Taking Stock of Your Fall Protection Compliance
Resonating throughout the industry today is an increasing concern regarding fall protection compliance – a key component of any powerline safety compliance program. Fall protection compliance has four essential elements: training, proper use and maintenance, inspection and documentation. Drawing from manufacturers’ specifications and OSHA standards, this Tailgate is a comprehensive resource to assist your organization in building a fall protection program that meets required compliance safety standards.
OSHA requires that all employees working at heights above 4 feet be trained in the proper use and care of their fall protection equipment. Training sessions related to care and maintenance should be held at regular intervals depending on the nature of the work. OSHA standards require that training be performed by a competent person – someone who is capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as in their application and use with related equipment. The person is trained and tested for competency and a record of that training is maintained in their personnel file.
A Proper Plan
A well-thought-out fall protection plan must include proper care and maintenance of all personal protective equipment (PPE) along with the associated items necessary for a complete system. The user is responsible for ensuring they know how to properly inspect, use, store and maintain the equipment. PPE – which includes harnesses and lanyards – should be stored in a clean, dry environment free from direct sunlight, dust, excessive heat and harmful chemicals. The equipment should be cleaned periodically using a mild detergent and water and washed with a soft, nonabrasive brush or sponge. It should then be allowed to air-dry after removing excess water with a dry cloth. PPE should be air-dried in a location out of direct sunlight – never place it in a mechanical dryer as excessive heat may melt the webbing and alter its strength. Further, chemicals should not be used to clean heavily-soiled gear as they may destroy the equipment webbing. Heavily-soiled equipment should be discarded and replaced.
Personal fall arrest systems should be inspected by the user before each use. In addition, a formal inspection must be performed by a competent person at intervals of no more than six months. The inspection should include:
• All webbing, straps and stitching for cuts, fraying, pulled or broken threads, abrasions, excessive wear, altered or missing straps, burns, and heat and chemical exposure.
• All rope for cuts, fraying, pulled or broken strands, abrasions, excessive wear, burns, and heat and chemical exposure.
• All metallic parts – such as D-rings, snap hooks, buckles, adjusters and grommets – for deformation, fractures, cracks, corrosion, deep pitting, sharp edges, cuts, deep nicks, missing or loose parts, improper function, and evidence of burns, excessive heat and chemical exposure.
When an inspection performed in accordance with these procedures reveals signs of inadequate maintenance, the harness must be immediately removed from service. Damage caused by excessive wear and aging can generally not be repaired. A competent person authorized to perform inspections is required to perform final disposition on all nonrepairable equipment submitted for disposal.
As previously stated, all PPE must be inspected by a competent person other than the user. If the harness is exposed to severe working conditions, more frequent formal inspections may be required. The frequency of inspection by a competent person should be established by the company based on such factors as the nature and severity of workplace conditions and exposure time of the equipment. Results should be recorded in a formal inspection log. In addition, before each use the user should ensure a formal inspection has been performed within the last six months.
Safety Policies and Documentation
Every company should establish and enforce a safety policy that immediately removes from service any personal fall arrest system found to be defective, damaged, impact loaded or in need of maintenance. Defective or damaged equipment should only be repaired by the manufacturer.
To ensure your organization’s fall protection program is well documented for auditing and compliance purposes, it should include the following:
• A log of all users and competent persons trained in use, maintenance and inspection
• A detailed record of each competent person’s training and testing
• An inspection log of all fall protection equipment
Incorporating these elements into your fall protection program can help keep your fall restraint system ready for use, your employees safe from falls and your fall restraint safety documentation in order. Remember that no job is so important, no customer in such need and no deadline so critical that we cannot work safe.
About the Author: Timothy D. Self, CUSP, is director of operations for the Institute for Safety in Powerline Construction. He has more than 20 years of powerline experience as a journeyman lineman, trainer and training manager working with both investor-owned utilities and contractors. He serves on the board of Southeast Lineman Training Center, is a member of the Utility Safety & Ops Leadership Network (USOLN) and serves on the USOLN’s testing committee.