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There are additional issues with fall arrest systems. One is that the harnesses are often worn too loose. Another is that shock-absorbing lanyards are sometimes used in areas with inadequate fall clearance. A retractable lifeline or fall limiter should be used where appropriate.

By THOMAS H. WELBY, P.E., ESQ.

If your trade requires employees to work on elevated surfaces, fall protection is probably the most important aspect of your safety program. In issuing citations for fall-protection violations, OSHA generally cites a total failure to employ fall-protection measures, or the failure by one or more employees to be tied off at all times.

While not being tied off may be the most common predicate for fall-protection citations, OSHA can and will cite you for improper (or improperly-affixed) anchors. The anchor acts as a base to secure the retractable or the lanyard, when employees are working on elevated surfaces. The anchor must be correctly secured to a structural member capable of supporting 5,000 pounds (for each worker who is to be fastened to it).

There exist a wide variety of types of anchors, such as roof anchors for residential or commercial roofing, beam anchors for steel erection, concrete anchors for concrete masonry and various kinds of specialty anchors. Online, you can find vendors that specialize in fall protection equipment, and they can help you choose equipment appropriate to the work that you do.

In addition to picking the right kind of anchor, it is crucial to follow the manufacturer’s instructions to ensure a secure installation. In a recent OSHA case, the employer was using a roof anchor, with two hinged flanges allowing the anchor to be used over a roof’s peak. Each of the flanges was supposed to be attached with screws to opposite sides of the peak. The ALJ affirmed a “Serious” OSHA citation, where the employer had an employee tied off, but only one flange of the anchor was screwed down.

There are additional issues with fall arrest systems. One is that the harnesses are often worn too loose. Another is that shock-absorbing lanyards are sometimes used in areas with inadequate fall clearance. A retractable lifeline or fall limiter should be used where appropriate. Also, to the extent possible, the anchorage should be positioned directly overhead, to avoid a “swinging fall injury,” and the equipment should be set up to limit the free-fall distance to a maximum of six feet.

Using equipment beyond its useful lifespan is another common and potentially disastrous error. Equipment must be inspected regularly. Pay particular attention to your lanyards, and look for fraying, cuts and deformed metal hardware. Discard and replace any equipment you even suspect of being defective or worn.

Manufacturers’ instructions for all fall-protection equipment need to be communicated to all who will be using it. Technical terms must be explained, and extra effort expended, as may be necessary to make sure that the information is expressed in language that each worker understands.

Trainers need to be OSHA “competent persons” and be able to explain:

* The nature of fall (and other) hazards at the worksite;

* Procedures for erecting, maintaining and disassembling fall-protection systems, and personal fall-arrest systems; and,

* The proper use and operation of personal fall-arrest equipment, and such other fall-protection systems as may be employed.

Many employers (and safety professionals and first responders) are unaware of the phenomenon of “suspension trauma,” which may occur where the worker is suspended in an upright posture, with legs relaxed beneath his body.

Where a fallen worker is suspended in a harness, gravity pulls blood into his lower legs, and the harness exerts pressure on the veins in his legs. Within minutes, enough blood accumulates in the legs that the return blood flow to the right chamber of the heart is reduced. The heart’s output begins to fall, whereupon the heart starts beating faster, to maintain adequate blood supply to the brain. The upright posture will be maintained, even if the worker loses consciousness, which can occur in as little as five minutes and may be followed by death.

Thus, employees and rescue workers must be made aware that a worker suspended erect in a fall-arrest harness is in a potentially fatal situation. OSHA does not prescribe how quickly a suspended worker must be rescued, but you should aim at limiting time in suspension to five minutes or less, and certainly not more than 15 minutes.

Worker training should include employees gaining (under competent, close supervision) experience in hanging in a harness of the type they will be using. Workers should be instructed in advance, and reminded in the event of a fall, that they should try to push, using their legs, against any available surface. If that is impracticable, they should try to maneuver their legs as high, and their heads as close to horizontal, as possible. Newer equipment features harnesses with a seat or “suspension trauma straps,” which can be deployed to ease the strain on leg (and shoulder) straps while awaiting rescue.

Additional measures can be taken to mitigate the dangers of “suspension trauma.” First, avoid allowing anyone to work in a fall-arrest harness alone, or in circumstances in which a fall would not be quickly noticed. Especially if workers must work with minimal supervision, they should be instructed to affix their lanyards to front (stomach or chest) rather than rear (back) attachment points. This will aid the worker, if conscious and uninjured, with self-rescue.

Gradual arrest devices can reduce the danger from deceleration injuries. Locating the tie-off attachment of the harness as near as possible to the body’s center of gravity may also reduce whiplash and other traumatic injuries. In addition to which, it should make it easier for the employee to move his legs upward, and head downward, while suspended. Self-retracting lifelines, which are available in a number of models, can be set to slowly lower the worker to the ground. Assuming that the fallen worker remains conscious, and is not badly injured, in most cases a self-retracting lifeline should permit self-rescue, and eliminate the need for a coordinated response from others onsite, or outside rescue forces.

All workers should be trained and re-trained to avoid moving victims rescued after losing consciousness to a horizontal position too rapidly. Between 30 minutes and 40 minutes is the recommended interval to move the victim from kneeling, to sitting, to a supine position. Deaths following rescue have occurred where the worker has been placed at once in a horizontal position. This is believed to be due to the heart’s inability to tolerate a sudden increase in blood flow to the right heart, following removal from the harness. Since EMTs and other first responders may be unaware of this danger, preparing and affixing cautionary labels to each worker’s harness is a good idea, and your workers should be trained to warn them in appropriate terms.

Finally, advance planning should precede every project. You must anticipate the likelihood that falls will occur, and have a plan to rescue fallen workers (and to get them competent medical attention) ideally in under five minutes. Calling “911” is not enough. The nearest rescue may be too far away, lack necessary equipment, or lack training for confined-space or tower rescue.

Rescue planning should begin when you select and purchase fall-protection equipment, and be revisited and revised to take into account the peculiarities of every new project and jobsite. Especially if circumstances may make speedy rescue problematic, you should consider strategies (such as alternative modes of fall protection, or restricting worker access to areas near the edge of elevated surfaces) to reduce the risk that fall-arrest harnesses will actually come into use.

Proper fall protection is more than just replacing any old equipment, or nagging your employees to wear it, or to always tie off. Proper anchoring (the right equipment, correctly installed) and planning for rescue when and if falls occur are essential aspects of the process.

 

About the author: Thomas H. Welby, an attorney and licensed professional engineer, is the managing partner at Welby, Brady & Greenblatt, LLP, with its main office in White Plains. Geoffrey S. Pope, counsel to the firm, collaborates in the preparation of this series, which is intended for general guidance only.