Safety and Risk Management
Safety and Risk Management has the primary responsibility for the implementation and
enforcement of the Fall Protection Program (FPP) and is responsible for the following:
- Developing, implementing, and evaluating the Fall Protection Program to ensure compliance.
- Reviewing Hazards and incidents associated with fall protection equipment.
- Assisting supervisors with employee training.
Supervisors in support and administrative areas are responsible for providing the
necessary direction and support to ensure the effective implementation of the Fall
Protection Program for their work areas. Supervisors are responsible for the following:
- Comply with all Fall Protection Program procedures.
- Identify all fall hazards and activities in their workplace and implement preventative
measures for these hazards.
- Ensure all affected employees attend and complete required training.
- Ensure that all personal fall arrest or restraint systems are maintained in accordance
with the manufacturer’s specifications.
- Hands on training of all fall protection equipment is required.
- Ensure employees are using all fall protective equipment in accordance with OSHA regulations
Affected employees are responsible for the following:
- Comply with all Fall Protection Program procedures.
- Maintain all Personal Protective Equipment (PPE) required to work at heights.
- Inspect all fall protection equipment prior to use.
- Attend and complete all training requirements.
- Immediately report all damaged or defective fall protection equipment to the supervisor
- Use all fall protection equipment in accordance with OSHA regulations.
Contractors performing work on state property shall follow all OSHA guidelines for
fall protection as applicable in 29 CFR 1926.500.
General Industry (1910)
All employees will be protected from falling when working on a surface that has an
unprotected side, edge, etc. or elevated work platforms at a height of 4 feet or more
above an adjacent lower level.
OSHA 29 CFR 1910 – General Industry Standards
- 22 General Requirements
- 23 Ladders
- 27 Scaffolds and rope decent systems
- 67 Vehicle-mounted elevating and rotating work platforms (Aerial lifts)
- 269 Electric power generation, transmission, and distribution
Construction Industry (1926)
All employees preforming construction type activities will be protected from falling
from a surface 6 feet or more above a lower level. Scaffolds used during construction
type activity requires fall protection to be used at 10 feet or more above a lower
OSHA 29 CFR 1926 – Construction Standards
- 451 General requirements (Scaffolding)
- 501 Duty to have fall protection
- 1052 Stairways
- 1926.1053 Ladders
In each of these requirements, the fall hazards must be evaluated to determine the
preferable method to protect the employee. When considering what type of fall protection
to use, the following solutions should be considered:
- Elimination of the fall hazard by bringing the work down to ground level
- Use of passive fall protection systems such as guard rails
- Fall restraint to prevent a person reaching a fall hazard
- Fall arrest which utilizes equipment to stop a fall after it occurs
- Use administrative controls which use work practices to signal or warn an employee
of a fall hazard
The following are identified general industry fall hazards:
Loading docks and other open sided floors greater than 4 feet above the ground must
be protected. The approved method of protection is the installation of a standard
guardrail system. The guardrail may have removable sections to provide access for
loading but rails must remain in place when access is not required.
Floor and Wall Openings and Holes
For stairway openings, standard railings shall be provided on all exposed sides except
at the stairway entrance. Where an employee can accidentally walk into a floor hole
opening measuring 12 inches but more than 1 inch in its least dimension, shall be
guarded by either a standard railing with toe board, or a floor hole cover of strength
and construction to support required load. A wall opening of 4 feet or more above
an adjacent surface shall be guarded.
Open Sided Floors or Platforms
An open sided floor or platform or a runway that is 4 feet or more above the ground
level or above the adjacent floor shall be guarded by a standard railing on all open
sides except for the entrance (to a ramp, stairway, or ladder). If equipment or materials
could fall and create a hazard, then the railing system must include a toe board on
Skylights are considered an opening when present on a roof. A standard guardrail
or skylight screen capable of supporting at least 200 pounds must be provided around
the opening to prevent employees from falling through to the surface below.
Open Pits, Tanks, or Spillways
Protect employees from hazards of open pits, tanks, and spillways by using covers
The following are identified construction industry fall hazards:
Aerial Lifts and Self-Powered Work Platforms
Body harnesses must be worn with a lanyard, not to exceed 3 feet in length, or a self-retracting
lifeline when working from all elevated mobile work platforms. The point of attachment
must be the anchor point of installation and designated by the equipment manufacturer.
Scissor lifts and telescoping lifts that can only move vertically do not require the
use of a harness and lanyard as long as the work platform is protected by a proper
guardrail system and occupants do not stand on or above guardrail system.
An employee cannot move an aerial lift while the boom is in an elevated working position
and the operator is inside of the lift platform.
Covers located in roadways and vehicular aisles shall be capable of supporting, without
failure, at least twice the maximum axle load of the largest vehicle expected to cross
over the cover.
All other covers shall be capable of supporting, without failure, at least twice the
weight of employees, equipment, and materials that may be imposed on the cover at
any one time.
All covers shall be secured when installed so as to prevent accidental displacement
by the wind, equipment, or employees.
Each employee less than 6 feet above dangerous equipment shall be protected from falling
into or onto the dangerous equipment by guardrail systems or by equipment guards.
Each employee 6 feet or more above dangerous equipment shall be protected from fall
hazards by guardrail systems, personal fall arrest systems, or safety net systems.
Each employee at the edge of an excavation 6 feet or more in depth shall be protected
from falling by guardrail systems, fences, or barricades when the excavations are
not readily seen because of plant growth or other visual barrier. Each employee at
the edge of a well, pit, shaft, and similar excavation 6 feet or more in depth shall
be protected from falling by guardrail systems, fences, barricades, or covers.
Each employee on walking/working surfaces shall be protected from falling through
holes (including skylights) more than 6 feet above lower levels by personal fall arrest
systems, covers, or guardrail systems erected around these areas.
Each employee on a walking/working surface shall be protected from tripping in or
stepping into or through holes (including skylights) by placing covers over the holes.
Each employee on a walking/working surface shall be protected from objects falling
through holes (including skylights) by placing covers over the holes.
Each employee who is constructing a leading edge 6 feet or more above levels shall
be protected from falling by guardrails systems, safety net systems, or fall arrest
Exception: when the supervisor can demonstrate that it is infeasible or creates a
greater hazard to use these systems, the supervisor shall develop and implement a
fall protection plan which meets the requirements of OSHA 1926.502 (k).
Each employee on a walking/working surface 6 feet or more above a lower level where
leading edges are under construction, but who is not engaged in the leading edge work,
shall be protected from falling by a guardrail system, safety net system, or personal
fall arrest system.
Protection from Falling Objects
When an employee is exposed to falling objects, the supervisor shall have each employee
wear a hard hat and shall implement one of the following measures:
- Erect toe boards, screens, or guardrail systems to prevent objects from falling from
- Erect a canopy structure and keep potential fall objects far enough from the edge
of the higher level so that those objects would not go over the edge if they were
- Barricade the area to which objects could fall, prohibit employees from entering the
barricaded area, and keep objects that may fall far enough away from the edge of a
higher level so that those objects would not go over the edge if they were accidentally
Roofing Work or Low-Slope Roofs
Each employee engaged in roofing activities on low-slope roofs, with unprotected sides
and edges 6 feet or more above lower levels shall be protected from falling by guardrail
systems, safety net systems, personal fall arrest systems, or a combination of warning
line system and guardrail system, warning line system and safety net system, or warning
line system and personal fall arrest system, or warning line system and safety monitoring
system. Or, on roofs 50 feet or less in width the use of a safety monitoring system
alone is permitted.
Each employee on a steep roof with unprotected sides and edges 6 feet or more above
lower levels shall be protected from falling by guardrail systems with toe boards,
safety net systems, or personal fall arrest systems.
Unprotected Sides and Edges
Each employee on a walking/working surface (horizontal and vertical surface) with
an unprotected side or edge which is 6 feet or more above a lower level shall be protected
from falling by the use of guardrail systems, safety net systems, or personal fall
Each employee working on, at, above, or near wall openings (including those with chutes
attached) where the outside bottom edge of the wall opening is 6 feet or more above
lower levels and the inside bottom edge of the wall opening is less than 39 inches
above the walking/working surface, shall be protected from falling by the use of a
guardrail system, a safety net system, or a personal fall arrest system.
One of the following systems shall be in place whenever an employee is exposed to
a fall hazard:
The use of guardrail systems is considered a passive method of fall protection and
is actually the preferred method for eliminating fall hazards.
Guardrails are needed at the edge of work areas 6 feet or more in height to protect
employees from falling. This includes the edge of excavations greater than six feet
in depth. Guardrail systems need to meet the following criteria:
- Top rail is 42 inches, +/- 3 inches above the walking/working level
- Mid rail is located midway between the top rail and the walking/working level
- It is important to remember that the working level is that level where the work is
being done. Someone working on a stepladder next to an edge may raise his/her working
surface well above the walking surface.
- Both top and mid rails should be constructed of materials at least one-quarter inch
in thickness or diameter. If wire rope is used for top rails, it needs to be flagged
with a high-visibility material at least every 6 feet and can have no more than 3”
- The top rail needs to withstand a force of 200 pounds when applied in any downward
or outward direction.
- The mid rail needs to withstand a force of 150 pounds applied in any downward or outward
- Toe boards are required for all guardrails on elevated walking or working platforms
where employees working below are exposed to falling objects. Toe boards must be four
inches in height and must be securely fastened.
- The system should be smooth to prevent punctures, lacerations or snagging of clothing.
- The ends of the top rail shouldn’t overhang the terminal posts, except when such overhang
does not present a projection hazard.
- When a hoisting area is needed, a chain, gate or removable guardrail section must
be placed across the access opening when hoisting operations are not taking place.
Safety nets shall be installed as close as practical under the walking/working surface
on which employees are working, but in no case more than 30 feet (9.1 m) below such
level. When nets are used on bridges, the potential fall area from the walking/working
surface to the net shall be unobstructed.
Safety nets shall extend outward from the outermost projection of the work surface
Vertical Distance from Working Level to Horizontal Plane of Net
Minimum Required Horizontal Distance of Outer Edge of Net from the Edge of the Working
Up to 5 feet (1.5 meters)
More than 5 feet up to 10 feet (3 meters)
More than 10 feet (3 meters)
8 feet (2.4 meters)
10 feet (3 meters)
13 feet (3.9 meters)
Safety nets shall be installed with sufficient clearance under them to prevent contact
with the surface or structures below when subjected to an impact force equal to the
drop test of this section.
Safety nets and their installations shall be capable of absorbing an impact force
equal to that produced by the drop test specified in this section.
Safety nets and safety net installations shall be drop-tested at the jobsite after
initial installation and before being used as a fall protection system, whenever relocated,
after major repair, and at six month intervals if left in one place. The drop-test
shall consist of a 400-pound bag of sand dropped into the net from the highest walking/working
surface at which employees are exposed to fall hazards, but not from less than 42
inches above that level.
A drop test is not needed when: The supervisor can demonstrate that it is unreasonable
to perform the drop-test required by this section, the supervisor (or a designated
competent person) shall certify that the net and net installation is in compliance
with the provisions of this section by preparing a certification record prior to the
net being used as a fall protection system.
Safety nets shall be:
- Inspected at least once a week for wear, damage, and other deterioration.
- Defective components shall be removed from service.
- Safety nets shall also be inspected after any occurrence which could affect the integrity
of the safety net system.
Materials, scrap pieces, equipment, and tools which have fallen into the safety net
shall be removed as soon as possible from the net and at least before the next work
The maximum size of each safety net mesh opening shall not exceed thirty-six (36)
square inches nor be longer than 6 inches on any side, and the opening, measured center-to-center
of mesh ropes or webbing, shall not be longer than 6 inches. All mesh crossings shall
be secured to prevent enlargement of the mesh opening.
Each safety net (or section of it) shall have a border rope for webbing with a minimum
breaking strength of 5,000 pounds.
Connections between safety net panels shall be as strong as integral net components
and shall be spaced not more than 6 inches apart.
Personal Fall Arrest Systems
When an employee is requiring the use of personal fall protection equipment they shall
employ another employee to render assistance when and if required.
There are three main components to the personal fall arrest system. This includes
the personal protective equipment the employee wears, the connecting devices, and
the anchorage point. Prior to tying off to perform the work a means of rescue in the
event of a fall must be immediately available. All personal fall arrest system components
must meet the requirements of the ANSI Z359 Standards.
The system needs to meet the following criteria for each component:
Personal Protective Equipment
- Full body harnesses are required. The use of body belts is prohibited.
- The attachment point of the body harness is the center D-ring on the back.
- Employees must always tie off at or above the D ring of the harness except when using
lanyards 3 feet or less in length.
- Harnesses or lanyards that have been subjected to an impact load shall be destroyed.
- Load testing shall not be performed on fall protection equipment.
This device can be a rope or web lanyard, rope grab or retractable lifeline.
- Only locking snap hooks may be used.
- Horizontal lifelines will be designed by a qualified person and installed in accordance
with the design requirements.
- Lanyards and vertical lifelines need a minimum breaking strength of 5,000 pounds.
- The length of a single lanyard shall not exceed six feet.
- The use of steel lanyards is prohibited.
- Lanyards may not be clipped back to itself (e.g. around an anchor point) unless specifically
designed to do so.
- If vertical lifelines are used, each employee will be attached to a separate lifeline.
- Lifelines need to be protected against being cut or abraded
Secure anchor points are the most critical component when employees must use fall
arrest equipment. Campus buildings may have existing structures (e.g., steel beams
that may meet the criteria for a secure anchor point). Other work locations and assignments
may require the installation of a temporary or permanent anchor. As a minimum, the
following criteria must be considered for each type of anchor point:
- Structure must be sound and capable of withstanding a 5000 lb. static load.
- Structure/anchor must be easily accessible to avoid fall hazards during hook up.
- Direct tying off around sharp edged structures can reduce breaking strength by 70%
therefore; chafing pads or abrasion resistant straps must be used around sharp edged
structures to prevent cutting action against safety lanyards or lifelines.
- Structures used as anchor points must be at the worker’s shoulder level or higher
to limit free fall to 6 feet or less and prevent contact with any lower level (except
when using a self-retracting lifeline or 3 foot lanyard).
- Choose structures for anchor points that will prevent swing fall hazards. Potentially
dangerous “pendulum” like swing falls can result when a worker moves horizontally
away from a fixed anchor point and falls. The arc of the swing produces as much energy
as a vertical free fall and the hazard of swinging into an obstruction becomes a major
factor. Raising the height of the anchor point can reduce the angle of the arc and
the force of the swing. Horizontal lifelines can help maintain the attachment point
overhead and limit the fall vertically. A qualified person must design a horizontal
Permanent Anchor Requirements
In addition to all the criteria listed above, the following points must be considered:
- Environmental factors and dissimilarity of materials can degrade exposed anchors.
- Compatibility of permanent anchors with employee’s fall arrest equipment.
- Inclusion of permanent anchors into a Preventive Maintenance Program with scheduled
- Visibly label permanent anchors.
- Roof anchors must be immediately removed from service and re-certified if subjected
to fall arrest forces.
Reusable Temporary Anchors
- Reusable temporary roof anchors must be installed and used following the manufacturer’s
- Roof anchors must be compatible with employee’s fall arrest equipment.
- Roof anchors must be removed from service at the completion of the job and inspected
prior to reuse following the manufacturer’s inspection guidelines.
- Roof anchors must be immediately removed from service and disposed of if subjected
to fall arrest forces.
- If a fall occurs, the employee should not be able to free fall more than 6 feet nor
contact a lower level.
- To ensure this, add the height of the worker, the lanyard length and an elongation
length of 5.5 feet. Using this formula, a six-foot worker would require a tie-off
point at least 15.5 feet above the next lower level.
- A personal fall arrest system that was subjected to an impact needs to be removed
from service immediately.
- Personal fall arrest systems need to be inspected prior to each use and damaged or
deteriorated components removed from service.
- Personal fall arrest systems should not be attached to guardrails or hoists.
Warning Line System
The warning line shall be erected around all sides of the roof work area.
When mechanical equipment is not being used, the warning line shall be erected not
less than 6 feet from the roof edge.
When mechanical equipment is being used, the warning line shall be erected not less
than 6 feet from the roof edge which is parallel to the direction of mechanical equipment
operation, and not less than 10 feet from the roof edge which is perpendicular to
the direction of mechanical equipment operation.
Points of access, materials handling areas, storage areas, and hoisting areas shall
be connected to the work area by an access path formed by two warning lines.
When the path to a point of access is not in use, a rope, wire, chain, or other barricade,
equivalent in strength and height to the warning line, shall be placed across the
path at the point where the path intersects the warning line erected around the work
area, or the path shall be offset such that a person cannot walk directly into the
Warning lines shall consist of ropes, wires, or chains, and supporting stanchions
erected as follows:
- The rope, wire, or chain shall be flagged at not more than 6 foot intervals with high-visibility
- The rope, wire, or chain shall be rigged and supported in such a way that its lowest
point (including sag) is no less than 34 inches from the walking/working surface and
its highest point is no more than 39 inches from the walking/working surface.
- After being erected, with the rope, wire, or chain attached, stanchions shall be capable
of resisting, without tipping over, a force of at least 16 pounds applied horizontally
against the stanchion, 30 inches above the walking/working surface, perpendicular
to the warning line, and in the direction of the floor, roof, or platform edge.
- The rope, wire, or chain shall have a minimum tensile strength of 500 pounds, and
after being attached to the stanchions, shall be capable of supporting, without breaking,
the loads applied to the stanchions.
- The line shall be attached at each stanchion in such a way that pulling on one section
of the line between stanchions will not result in slack being taken up in adjacent
sections before the stanchion tips over.
No employee shall be allowed in the area between a roof edge and a warning line unless
the employee is performing roofing work in that area.
Mechanical equipment on roofs shall be used or stored only in areas where employees
are protected by a warning line system, guardrail system, or personal fall arrest
The employee shall inspect the entire personal fall arrest system prior to every use.
The competent person will inspect the entire system in use at the initial installation
and weekly thereafter. The visual inspection of a personal fall arrest system shall
follow the manufacturer’s recommendations. Any components of a personal fall arrest
system noted to be damaged shall be removed from service immediately.
Inspect the entire surface of webbing for damage. Beginning at one end, bend the webbing
in an inverted “U”. Holding the body side of the belt toward you, grasp the belt with
your hands six to eight inches apart. This surface tension makes the damaged fibers
or cuts easier to see. Watch for frayed edges, broken fibers, pulled stitches, cuts,
burns, and chemical damage.
“D” Rings/Back Pads
Check “D” rings for distortion, cracks, breaks, and rough or sharp edges. The “D”
ring should pivot freely. “D” ring back pads should also be inspected for damage.
Attachment of Buckles
Note any unusual wear, frayed or cut fiber, or distortion of the buckles.
The tongue receives heavy wear from repeated buckling and unbuckling. Inspect for
loose, distorted or broken grommets. The webbing should not have any additional punched
Buckle tongues should be free of distortion in shape and motion. They should overlap
the buckle frame and move freely back and forth in their socket. The roller should
turn freely on the frame. Check for distortion or sharp edges.
Friction and Mating Buckles
Inspect the buckle for distortion. The outer bars and center bars must be straight.
Pay special attention to corners and attachment points of the center bar.
Lanyard Inspection Hardware
- Snaps: Inspect closely for hook and eye distortions, cracks, corrosion, or pitted
surfaces. The keeper (latch) should seat into the nose without binding and should
not be distorted or obstructed. The keeper spring should exert sufficient force to
firmly close the keeper. Keeper locks must prevent the keeper from opening when the
- Thimbles: The thimble must be firmly seated in the eye of the splice, and splice should
have no loose or cut strands. The edges of the thimble must be free of sharp edges,
distortion, or cracks.
While bending the webbing over a curved surface such as a pipe, observe each side
of the webbed lanyard. This will reveal any cuts or breaks. Examine the webbing for
swelling, discoloration, cracks, or burns. Observe closely for any breaks in the stitching.
Rotation of the rope lanyard while inspecting from end to end will bring to light
any fuzzy, worn, broken or cut fibers. Weakened areas from extreme loads will appear
as a noticeable change from the original diameter. The rope diameter should be uniform
throughout, following a short break-in period. Make sure the rope has no knots tied
in it. Knots can reduce the strength of the rope by up to 60%.
Shock-absorbing lanyards should be examined as a web lanyard. However, also look for
signs of deployment. If the lanyard shows signs of having been put under load (e.g.
torn out stitching), remove it from service.
- The lanyard housing must be inspected to ensure that casing bolts are tight and that
there are no loose fasteners, missing parts, cracks or excessive wear or corrosion.
- Webbing must be inspected for cuts, nicks or tears as well as for any broken fibers,
stitching or fraying.
- Steel lanyards should be inspected for cuts, fraying, broken wires and overall deterioration
and excessive wear.
- Fittings are to be inspected for wear or cracks and obvious damage.
- Follow manufacturer’s recommendations for additional inspection tasks and for any
requirements that the unit be sent in to the manufacturer for periodic inspection.
Fall protection equipment must be appropriately stored to prevent damage or aging
All ladders in use by employees will meet the following requirements:
- Only wooden ladders or ladders made of other synthetic materials shall be used where
an electrical hazard exists.
- All ladders must be inspected daily before use.
- Ladders should be stored in such a way as to prevent damage from sagging, weather
conditions, excessive heat, etc.
- If a ladder is found to be damaged and is deemed unsafe, it shall be tagged “out of
service”, made inoperable, or removed from the jobsite.
- Ladders shall not be left unattended in the upright position and should be removed
once the worker has ascended the ladder.
- When setting up a portable ladder, be sure to set the ladder at the proper angle to
the building (usually about 25% of the ladder’s vertical height).
- Never lean a ladder against cables or wires of any type.
- Use the help of another worker to extend the ladder to the proper height and positioning.
- Be sure the locks are secure.
- When a climber is ascending the ladder, another worker should be used to stabilize
the ladder by holding the sides and supporting the feet of the ladder.
- The climber should use the three-point method when climbing a ladder. This means that
two hands and one foot or two feet and one hand should be in contact with the ladder
at all times during the climb.
- Never carry tools up the ladder in one hand. Always use two hands to climb.
- Never climb a ladder from the side or underside.
- Never “walk” or “shift” a ladder while standing on it.
Each employee who may be exposed to fall hazards must be trained to recognize the
hazards and the procedures to follow to minimize the hazards. Training should consist
of the following:
- Review of OSHA requirements for fall protection.
- Fall hazards in the work area.
- Correct procedures for erecting, using, maintaining, disassembling, and inspecting
the fall prevention and protection systems.
- The proper use and can of fall protection equipment.
- Limitations of fall protection equipment.
- Receiving emergency assistance.