Introduction

University facility and safety professionals seeking to comply with OSHA standards for rooftop fall protection are met with a myriad of product offerings and vendors ready to propose solutions. The sheer volume of information can be overwhelming as each product claims OSHA compliance and marketing efforts highlight cost efficient, user-friendly performance. For the EHS team seeking OSHA compliance and employee safety while also honoring corporate fiscal responsibility, where should the search begin and what factors should be considered? As prospective vendors offer expertise through partnership, what matrix should be used to ensure those partnerships are qualified? These 10 steps are intended to provide guidance to facility professionals that need to address not just a single hazard, but to implement a managed fall protection plan and ensure compliance for an entire campus of buildings.

1. Create a Managed Fall Protection Plan

The creation of a managed fall protection plan is the first critical step which may be somewhat daunting and time consuming, but proper planning will ensure that the process is a success and conducted only one time. The quick point and click approach for a product with OSHA compliant labels sometimes results in time and capital wasted if the product is not compliant for the specific required application. Instituting a managed fall protection plan is the first step toward a programmatic approach instead of evaluating specific issues on a case by case basis. Essential to this process is a hazard analysis study which should identify applicable factors such as the work task that results in fall exposure, severity of a fall, frequency, duration, environmental conditions, history of incidents or near misses related to the work task, among other factors. The ANSI Z359.2 standard “Minimum Requirements for a Comprehensive Managed Fall Protection Program” is an excellent, well-written resource and should be consulted as the primary guide for establishing a plan. The plan will evolve as you make progress through the next nine steps but establishing at least an outline plan is an essential first step.

2. Partner with an Expert

Depending on the internal depth of experience and bandwidth available to create a managed fall protection plan, successful implementation may require integration of a third party. Partnering with a firm that can provide expertise can streamline the process and minimize scope gaps. Selection of this partner is therefore a critical part of the process, as this partner will eliminate common pitfalls as strategy is created, ensure proper implementation, and assist with ongoing management and maintenance of the plan. It is important to partner with a firm with safety engineering and design expertise, rather than a firm offering a sales representative standing in as a safety professional. Consider these prospective partnerships as you would a typical interview, as the prospective firm and their representatives that will be assigned to your account will become an extension of your own safety management team, potentially for years to come. A review of credentials will help ensure your prospective partner has the capacity to offer expertise and designed solutions.

3. Welcome an Interactive Process

Although your designated fall protection partner will provide expert guidance, it is important to consider input from the workers that currently perform rooftop maintenance tasks and will ultimately be using the designated systems. Because the process will result in changes to means and methods that have been practiced for years, it is important to have both insight and buy-in from key personnel. Also essential is the integration of the University Architectural committee that would have insight or influence regarding any visual impact of any newly installed systems from steel level or from adjacent facilities. In certain areas, building aesthetics may be a major concern whereas other low-profile areas may have no restrictions. Similarly, the operations team will need to comment on any constraints related to new permanently or temporarily mounted abatement solutions to ensure those do not prevent operational functions and maintenance. Interaction with key team members should be ongoing through the process and it’s important to communicate concerns and constraints prior to implementation. The costliest system is the one that must be replaced due to an assumption or misunderstanding; therefore, it is critical to introduce team members early and keep them integrated through the process.

 

4. Identify Fall Protection Hazards in “Plan View” Format

To ensure clarity as to where maintenance must be conducted within a fall hazard, identification in a plan view format is a very helpful visual aid that should be created early in the process. Using a scaled building drawing or satellite view as a background image, a dimensioned overlay of existing hazards can be created and then vetted by key team members. Although a rooftop component may be physically outside of the fall hazard zone, access to the perimeter of the component for maintenance could cause the user to breach the hazard zone and work in violation. Conversely, if a component is partially inside of the fall hazard zone, it is possible that the portion within the hazard does not require periodic maintenance, and this may influence the abatement method. Digital review of this plan view drawing allows for interactive markups and comments that can be considered in the following steps.

5. Use Hierarchy of Controls to Identify Proper Abatement Methods

With preference to best practice, the hierarchy of controls are: Hazard Elimination, Passive Fall Protection, Fall Restraint, Fall Arrest, and Administrative Controls. As a case in point, relocating a 25-ton cooling tower further from the roof edge is likely not a viable or realistic hazard elimination practice, but relocating a 1-ton unit by extending or re-routing lines may be a consideration. Not all hazards can be eliminated, and not all hazards can be protected with measures that would create a passive work environment due to architectural or work access constraints. Although, when passive fall protection is required within view from a prominent location, guardrail systems can often be customized and placed out of line of sight. A successful plan requires analysis of each hazard to determine the most realistic and effective abatement method.

 

6. Establish a Consistent Approach

When a campus safety team responds to fall protection needs on a case-by-case basis, there is a tendency to assign protective measures with that specific case in mind. In a vacuum, the assigned solution may be a great one, but when assessed across the entire campus, other very similar solutions may be less apt to fit the mold. The result of this approach is an assortment of solutions where certain systems be similar in appearance, but with enough variation that the use and training for the various systems do not fully transfer. At best, this approach is difficult and costly to manage. At worst, the system user doesn’t grasp the variation which could result in injury or worse. The concept of establishing a plan for a campus of buildings is a more holistic approach where similar hazards are identified and solutions are then consistently applied. From a training perspective, the user is then well equipped with both the knowledge base and the packaged equipment required to perform the task in a controlled and consistent manner.

7. Designate Most Suitable Products for Each Application

The concept of consistency is critical, but not to the extent that only a single solution is designated universally. As the saying goes, when your only tool is a hammer, everything looks like a nail. Your fall protection partner should offer a full array of solutions, rather than a few preferred solutions that are applied to every hazard without discretion. Exploring the benefits of various solutions is an exercise that will add clarity to the process and ensure that the proper solution is designated for the hazard. For rooftops, non-penetrating solutions are often available but depending on the application, may not always be the most practical or even the most cost efficient. Product application must also consider the existing building structure and its ability to properly transfer the fall protection applied loads, as design and installation of supplemental bracing may otherwise become a surprise expense. The suitability of the product for a given application should certainly consider the number of users and level of training required, where a highly accessible hazard demands a passive solution whenever possible.

 

8. Assessment Should Include Review of Existing Components

Inquiries regarding fall protection needs often originate from corporate audits or incidents. Although the initiative may focus on the assessment of roof hazards where fall protection systems do not yet exist, it is also imperative to include review of all existing components. Special emphasis should be placed on rooftop access and fixed ladders. Access methods are often overlooked but should be considered a high frequency hazard since each rooftop maintenance task first requires access to and from the roof. Proper footing and climbing clearance on a ladder could represent a nominal repair cost to shield liability against a high frequency hazard. Campus portfolios are constructed over a period of years and older ladders with known variances have perhaps become accepted with their faults as known hazards that require special attention. The fall protection hazard assessment is the appropriate time to review all existing access methods for compliance with current standards and inclusion to the master maintenance and inspection schedule as applicable.

 

9. Consider Maintenance, Replacement Costs, and Recurring Costs

The comparison of expected service life, recurring maintenance, and inspection fees can sometimes be difficult to quantify, however an estimation of these expenses will serve as meaningful data prior to procurement, as well as future budget planning. An emphasis on corrosion finish and complexity of the system with regards to replacement or repair is key to this review. In corrosive environments, consider installation of stainless steel or anodized aluminum in lieu of coated or galvanized mild steel. For systems exposed to exterior elements, hot-dip galvanized steel will provide superior corrosion resistance compared to powder coated steel. The proper selection, storage, and documented maintenance of components will protect your investment and reduce annual costs. System implementation may be phased with respect to budgetary planning, re-roofing projects, and other variables. However, annual inspections need not follow the original inspection date and it may be advantageous to complete initial inspections early in order to track in parallel on a campus-wide basis. Consider adding this first inspection to the initial scope of work as not to adversely impact annual maintenance budgets.

10. Share Program Documentation to be Centrally Available with Key Dates Calendared

In tandem with the fall protection plan, creation of a calendared maintenance plan will ensure continued compliance and proper use. Documented user training, system certifications, user instructions, warranties, and similar items should be stored in a central location. The maintenance plan should include some level of automation to ensure proper timing for inspections, maintenance, or training for new system users. Integration of the key system users and decision makers in prior steps is key to ensure buy-in at all levels, but the fall protection plan is only successful to the extent that it is managed and maintained properly. For large campus applications, GIS can be a helpful resource to quickly and universally identify systems once installed, in addition to embedded details related to each specific system. The added functionality of GIS mapping makes information centrally available to all users and provides an additional level of accountability and transparency.

Parting Thoughts

Successful implementation of an effective rooftop safety program is an enormous undertaking. However, taking time at the beginning of the process to create the framework of the program with these 10 steps in mind will help control costs and streamline the process. Communicating anticipated challenges and needs to all team members will keep the project on course as issues arise, and this initial communication will define the team approach that is required for successful execution. Finally, don’t hesitate to contact the fall protection experts at Diversified Fall Protection and Peak Fall Protection for further guidance and service! Our engineering team is very well versed on applicable standards, available solutions and can provide assistance on small project or a campus-wide assessment.

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