Fall Protection Program

Purpose and Objective 

The company is dedicated to the protection of employees from on the job injuries. The purpose of this program is to assist in the identification, evaluation, and mitigation of fall hazards to which employees will be exposed, and to provide specific training as required by OSHA 1910 Subpart D. 

It is the policy of this company to protect employees from injuries by properly implementing safe work practices and consistently enforcing those policies. When properly implemented and maintained, this policy is an important part of an effective fall protection program. By adhering to the rules and regulations in place, work at heights can be done safely and efficiently. 

Definitions 

Anchorage: A secure point of attachment for lifelines, lanyards, or deceleration devices. 

Authorized: An employee who the employer assigns to perform a specific type of duty or allows the employee to be in a specific location or area. 

Buckle: Any device for holding a body belt or body harness closed around an employee’s body. 

Body Belt (safety belt): A strap with means for both securing it about the waist and for attaching it to a lanyard, lifeline, or deceleration device. 

Body Harness: Straps which may be secured about an employee in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders with means for attaching it to other components of a personal fall arrest system. 

Competent Person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees and who has authorization to take prompt corrective measures to eliminate them. 

Connector: A device which is used to couple or connect parts of a personal fall arrest system and positioning device system together. It may be an independent component of the system, such as a carabiner, or it may be an integral component of part of the system (such as a buckle or dee ring sewn into a body belt or boy harness, or a snap hook spliced or sewn to a lanyard or self-retracting lanyard). 

Controlled Access Zone (CAZ): An area in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled. 

Dangerous Equipment: Equipment such as degreasing units, machinery, electrical equipment, etc., which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment. 

Deceleration Device: Any mechanism, such as a rope grab, rip-stitch lanyard, specially-woven lanyard, tearing or deforming lanyards, and automatic self-retracting lifelines/lanyards, etc., which serves to dissipate a substantial amount of energy during a fall arrest or otherwise limit the energy imposed on an employee during a fall arrest. 

Deceleration Distance: The additional vertical distance a falling employee travels, excluding lifeline elongation and free-fall distance, before stopping from the point at which the deceleration device begins to operate. It is measured as the distance between the location of an employee’s body belt or body harness attachment point at the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location of that attachment point after the employee comes to a full stop. 

Designated Area: A distinct portion of a walking/working surface delineated by a warning line in which employees may perform work without additional fall protection. 

Equivalent: Alternative designs, materials, or methods to protect against a hazard which the employer can demonstrate will provide an equal or greater degree of safety for employees than the methods, materials, or designs specified in the standard. 

Failure: Load refusal, breakage, or separation of component parts. Load refusal is the point where the ultimate strength is exceeded. 

Free Fall: The act of falling before a personal fall arrest system begins to apply force to arrest the fall.   

Free Fall Distance: The vertical displacement of the fall arrest attachment point on the employee’s body belt or body harness between the onset of the fall and just before the system begins to apply force to arrest the fall. This distance excludes deceleration distance and lifeline/lanyard extension before they operate and fall arrest forces occur. 

Guardrail System: A barrier erected to prevent employees from falling to lower levels. 

Hole: A gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other walking/working surface. 

Infeasible: Impossible to perform the construction work using a conventional fall protection system (i.e., guardrail system, safety net system, or personal fall arrest system) or that it is technologically impossible to use any one of these systems to provide fall protection. 

Lanyard: A flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. 

Leading Edge: The edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed and formed or constructed. A leading edge is considered to be an “unprotected side and edge” during periods when it is not actively and continuously under construction. 

Lifeline: A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), and which serves as a means for connecting other components of a personal fall arrest system to the anchorage. 

Low-Slope:  A roof having a slope of less than or equal to 4 in 12 (vertical to horizontal). 

Lower Levels: Those areas or surfaces to which an employee can fall. Such areas or surfaces include but are not limited to, ground levels, floors, platforms, ramps, runways, excavations, pits, tanks, material, water, equipment, structures, or portions thereof. 

Mechanical Equipment: All motor or human propelled wheeled equipment used for roofing work except wheelbarrows and mopcarts. 

Opening: A gap or void 30 inches (76 cm) or higher and 18 inches (48 cm) or wider in a wall or  partition through which employees can fall to a lower level. 

Personal Fall Arrest System: A system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, and a body belt or body harness and may include a lanyard deceleration device, lifeline, or suitable combination of these. 

Positioning Device System: A body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning. 

Qualified Person: One who by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his or her ability to solve or resolve problems relating to the subject matter, the work, or the project.   

Rope Grab: A deceleration device, which travels on a lifeline and automatically by friction, and engages the lifeline and locks so as to arrest the fall of an employee. A rope grab usually employs the principle or inertial locking, cam/level locking, or both. 

Roof: The exterior surface on the top of a building. This does not include floors or formwork which, because a building has not been completed, temporarily become the top surface of the building. 

Roofing Work: The hoisting, storage, application, and removal of roofing materials and equipment including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. 

Safety-Monitoring System: A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. 

Self-Retracting Lifeline/Lanyard: A deceleration device containing a drum-wound line which can be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement and which, after onset of a fall, automatically locks the drum and arrests the fall. 

Snap Hook: A connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object. 

Steep Roof: A roof having a slope greater than 4 in 12 inches (vertical to horizontal). 

Toeboard: A low protective barrier that will prevent the fall of materials and equipment to lower levels and provide protection from falls for personnel. 

Unprotected Sides and Edges: Any side or edge (except at entrances to points of access), or a walking/working surface, e.g., floor, roof, ramp, or runway where there is no wall or guardrail system at least 39 inches (1.0 m) high. 

Walking/Working surface: Any surface, whether horizontal or vertical, on which an employee walks or works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel, but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties. 

Warning Line System: A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. 

Work Area: That portion of a walking/working surface where job duties are performed

Responsibilities 

Management 

Management is responsible for implementing, supporting, and enforcing this program. 

Supervisors are responsible for: 

• Compliance with this program at sites under their supervision. 
• Performing safety checks of work operations. 
• Correcting any unsafe practices or conditions immediately. 
• Ensuring employees have the proper tools and personal protective equipment for working on elevated surfaces. 
• Coordinating employee schedules to ensure all involved employees receive training. 
• Notifying the program manager of potential hazards requiring assessments or improvements to the program. 

The program manager is responsible for: 

• Performing routine safety inspections of sites and work operations. 
• Ensuring that an adequate number of employees receive competent personal training and that they can fulfill the responsibilities of performing duties that are assigned to them. 
• Enforcing company safety policies and procedures. 
• Correcting unsafe practices and conditions immediately. 
• Training employees and supervisors in recognizing fall hazards and the correct use of fall protection systems prior to use. 
• Maintaining records of employee training, equipment issue, and fall protection systems used at company jobsites. 
• Investigating and documenting all incidents that result in employee injury. 

A competent person onsite is responsible for the immediate supervision, implementation, and monitoring of the Fall Protection Program. The competent person onsite has an important role for identifying existing and predictable hazards associated with working at heights and has the authorization to take prompt corrective measures to eliminate them. 

Employees are responsible for complying with this program and using the knowledge gained from training to properly protect themselves from falls. They must also report any hazardous conditions which could lead to falls as well as accidents and incidents. 

General Requirements 

Work at heights is prevalent across general industry. It is critical for the safety and health of employees that fall hazards are properly identified and employees are protected by taking precautions and adhering to company policies and procedures. When evaluating worksites prior to work at heights, it is extremely important to recognize when additional hazards may be present and to take measures that will adequately mitigate those hazards. 

Any time an employee must conduct work on a walking/working surface with an unprotected edge or side that is 4 feet or more above a lower level, fall protections must be in place. 

Hazard Identification 

The company will ensure a survey of the worksite is conducted and fall hazards of 4 feet or greater are identified prior to work taking place. When work will be conducted at heights, the proper procedures can be prepared prior to tasks beginning. The survey should develop an inventory of locations and equipment needs to ensure employees are properly prepared and have adequate protection prior to work beginning. 

Hazard Assessment and Fall Protection Plans 

Prior to any work at heights, a hazard assessment will be completed by a competent person. The hazard assessment must include a visual inspection and should identify: 

• The work steps to be performed. 
• The specific hazards that are known or may be anticipated. 

Hazard control measures to be implemented prior to exposure to fall risk. Once the hazards have been identified, they must be mitigated prior to work beginning and documented in the fall protection plan. The hazard assessment must be reviewed by all involved employees before work at heights can be conducted. 

Alternate Fall Protection Plans 

An alternate fall protection plan shall be used if a competent person determines the implementation of conventional systems is either infeasible or creates a greater hazard to employees. All alternative fall protection plans shall: 

• Be written to be specific to the jobsite needs 
• Include an explanation of how conventional fall protection is either infeasible or creates a greater hazard to employees 
• Explain what alternative fall protection will be used for each task 
• Be maintained in writing at the jobsite 
• Meet the requirements of OSHA 

Ladders 

Incorrect ladder use can be hazardous to employee safety. In order to ensure that ladders are used properly, the following general rules must be observed unless the ladder is in use for firefighting, rescue, training, or an integral part of machines or equipment: 

• Ladders must never be loaded beyond the maximum intended load 
• Ladders may only be used on stable, level surfaces unless they are stabilized 
• Portable single rail ladders are prohibited 
• A ladder must not be moved while an employee is on it 
• Ladders used in locations where they can be displaced must be secured or guarded by a temporary barricade such as traffic cones or caution tape 
• The top step of ladders must not be used as a step 

The company will ensure that each ladder used meets the following requirements: 

• Ladder rungs, steps, and cleats are parallel, level, and uniformly spaced 
• Ladder rungs in elevator shafts are not less than 6 inches apart and no more than 14 inches apart 
• General ladder rungs are spaced not less than 10 inches apart and no more than 14 inches apart 
• Fixed ladder rungs and steps must not be more than 18 inches apart 
• Steps on stepstools are not less than 8 inches apart and not more than 12 inches apart 
• Ladder rungs, steps, and cleats must have a width of at least 11.5 inches on portable ladders and 16 inches on fixed ladders 
• Rungs of manhole entry ladders must have a minimum width of 9 inches 
• Runs on rolling ladders and telecommunication centers must have a minimum clear width of 8 inches 
• Stepstools must have a minimum clear width of 10.5 inches 
• Ladders must be inspected before initial use in each work shift and more frequently as necessary to identify defects 
• Any ladder with defects must be immediately tagged “Dangerous: Do Not Use” and removed from service 
• Employees must face the ladder when climbing up or down and must not carry any load that could cause the employee to fall 
• Ladders must not be used above the maximum intended load 
• Rungs and steps must be corrugated or use skid-resistant material or otherwise treated to minimize the possibility of slipping 
• Ladders must be equipped with a metal spreader or locking device that securely holds the front and back sections in an open position while the ladder is in use 

Fixed Ladders 

For fixed ladders that extend 24 feet or more above a lower level, the following protections must be in place: 

• Such ladders must be equipped with a personal fall arrest system, ladder safety system, cage or well (this applies to ladders installed before November 19, 2018) 
• Such ladders must be equipped with a personal fall arrest system or ladder safety system (for ladders installed on and after November 19, 2018) 

Fixed ladders that must be replaced, either in total or in sections, must include a personal fall arrest system or ladder safety system. 

Guardrail Systems 

Guardrails systems shall be erected at identified unprotected edges, ramps, runways, or holes where it is determined by the program manager or a competent person that such a system will not cause an additional or increased hazard to employees. The following specifications must be met when erecting the guardrail system: 

Top rails must be 42 inches (plus or minus 3 inches) above the walking/working level. 

Mid rails, screens, mesh, intermediate vertical members, and solid panels or equivalent must be installed between the walking/working surface and the top edge of the guardrail system when there is not a wall or parapet at least 21 inches high. These systems must meet the following criteria: 

Midrails must be installed at a height midway between the top edge of the guardrail system and walking/working surface 

Screens and mesh must extend from the walking/working surface to the top rail and along the entire opening between supports 

Intermediate vertical members are to be installed no more than 19 inches apart 

Equivalent intermediate members must be installed so that openings are no more than 19 inches wide 

Guardrail systems must be capable of withstanding a force of at least 200 pounds applied within 2 inches of the top edge. Mid rails, screens, mesh, and intermediate vertical members must be capable of withstanding a force of 150 pounds when applied in a downward or outward direction. 

When guardrail systems are to be used around holes that must be used as points of access, the guardrail system must be equipped with a self-closing gate that slides or swings away from the hole and which has a top rail and midrail. 

Personal Fall Protection Systems 

Personal fall arrest systems shall be issued to and used by employees as determined by a competent person. These may consist of anchorage, connectors, body harnesses, deceleration devices, lifelines, or suitable combinations. 

Personal fall arrest systems must: 

• Limit the maximum arresting force on an employee to 1,800 pounds when using a body harness. 
• Be rigged so an employee cannot free fall more than 6 feet or contact any lower level. 
• Bring an employee to a complete stop and limit the maximum deceleration distance traveled to 3.5  feet. 
• Be strong enough to withstand twice the potential impact energy of an employee free falling 6 feet (or the free fall distance permitted by the system, whichever is less). 
• Be inspected prior to each use for damage and deterioration. 
• Be removed from service immediately if any damaged parts or components are detected. 

All components of a fall arrest system are life-saving equipment and shall meet the specifications of the OSHA Fall Protection Standard. These systems shall be used in accordance with the manufacturer’s instructions. 

• Anchorages must support at least 5,000 pounds per person attached and shall be: 

Designed, installed, and used under the supervision of the program manager or competent person. 

Capable of supporting twice the weight expected to be imposed. 

Independent of any anchorage used to support or suspend platforms. 

• Self-retracting lifelines and lanyards must have straps or ropes made of synthetic fibers and shall: 

Sustain a minimum tensile load of 3,000 pounds if they automatically limit free fall distance to 2 feet. 

Sustain a minimum tensile load of 5,000 pounds if rip-stitch and tearing type of lanyards are used. 

• Lifelines shall be: 

Designed, installed and used under the supervision of a qualified person. 

Protected against cuts and abrasions. 

Equipped with horizontal lifeline connection devices capable of locking in both directions on the lifeline when used on suspended scaffolds or similar work platforms that have horizontal lifelines that may become vertical lifelines. 

• Dee-rings and locking snap hooks shall: 

Have a minimum tensile strength of 5,000 pounds. 

Be proof-tested to a minimum tensile load of 3,600 pounds without cracking, breaking, or suffering permanent deformation. 

Only locking snap hooks shall be used. 

Safety Net Systems 

When safety net systems are used, they must be installed no more than 30 feet below the walking/working surface with sufficient clearance to prevent contact with the surface below. These nets shall be installed with both sufficient vertical and horizontal distances as described in the OSHA Fall Protection Standard. Nets shall be inspected at least once per week by a competent person. Defective nets shall be removed from use immediately and replaced with acceptable nets. 

Nets must be in compliance with the following: 

• All nets must have proper mesh, mesh crossing, border rope, and connections as specified in the OSHA Fall Protection Standard. 
• If nets are to be used on bridges, the potential fall area from the walking/working surface shall remain unobstructed. 
• Objects that have fallen into the safety net shall be removed as soon as possible and at least prior to the following working shift. 

Designated Areas 

In certain cases, designated areas will be used to ensure employees work in an area that is safely distanced from leading edges with a height of 4 feet or more. These designated areas will be delineated by a warning line which employees are required to stay inside of while conducting work in the area. The warning line must be rope, wire, tape, or chain and must meet the following requirements: 

• Have a minimum breaking strength of 200 pounds. 
• Be installed so that the lowest point is not less than 34 inches and not more than 39 inches above the walking/working surface. 
• Be supported in a way that ensures pulling one section of the line will not result in adjacent sections falling below the limits listed above. 
• Be clearly visible from 25 feet away. 
• Be erected not less than 6 feet away from the edge for roof work that is temporary and infrequent or not less than 15 feet away from the edge for other work. 

Fall Protection for Specific Situations 

Hoist Areas 

Guardrail systems, personal fall arrest systems, or a travel restraint system will be used in hoist areas when an employee may fall 4 feet or more. If guardrail systems must be removed for hoisting, employees are required to use personal fall arrest systems. 

Holes and Covers 

Employees must be protected from falling through holes (including skylights) that are 4 feet or more above lower levels by using covers, guardrail systems, or personal fall arrest systems. In order to protect from falls in holes, the following must be ensured: 

• Stairway holes must be protected by a fixed guardrail system on all exposed sides except the stair entrance. 
• Ladderway holes must be protected by guardrail and toeboard on all protected sides except the entrance to the hole where self-closing gates or offsets may be used. 
• Hatchways and chutes must be protected by: 
• A hinged floor-hole cover that leaves only one exposed side and must be closed when not in use or 
• A removable guardrail system with toeboards or 
• A travel restraint system 

Covers must be capable of withstanding at least twice the maximum intended load and secured to prevent accidental displacement. 

Dockboards 

Employees working on dockboards that are 4 feet or more above a lower level must be protected by guardrail systems or handrails. Guardrails or handrails will not be required when: 

• Dockboards are being used only for materials-handling operations using motorized equipment. 
• Employees taking part in these operations are not exposed to fall hazards greater than 10 feet. 
• Employees are trained in accordance with OSHA 1910.30. 

Ramps, Runways, and Other Walkways 

Employees using ramps, runways, and other walkways 4 feet or more above the lower level shall be protected by guardrail systems. In cases where it is not feasible to have guardrails on both sides of a runway, a one-sided guardrail is permissible if the following conditions are met: 

• The runway is at least 18 inches wide. 
• Each employee uses a personal fall arrest or travel restraint system when on a runway. 

Dangerous Equipment 

Employees who are working 4 feet or less above dangerous equipment must be protected from falling into or onto the equipment by either a guardrail system or a travel restraint system. The only exception to this is if the equipment is covered or guarded in such a way that the hazard is eliminated. 

When employees are 4 feet or more above dangerous equipment, they must be protected from falling by guardrail systems, safety net systems, travel restraint systems, or personal fall arrest systems. 

Openings 

When openings are present on a walking/working surface with the bottom edge less than 39 inches above the surface and the bottom edge of the opening is 4 feet or more above a lower level, one of the following protections must be in place: 

• Guardrail systems 
• Safety net systems 
• Travel restraint systems 
• Personal fall arrest systems 

Repair Pits, Service Pits, and Assembly Pits 

When there are repair pits, service pits, and assembly pits less than 10 feet in depth, the use of a fall protection system isn’t required as long as access is limited within 6 feet of the edge of the pit. When access is limited, floor marking must be applied as well as stanchions that are capable of resisting a force of at least 16 pounds or a combination of floor markings and warning lines must be used. 

Scaffolds 

Each employee who uses scaffolding must be protected using the requirements of OSHA 1926 Subpart L. 

Low-slope Roofs 

When work is performed on low-slope roofs and is 6 feet or less from the roof’s edge, employees must be protected by a guardrail system, safety net system, travel restraint system, or personal fall arrest system. 

When work is performed between 6 and 15 feet from the roof’s edge, employees will be protected by a guardrail system, safety net system, travel restraint system, or personal fall arrest system. However, if the work is temporary and infrequent, a designated area may be used. 

With work that is greater than 15 feet from the roof’s edge, the employee must be protected by guardrail systems, safety net systems, travel restraint systems, or personal fall arrest systems unless the work is both infrequent and temporary. In that case, employees will be prohibited from going within 15 feet of the roof’s edge. 

Surface Conditions 

The company will ensure all places of employment, passageways, storerooms, service rooms, and walking/working surfaces are kept in a clean, orderly, and sanitary condition. The floor must be maintained as clean and dry to the extent feasible. When wet processes are used, drainage must be maintained and dry standing places such as false floors, mats, and platforms will be provided. Walking/working surfaces must also be kept free of hazards such as sharp objects, loose boards, leaks, etc. 

All floors will only be used for their maximum intended load and no more than that. Safe access and egress will be provided for all walking/working surfaces. Walking/working surfaces will be inspected regularly to be maintained in a safe condition. If repairs cannot be made immediately, the hazard must be guarded until the repair is complete. When any repair involves the structural integrity of the working/working surface, a qualified person must supervise the correction or repair. 

Protection from Falling Objects 

The following requirements must be followed by employees to prevent hazards associated with falling objects: 

• Toeboards, screens, or guardrail systems must be used to prevent objects from falling to a lower level 
• Canopy structures must be erected to prevent falling objects through edges, holes, or openings 
• Barricades must be used to prohibit employees and objects from nearing the edges of openings 

Fall Rescue Plans 

The company will provide for the prompt rescue of employees in the event of a fall or shall ensure that employees have the abilities or equipment necessary to rescue themselves. 

Accident Investigations 

All incidents including near misses, accidents, or incidents shall be reported and investigated. Investigations must be led by a competent person as soon after an incident as possible to identify the cause and means of prevention to eliminate reoccurrence. 

In the event of such an incident, fall protection plans shall be reevaluated to determine if additional practices and procedures are necessary. It must also be determined if additional training should be conducted to ensure employee understanding of such plans. 



Training Requirements 

Before any employee is exposed to a fall hazard, training will be provided for employees who use personal fall protection systems. Training must be conducted by a qualified person. It is critical that all training is documented. Training for the program manager should include the following provisions: 

• The nature of fall hazards in the work area 
• How to recognize fall hazards 
• Procedures to minimize fall hazards 
• Correct procedures for installing, inspecting, operating, maintaining, and disassembling the personal fall protection systems an employee uses 
• Correct use of personal fall protection systems 

After training, the company shall verify compliance by preparing a written certification record which contains: 

• The name of the employee trained 
• Dates of training 
• Signature of trainer 

Additional training or retraining is required when: 

• Job duties change 
• A change occurs in the Fall Protection Program or the operation presents any new hazard 
• An employee’s job performance shows deficiencies 
• Types of fall protection systems or equipment change