Fall Protection Procedures
Fall Protection Program Fundamentals – Part 2
Maintenance of the National Airspace System (NAS) demands high performance and reliability from systems, and most importantly from the people that operate and maintain those systems. Some work tasks also demand high performance because mistakes can lead to injury or death. In his book The Blame Machine – Why Human Error Causes Accidents, R. B. Whittingham lists seven primary factors weighing on human error (select a tab for a description of the performance factor):
{tab Task Familiarity}
Familiarity with the task being carried out will reduce human error rates at least down to the point where boredom may take over. Methods of Improving vigilance may then have to be adopted.
{tab Available Time}
Complex tasks may require more time to carry out than simple off-the-cuff tasks and if this time is not available, due perhaps to external constraints, then human error rates will increase.
{tab Ergonomics}
It is important that design of the equipment adequately supports the needs of the operator and if it does not then this will cause human error rates to increase.
{tab Fatigue and Stress}
Depending on the level of stress, the effects can vary from the merely distracting to the totally incapacitating. At the same time there is an optimal level of arousal and stimulation necessary to maintain vigilance (see Task Familiarity). Fatigue effects the ability to perform tasks accurately and also increases the influence of the other performance factors.
{tab Attentional Demands}
Human error rates for a single task carried out on its own may increase considerably if other tasks or distractions compete for attention. Human beings are not particularly good at multitasking.
{tab Plans and Procedures With Level of Training}
Complex tasks require both experience and information to be completed successfully. Information should be presented in the form of easily understood procedures and plans which in some cases must be memorized depending upon the task complexity.
{tab Experience}
Human error rates will depend upon whether the person carrying out the task is a novice or an expert, and this must always be taken into account with assessing human error performance. To some degree this will depend on task complexity.
{/tabs}
Most of the factors contributing to human error are present in tasks involving the presence of fall hazards. Most of those factors are largely situational and beyond our control. One factor that is totally within our control is the presence of adequate plans and procedures. That fact makes the absence of adequate procedures an inexcusable risk factor when negotiating a fall hazard. Many fall hazards associated with maintenance of the NAS involve work at considerable heights – heights from which a fall means likely severe injury or death. Increasing risk in these situations by not providing adequate plans, procedures and training indicates an indifference to the well-being of employees that is nothing short of negligence.
Fortunately, the ANSI/ASSE Fall Protection Code (Z359.2-2007) provides a detailed and concise description of what should be included in fall protection procedures. FAA employees can, and PASS representatives should, download a copy when signed into the agency intranet: https://ksn2.faa.gov/ajw/es4/nes/res/ihsaccess.aspx . Another useful standard that that can be downloaded is American National Standard ANSI/ASSE Z359.0-2012 Definitions and Nomenclature Used for Fall Protection and Fall Arrest. Both of these documents are part of the ANSI/ASSE Fall Protection Code, or simply the Fall Protection Code (FPC).
The FPC (ANSI/ASSE Z359.0-2012) describes a “procedure” as: a series of logical steps by which all repetitive action is initiated, performed, controlled and finalized. A procedure establishes the specific step-by-step action that is required; who is required to act; and when the action is to take place. The FPC continues to explain that a procedure differs from a plan in that a procedure provides specific steps to be followed in performing a task or addressing a particular situation, while a plan sets out a general course of action. This leads to the FPC’s definition of a fall protection procedure: a written series of logical steps that describes in detail the specific practices, equipment and methods to be used to protect authorized persons from falling when exposed to fall hazards.
The primary purpose of fall protection procedures is proper task preparation. Finding out that the equipment that you’ve been issued isn’t compatible with the fall protection system at a site right before a scheduled outage, or at a remote site after a day’s travel, is inexcusable. Coming upon an unexpected situation while climbing a structure 50 feet or more off the ground is inexcusable. Unfortunately, these types of situations are not unusual in the NAS today.
Fall protection procedures are as complex as the situation. Fall protection procedures for crossing the face of a communications tower 60-feet above the ground is predictably more complex than the fall protection procedures for work at the fall edge of a loading dock. The complexity of procedures required for work at a loading dock is negligible, making their absence inexcusable. The risk to life and limb from an error working at extreme heights makes the absence of the presence of fall protection procedures in that situation inexcusable. There simply is no rational reason for the absence of fall protection procedures in any situation involving work in the presence of a fall hazard.
ANSI/ASSE Fall Protection Code 4.1.2: Written fall protection procedures shall specify the fall protection equipment and systems used to protect authorized persons from each fall hazard and shall document the proper way to operate the specified fall protection equipment and systems, including installation, inspection, use, and dismantling.
The obvious first step in preparing procedures is identifying the fall hazards in the workplace. This is accomplished by conducting the fall hazard survey discussed in Part 1 of this series. The fall hazard report produced from the information collected during the survey should prescribe a method of fall protection for each hazard identified. That report is the basis for the establishment of site and activity specific fall protection procedures.
ANSI/ASSE Fall Protection Code (Z359.2-2007) prescribes requirements for fall protection procedures:
{tab General Requirements}
- Fall protection procedures must be written by a fall protection Qualified Person or Competent Person.
- Fall protection procedures shall be prepared specifically for the workplace and task where they will be applied except where the same procedure can be effectively applied to multiple workplaces.
- Fall protection procedures shall provide for 100% continuous fall protection.
- Fall protection procedure shall include training requirements and qualifications of authorized persons permitted to use the system.
{tab Fall Arrest}
Written fall protection procedures for fall arrest systems shall include:
- identification of acceptable fall arrest anchorages
- clearance requirements
- complete setup procedures for access
- use and egress from the system
- limitations on the use of the system
- maximum free fall
- maximum arrest force
- maximum number and permitted locations of authorized person who may attach to or use the system
{tab Work Positioning and Travel Restraint}
Written fall protection procedures for work positioning and travel restraint systems shall include:
- identification of acceptable anchorages
- complete setup procedures for access
- use and egress from the system
- limitations on the use of the system including the maximum number and permitted locations of authorized person who may attach to or use the system
{tab Installing and Dismantling Equipment}
Written fall protection procedures for installing and dismantling equipment shall include at least the following information:
- A description of all components used in the fall protection system, specifying the the applicable manufacturers, standard, and/or drawings
- Required anchorage strengths or other criteria for choosing acceptable anchorages
- Any limitations of where or how the system shall be installed
- Detailed instructions for assembling the components into the complete fall protection system
- If applicable, detailed instructions for disassembling the fall protection system
{tab Equipment Inspection}
Written fall protection procedures for inspection shall include:
- Required or recommended inspection intervals
- Detailed instructions for inspecting each component of the system
- Description of acceptance and rejection criteria, of each component of the system
{tab Investigations}
Written fall protection procedures for inspection shall include a requirement that any incidents, including accidents or near misses, be investigated to determine if procedures can be improved.
{/tabs}
Fall hazards in the workplace that have not been addressed with fall protection procedures is a violation of Article 54, Section 1, of the CBA. Submission of a grievance is appropriate. An editable grievance template/form is provided at: https://members.passnational.org/index.php/safety/ato-safety-menu#fall-protection .
