I just received a message from a client that said, “even though a contractor has a ‘competent person’ for fall protection, the use of the equipment is not only being done wrong, but is grossly misunderstood.” Unfortunately, this is often a reality. With information from training courses, reading regulations and reviewing manufacturers’ instructions, fall protection equipment can be extremely complex to understand and apply correctly.
In my opinion, one reason why there is so much misuse in the fall protection equipment industry is that many manufacturers have oversimplified the requirements to use their product safely. A good example of this happened during the OSHA public hearings (January 2011) for the proposed 29 CFR 1910 Subpart D&I. A manufacturer was talking about how easy it would be to just install an anchorage for someone accessing a roof. Below is a relevant portion of the transcript from the hearing, with the names removed.
OSHA rep: And how long would it take them to install such an anchor?
Manufacturers rep: A matter of minutes. I mean some of them install with nails, as Mr. XXXXX pointed out. Some of them install with screws. So it’s pretty standard hardware that these people would already have on their trucks or in their tool boxes.
My follow up questions include: What about your rescue plan, anchorage identification, job safety analysis, free fall distance, training, etc.? These items cannot be done in “a matter of minutes,” even with a significant amount of training that may or may not have been done.
As an industry, we have made fall protection–specifically the use of PPE–too complex for the average worker, who doesn’t specialize in safety. This is why risk assessments are key, and the use of engineering controls is so paramount. Organizations in general need to take some of the decision making out of the hands of the workers. Assessments lead to making sure you know where nearly all the issues are. When you know this, you can minimize the use of PPE, and you can properly plan the usage of equipment for locations where engineering controls are not feasible.