Falls have moved from the third leading cause of work-related death to become the number one killer of construction workers and the second leading cause of occupational death for general industry workers, according to the Bureau of Labor Statistics' 2004 Census of Fatal Occupational Injuries. These statistics are fueling a new set of standards called the ANSI Z359.1 Managed Fall Protection Program (MFPP). One of the deterrents to a comprehensive fall protection standards package has been the assortment of standards already in place. The new set of proposed guidelines would help companies to successfully navigate the requirements and best safety practices as well as to develop a 100% fall protection program that keeps their employees safe. There is growing consensus that a new 100% fall protection initiative is due for the electric utility industry.

The 2004 Census of Fatal Occupational Injuries also reported that a fall from a height of 11 ft or more increases the probability of death to 85%. Electric utility workers are exposed to heights that range anywhere from ground level to 20 ft or more for line crews and twice to three times that height for transmission crews. Other factors in the electric utility field, such as acceleration, swing fall, clear height and obstructions, and weather, may escalate the severity of the injury and increases the probability of fatality significantly.

Convergence of Standards

The MFPP has been developed to cover all general industry types with the exception of construction, which is currently being addressed by ANSI A10.32, and mountain climbing. (For more details see the ASSE website, http://engineers.ihs.com/abstracts/asse-a10-32.jsp.) In coming up with the proposed MFPP, the ANSI Z359.1 committee gathered the current elements of fall protection standards and positioned them into a universal format. The proposed set of standards is an excellent tool for employers to use in developing their comprehensive programs. MFPP outlines the fall protection policy guidelines and requirements for: the duties and responsibilities of employees and employers, fall hazard survey reports, fall protection procedures, training programs, the elimination or control of fall hazards, rescue and evacuation plans, accident investigation and program evaluations.

Additionally, the proposed MFPP identifies team members and definitions that should be involved in a company's fall protection discussion. The new set of standards also further expands the roles and responsibilities of the fall protection Competent Person and Qualified Persons. Stakeholder positions were identified by the safety, engineering and training disciplines of the committee to eliminate the undefined areas of existing fall protection guidelines and to clarify roles and responsibilities:

• Authorized Person
• Authorized Rescuer
• Competent Person
• Competent Fall Protection Trainer
• Competent Rescuer
• Competent Rescue Trainer
• Continuous Fall Protection
• Fall Protection Procedures
• Program Administrator
• Qualified Person
• Qualified Person Trainer
• Rope Access.

In addition, the committee said it was time to raise the standard for fall protection. Issues such as preplanning, rescue and design were proposed in an all-out effort to raise fall protection requirements. The committee's recommendations include the following:

Fall protection procedures, including 100% continuous fall protection (not the OSHA Fall Protection Plan, which consists of administrative controls versus physical 100% fall protection), are to be used at every location of an active fall protection system being used to control a fall hazard. These procedures require preplanning before work-at-height occurs.

Design criteria that incorporate fall protection are to be developed and used by the Qualified Person.

Management is to designate a Program Administrator who is an individual committed to the process and implementation of the MFPP. The knowledge and experience of this person will more than likely ensure that the fall protection program works and is more financially efficient.

Rescues are to be preplanned. In addition, rescue equipment and anchorages might be required to be installed before work-at-height occurs to increase the possibility of prompt rescue.

Employer Responsibility

Fall protection roles and responsibilities of the employer are also more clearly defined in the proposed MFPP:

• Develop and implement a fall protection policy and program.

• Provide adequate training to all employees involved in the fall protection process.

• Provide adequate fall hazard analysis and fall hazard abatement before employees are allowed to perform work-at-height activities.

• Provide and verify that 100% continuous fall protection is available and used by employees for all workplace activities.

• Provide a Competent Person to supervise all work activities performed above 4 ft.

100% Continuous Fall Protection

Two of the issues that had not been addressed in the past will probably hit the hot button for many people: the requirements for 100% continuous fall protection and the preplanned work procedures that are in place before permitting employees to work-at-height. These requirements call attention to the need for an open mind to provide adequate training, the means for employees to practice their training and reinforcement to support their learning. With the proposed set of standards, employers would be required to prepare fall hazard survey reports that would identify current and predictable work paths as well as the locations and distances of all obstructions. A fall hazard analysis would be required to be performed before each workplace activity began in order to identify proper work procedures, equipment needs and to determine if abatement measures could be taken.

Too many employers are still willing to bank on Lady Luck versus taking a proactive stance against workplace fall hazards. Some of these have resulted in tragic and preventable incidents. The industry statistics and experience are strong indicators that the issues impacting current fall protection methods are deadly. Unfortunately, over the last 35 years, fall-related injuries and deaths have not declined to a level where safety professionals can breathe a sigh of relief. The Bureau of Labor Statistics recently reported that while the number of workplace fatalities in 2004 increased slightly, the highest recorded number of falls and struck-by accidents since 1992 occurred last year.

Getting Started on an MFPP

Here are some ways to prepare for the proposed MFPP set of standards:

1. Know the definitions. They are new, expanded and provide the foundation from which the program should be developed. The Program Administrator is a new role, and the Competent Person and Qualified Person have expanded duties.

2. Understand the roles and responsibilities of each fall protection team player. The Authorized Person works closely with the Competent Person, and the Competent Person works closely with the Qualified Person. All work closely with the Program Administrator.

3. Form a Fall Protection Committee. Select individuals from all divisions of the company and have a mixed group of ages, experience and safety knowledge. It is as important to have a new set of eyes and a sage.

4. Assess your existing fall protection program using in-house and outside resources, and determine if they are adequate to keep the fall protection team safe and prevent hazards from entering the workplace.

   a. Identify the number of fall fatalities and injuries.

   b. Measure management's level of support for this program.

   c. Define employee safety attitude.

   d. Identify existing workplace activities, such as job hazard analysis and their fall hazards.

   e. What are the existing fall protection training programs and their effectiveness?

   f. Who are the members of the Fall Protection Committee and is their level of commitment and ability to perform this role adequate?

   g. Is there a budget and is it adequate?

   h. What do you want this program to do for your company and employees?

   i. What are the obstacles — present and future — that will impact the program?

5. Identify the type of fall protection training that is needed and who should attend.

6. The Fall Protection Committee, along with a Qualified Person, should perform an audit and rank hazards on a scale of 1 to 10, with 10 rating the highest risk.

7. Identify abatement options.

8. Develop a rescue plan and program.

Improving Safety

The proposed Managed Fall Protection Program has been called a milestone in how the industry implements and practices fall protection. It demonstrates that work-at-height can be performed safer and outlines how to tackle developing and implementing a managed fall protection safety program. Through adequate fall protection training, it is possible to preplan a 100% fall protection work action plan. Adequate is best defined as what learning needs to take place and what skill sets need to be achieved, so that each member of the fall protection team, from the at-risk worker to the rescue team, can perform their fall protection role safely. Critical questions to ask include: What are the fall hazards my employees face performing their work? Can two hours of training prepare my employee to work or supervise safely?

The proposed ANSI Z359.1 MFPP standard has the potential of helping companies to navigate through the requirements, best safety practices and training programs successfully and to develop a 100% fall protection program that keeps its employees safe.

The most common justification used for not having an effective fall protection program is the degree of difficulty and uncertainty associated with developing and enforcing such a program. But through adequate fall protection training it is possible to preplan a 100% fall protection work action plan, and the proposed ANSI Z359.1 MFPP standard was designed to help utilities do just that. Whether you are a regional or national utility company, this standard levels the playing field for employees and employers to strengthen or begin their fall protection program. Implementing the MFPP will create a positive, improved safety culture, your company's safety signature for generations.

Michael C. Wright, PE, CSP, CPE, is president of Safety Through Engineering Inc. in New Carlisle, Ohio, U.S. He has 27 years of structural engineering, fall protection engineering, machine guarding engineering and safety engineering consulting experience. mikewright@ste4u.com

Moniqua Suits is the director of training at Safety Through Engineering Inc. She has more than 18 years of experience in the safety and training industries, and holds a bachelor's degree and has taken advanced studies at Marshall University in Huntington, West Virginia, U.S.
Moniqua@ste4u.com

Misconceptions Abound

A common misconception within companies is the tendency to address fall hazards based solely on the use of fall protection equipment, without consideration to training or the structural issues associated with wearing equipment. This lack of knowledge and training has left many fall protection Competent Persons unaware of the requirements. And if you are the supervisor of personnel working at heights above 4 ft, you are the Competent Person. The requirements include such procedures as inspection, use and maintenance of equipment, and the need for retraining and repurchasing of equipment when workplace activities change.

In addition, like most industries, utilities have to convince their workforce that it is necessary to wear and use the equipment correctly every time they perform work-at-heights. Safety Through Engineering's trainers have watched Authorized Persons wear full-body harnesses without the leg straps being secured or anchored to side D-Rings, phone cable, railing of the bucket truck or nothing at all. And, the trainers also have seen Authorized Persons wear full-body harnesses correctly but connected to a system that would allow them to hit the ground before their equipment deployed or to fall out of the bucket. Frequently, companies purchase several different lines of fall protection equipment and their Authorized Persons mix and match the different product lines without considering performance or compatibility issues. What appealed to management and safety as the one perfect solution to fall hazards has become more complex than simply selecting fall protection equipment.

Another misconception is to view 911 as the solution to OSHA requirements for prompt rescue. Stop and map out the time it would take for a public rescue department to reach your crew member in a remote area and/or in the middle of the night. Time how long it would take to realize your solo worker has been injured, notify the rescue team and for the rescue team to arrive. If an unconscious crew member has been hanging in a full-body harness for longer than 30 minutes, how will you address the effects of suspension trauma? All of these factors need to be preplanned before the work activity starts. The Preamble to Subpart M is a great resource to read to gain an understanding of how to preplan your next work-at-height project.