Oftentimes when folks think about fall protection, especially fall protection compliance, they think about lanyards, harnesses, and anchors, or other physical systems that protect workers at height. While those are critical components to ensure that a worksite is compliant with federal regulation, there are other requirements, such as regular training, inspections, and testing and certification of systems. These are referred to as fall protection services, and while they are different from a physical system, they are no less important, and OSHA requires that all these services be performed and documented regularly to have a compliant fall protection program. Let’s look at some of the different services and what they entail.
OSHA designates that the three (3) types of personnel that must be involved in a fall protection program are the Authorized, Competent, and Qualified Person(s). While OSHA specifies and helps vaguely define these roles, ANSI Z359 helps further describe the specific duties & responsibilities of each participant in the program. Let’s dive into each of these to figure out who at your organization should be trained to what level and what significance they will have in your program’s functionality:
Per OSHA 1910.21(b), this is defined as “an employee who the employer assigns to perform a specific type of duty, or allows in a specific location or area.” This level of training is ideal for anyone who will be using fall protection equipment and is required to be conducted before providing the user with their equipment. Proper authorized person training will make the user aware of the hazards of working at heights and teach the basic principles of proper use of the equipment. Authorized Person training must be completed by a Competent Person, either within the organization or by a third-party trainer like Diversified Fall Protection. We offer 8-hour Authorized Person comprehensive training and 4-hour Authorized Person essentials training.
Regular & consistent training is recommended to ensure users retain their knowledge and comply with the organization’s fall protection policies & procedures. OSHA requires retraining if the employer feels that there is a gap in understanding of the employee’s capability to comply with the fall protection program or OSHA code. Retraining is also required if there is a change to the workplace that makes prior training obsolete—perhaps new equipment is installed, or upgrades are made to existing equipment.
Per OSHA 1926.32(f), this is defined as “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.” Each organization must designate at least one employee to be their Competent Person and that employee must go through an ANSI-accredited Competent Person training program. We offer a 16-hour course and the certification must be refreshed every two (2) years.
While it is not specifically required, it is recommended that a Competent Person is always present when fall protection equipment is in use. Many organizations train multiple people to a Competent Person level to ensure one is always available to their fall protection users. The Competent Person is responsible for approving equipment to use in the fall protection program, facilitating training to authorized users, and ensuring workers are adhering to OSHA mandates & ANSI guidelines for best practices. The Competent Person is also responsible for the annual inspection of all fall protection equipment.
Again, per OSHA 1910.21(b), this is defined as “a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.” Essentially, this is an engineer. A Qualified Person must be involved in the design & installation of permanent fall protection systems (i.e. horizontal lifelines, certified anchors, rigid rail trolley systems, etc.). They must also be involved during incident investigations after a fall occurs. Our services team has Qualified Persons on staff to perform our in-house engineering services.
There are two types of inspections OSHA requires for fall protection equipment:
Per OSHA 1910.140(c)(18), “Personal fall protection systems must be inspected before initial use during each workshift for mildew, wear, damage, and other deterioration, and defective components must be removed from service.” Each time a user is about to don their equipment, they must ensure the equipment is in proper working order and will perform as designed if a fall occurs. We have a free Pre-Use Inspection Checklist you can download here for more information.
The pre-use inspection does not have to be documented, but failing to perform these inspections can result in disastrous results for the user. If a piece of equipment fails inspection, it should be removed from service immediately for further review by the organization’s Competent Person.
OSHA requires that all fall protection equipment (anchorages, body harnesses, lanyards, SRLs, and other applicable accessories) be inspected by a Competent Person annually. As opposed to pre-use inspections, organizations must document annual inspections.
Annual fall protection equipment inspection documentation should include:
In theory, if users are trained to perform thorough pre-use inspections and perform them diligently, annual inspections should produce no failed equipment.
Typically, fall protection anchors must withstand a minimum load of 5000 lbs. However, certain applications or circumstances warrant the need for certified anchorages. Some examples could include (but are not limited to) when rooftop tie-back systems are required for façade maintenance, a horizontal lifeline must be installed, or the available structure cannot withstand a 5000 lb load. (In the instance of the latter, the available structure must be rated to withstand twice the anticipated maximum arresting force of the personal fall protection system.)
If a certified anchor is required, the engineering, design, and installation must be performed by (or under the supervision of) a Qualified Person. Once an anchor is certified, it is subject to periodic recertification. Certified anchors that are part of active fall protection systems require recertification every five (5) years and suspended access systems every ten (10) years. The recertification process involves a visual inspection, onsite load testing to confirm proper capacity of anchorages, and further review of the system to confirm compliance with the latest codes and standards. This ensures the anchors and systems are in good working order and meets current manufacturer requirements. Our certification tests will include documentation and a report from one of our fall protection engineers.
A critical first step to preventing injury from falls is an analysis of the site to identify risks and where workers are exposed to hazards. We offer a complete on-site fall hazard assessment to determine whether your facility is in compliance with current OSHA regulations. We will have a Qualified Person evaluate your site for all fall hazards, taking into consideration the many unique factors of each site. Based on our findings, we will provide a comprehensive report detailing all the potential fall hazards and our recommendations to meet or maintain regulatory standards at your site.
If you’re on the search for a partner to enhance your organization’s fall protection program, reach out to the experts at Diversified Fall Protection. We can perform all OSHA-mandated fall protection services, and will document all of it for you to access via your customer portal should you ever need to. Best of all, when regular inspections and certification is performed by Diversified Fall Protection, we assume liability for the proper functioning of that system if used according to the manufacturers’ instructions. By working together, we can ensure that workers #MakeItHome at the end of the day. Contact us to learn more.