consensus standards.  This means that they are not written laws or regulations.  However, the standards are recognized as an excellent source of reference material and OSHA can incorporate ANSI and other standards by reference to provide the same force and effect as other OSHA standards.  OSHA has stated that, “ANSI will furnish assistance and support and continue to encourage the development of national consensus standards for occupational safety and health issues for the use of OSHA and others.”


My building has anchors for suspended maintenance operations, is the building in compliance?

OSHA/ANSI standards require that anchors be located to prevent dangerous swing falls and to limit free fall distance.  Suspended maintenance anchorage systems should be reviewed and certified by a registered professional engineer that is qualified in the design of fall protection systems.  Suspended maintenance fall protection design should include review of anchor placement and capacity.  System certification and subsequent annual inspections and recertifications (to be conducted at ten year intervals) should be documented and kept on file for the review and use of suspended maintenance contractors


My building's suspended maintenance contractors use portable equipment for suspension. Is my building in compliance?

According to OSHA 1910.66, “Each transportable outrigger shall be secured with a tie-down to a verified anchorage on the building during the entire period of its use. The anchorage shall be designed to have a stability factor of not less than four against overturning or upsetting of the outrigger.”  Fall protection measures should also be available when working on or moving portable equipment near the edge where they would be exposed to a fall.


Does my fall protection roof anchorage system need to be inspected annually?

Fall protection anchorage should be visually inspected each time an authorized user is about to tie-off to the anchor.  According to OSHA 1926 Subpart M, “Personal fall arrest systems must be regularly inspected.”  ANSI Z359.2 goes further to say that, “fall protections and rescue equipment shall be inspected on a regular basis not to exceed one year by a competent person to verify that the equipment is safe for use.”  Also, “anchorages shall be re-certified when re-roofing or renovating or at periods not to exceed 10 years.” (ANSI IWCA I-14.1)

 

 

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