by Marty Sharp and Arthur M. Stevens
August 5, 2005
Years ago fall protection equipment was heavy and uncomfortable. Buckles and D-rings were clumsy, bulky forgings. Harness webbing was stiff and abrasive. No wonder workers avoided wearing them, even when they understood the risks.
Several years ago at my company we introduced a tower worker’s harness that met all the ANSI requirements. However, we were totally oblivious to the comfort level the product offered. Successfully passing drop tests, stress requirements and the like was not enough. We subsequently experienced a tragedy.
A young worker, in his early twenties, found the leg straps extremely uncomfortable. He had his own solution. With a little duct tape, he was able to get those straps “out of his way.” He fell, slipped out of the harness and plunged to his death. His widow and two small children took no comfort in the fact that he had been issued fully compliant fall protection equipment.
We are listening
As a manufacturer, we were not legally responsible, but we knew we had not provided all that was needed. We also realized this tragic scene had replayed itself multiple times across our industry.
There has been a change. We, along with all reputable manufacturers of fall protection devices, are in ongoing discussions with our end-users. We are listening when they express a need. Then we take what we hear to our engineers and make sure our products are user-friendly as well as OSHA compliant – webbing is soft and pliable, stretch fabrics are available, and harnesses come in full vest configurations. Hardware is lightweight; closure designs offer simple and quick operation.
Appearance and style has become significant in the safety equipment industry. Colors and fabric influence a worker’s perception of the harness and his attitude toward wearing it. We live in a fashion-conscious society. Both men and women care about their appearance.
In short, if it looks good and is comfortable, the construction worker will put it on. Of course, he must understand how to wear it properly, which brings us to training.
The OSHA standard
§29CFR part 1926.21, the OSHA standard for the construction industry, generally requires training:
– The standard calls for the establishment and supervision of “programs for the education and training of employers and employees in the recognition, avoidance and prevention of unsafe conditions in employments covered” by the OSH Act.
– The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.
Subpart M – Fall Protection, states in Part §1926.503, Training Requirements, that the following training provisions supplement and clarify the requirements of §1926.21:
- The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.
- The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas:- The nature of fall hazards in the work area;
– The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used;
– The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones and other protection to be used;
– The role of each employee in the safety monitoring system when this system is used;
– The limitation on the use of mechanical equipment during the performance of roofing work on low-sloped roofs; – The correct procedures for the handling and storage of equipment and materials and the erection of overhead protections;
– The role of employees in fall protection plans; and
– The standards contained in this subpart.
- The employer shall verify compliance by preparing a written certification record, which shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the employer.
- The latest training certification shall be maintained.
– When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required under “Training Program” (above), the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
- Changes in the workplace render previous training obsolete; or
- Changes in the types of fall protection systems or equipment to be used render previous training obsolete; or
- Inadequacies in an affected employee’s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill.
As manufacturers, we must take our responsibility seriously and help employers train their workers. Should a fall incident occur at your workplace and OSHA investigates, will you be able to respond affirmatively when the investigator asks the all-important training question? Will you be able to demonstrate that the injured worker had completed the required training?
I have been involved in training throughout the country in fall protection with drop test trailers for many years now. I begin my seminar with a painful story: leg straps loose at the knees, a fall, and another worker has lost his manhood. Simply reciting the do’s and don’ts in a classroom doesn’t cut it. We must talk about these case histories resulting in groin injuries, amputations and even death.
According to the Liberty Mutual Workplace Safety Index for 2003, falls to another level were the fourth leading workplace injury. Fall protection compliance is a major problem for OSHA. The fall protection standard ranked third among the most frequently cited violations in 2004. In conclusion, if a compliant harness is comfortable and looks good, and the workers remember their training, there is a good chance they’ll use it, and they’ll use it properly.