Purpose

This chapter establishes the OSHA Field Safety and Health Management System (SHMS) Fall Prevention and Protection Program. OSHA employees need to recognize fall hazards and know how to avoid them. If tasked to work at heights, OSHA employees should understand safe procedures to work at heights and have the appropriate level of training. The policies and procedures in this Program are intended to set broad expectations for preventing OSHA employee injury or death from falling. OSHA expects Regions, DTSEM, and DTE to develop specific procedures that align with this Program as needed. This Program emphasizes using acceptable alternatives that meet the work requirement without working at heights, establishes roles and responsibilities, and describes training requirements. Chapter 11, Walking Working Surfaces provides additional information applicable to surfaces at heights.

Scope

This Program applies to all OSHA employees covered by the OSHA Field Safety and Health Manual. All employees will take necessary precautions while conducting work activities, including collecting information to document fall hazards in workplaces. The majority of policies in this chapter are for activities that require Basic or Advanced Climber Training. OSHA employees that do not need Basic or Advanced Climber Training to conduct work activities will receive awareness training and may use ladders at their discretion when fall protection equipment is not required.

References

1. 29 Code of Federal Regulations Part 1926 Subpart M, Fall Protection
2. OSHA Field Safety and Health Manual, Chapter 13, Control of Hazardous Energy Sources
3. OSHA Field Safety and Health Manual, Chapter 11, Walking and Working Surfaces
4. American National Standards Institute (ANSI)/American Society of Safety Engineers (ASSE) Z-359, Fall Protection Code
5. Personal Fall Protection Used in Construction and Demolition Operations, ANSI/ASSE A10.32-2012

Definitions

1. Responsible OSHA Managers are trained and competent supervisors appointed by Regional Administrators/Directorate Directors (RAs/Directors) to perform duties specified in this Program for overseeing local implementation.

2. Authorized OSHA Employees (Authorized Employees) are designated by the Responsible OSHA Manager based on the need to conduct work activities at heights requiring fall protection (e.g. investigation and inspections). Authorized Employees complete appropriate training and have the knowledge and expertise to safely conduct work activities with fall protection at anticipated heights. Authorized Employees will use ladders at their discretion and follow Regional policy for notification to their supervisor when conducting work activities that require Basic or Advanced Climber training. Authorized Employees designation may include OSHA trainers who teach fall protection courses and conduct hands-on exercises at heights.

   Authorized Employees are grouped into two categories:

   1. Basic Climbers: This authorization level is for employees who are trained and equipped with the knowledge and expertise to safely work at limited locations at heights (see Activities Requiring Basic Fall Prevention and Protection Training, Section VII.A). Basic Climbers are not authorized to use fall arrest systems.

   2. Advanced Climbers: Employees who volunteer and are selected, receive medical clearance, and are trained and equipped with advanced knowledge and expertise to safely work at heights with complexities, including towers (see Activities Requiring Advanced Climber Training Level, Section VII.A).

3. Personal Fall Protection Systems include Personal Fall Arrest Systems (PFAS), Personal Fall Restraint Systems (PFRS), positioning devices, and ladder safety devices or systems.

   1. PFAS: A PFAS protects an Authorized OSHA Employee if a fall occurs by arresting or stopping the fall. It must function to ensure that the worker neither free falls more than 6 feet nor contacts any lower level (see 29 CFR 1926.502(d)(16)(iii)). The anchor point must support at least 5,000 pounds as per attached Authorized Employee (see 29 CFR 1926.502(d)(15)).

   2. PFRS: A PFRS will prevent an Authorized OSHA Employee from falling any distance. Restraint systems used by Authorized OSHA Employees must have the capacity to withstand at least twice the maximum expected force that is needed to restrain a person from exposure to the fall hazard. In determining this force, consideration should be given to site-specific factors such as the force generated by a person walking, leaning, or sliding down a working surface. The OSHA Technical Manual Fall Protection in Construction Chapter provides further information and PFRS examples.

      NOTE: Fall restraint is preferred over fall arrest.

   3. Positioning devices: Body belts serve as positioning devices. They can position a worker so that he or she can safely perform a job in a vertical work position at a height as per requirements in 29 CFR 1926.502(e), 29 CFR 1926 Subpart M, Appendix D.

   4. A ladder safety device or system is used to climb fixed ladders and includes a carabiner, carrier rail, safety sleeve and body harness. It is available as a cable (i.e., vertical lifeline) or fixed rail system per requirements in 29 CFR 1926.1053(a)(18),(22), and (23) and 29 CFR 1910.27(d).

Responsibilities

1. RAs/Directors will:

   1. Establish fall prevention and protection specific to the Region/SLTC/CTC/DTE and implement them in accordance with this Program. These site specific procedures will include:

      1. Means for ensuring that all employees are appropriately trained.

      2. An established process for employees to notify the Responsible OSHA Manager about fall hazards when work activities require basic and advanced training.

      3. A mechanism for properly inspecting, maintaining, storing, and removing fall protection equipment from service when it is no longer in good condition.

   2. Appoint Responsible OSHA Managers to implement this Program locally.

   3. Provide training in local procedures in addition to the specific requirements in this Program for employees as deemed necessary.

   4. Assess hazards in collaboration with Authorized Employees (i.e., Basic and Advanced Climbers) before giving permission when a request is made to conduct work activities at heights requiring fall protection systems, or use personnel lifting devices (e.g. aerial lifts, scissor lifts); or assign the Responsible OSHA Manager to perform this function.

   5. Develop and implement appropriate procedures in accordance with policy specified in this Program for using equipment owned by an employer other than OSHA at an investigation, inspection or fall protection training location. Give permission to Authorized Employees to use such equipment if appropriate or assign the Responsible OSHA Manager to give permission.

   6. Decide if a fall hazard response team is needed to conduct complex inspections or investigations within the Region/SLTC/CTC/DTE. If needed, establish a fall hazard response team including Authorized Employees with advanced training, knowledge, expertise, and experience to provide technical support for inspections or investigations involving fall hazards. The team may also provide other support as necessary.

   7. Request assistance from SLTC’s Health Response Team for investigations and inspections that present fall hazards when the Region/Directorate does not have the resources to safely conduct work activities.

   8. Ensure that resources are made available to implement this Program.

2. Responsible OSHA Managers will:

   1. Complete the Annual SHMS Fall Prevention Awareness training.

   2. Complete the Basic Fall Prevention and Protection training if any employees are Authorized Employees.

   3. Select proficient training sources. Training sources must have knowledge, expertise, and experience to provide proper training to employees who meet the objectives described in this Program.

   4. Ensure that OSHA employees covered by the OSHA Field Safety and Health Manual receive appropriate training (e.g. awareness, Basic Climber, or Advanced Climber) as described in this Program.

   5. Maintain training records per 29 CFR 1926.503(b) or designate an employee to perform this function.

   6. Designate Authorized Employees and the appropriate authorization level their job requires (e.g. Basic or Advanced Climbers), in writing.

   7. Assess hazards in collaboration with Authorized Employees before giving permission when a request is made to conduct work activities at heights requiring fall protection systems, or personnel lifting devices (e.g. aerial lifts and scissor lifts), or if assigned by the RA/Director to perform this function.

   8. Ensure that only Authorized Employees use personal fall protection and that they are fully authorized by the Area Office before they climb. If the hazard warrants more than one authorized employee, that employee should be present on site before the authorized employee is allowed to climb.

   9. Follow established procedures for the Region/SLTC/CTC/DTE to give permission to Authorized Employees to use equipment owned by an employer other than OSHA at an investigation, inspection or fall protection training location if appropriate and assigned by the RA/Director to do so. Submit the request to the RA/Director if not assigned to perform this function.

   10. Develop and implement appropriate inspection, maintenance, storage, and disposal system for fall protection equipment in accordance with applicable guidance, manufacturer’s instructions, and procedures established for the Region/SLTC/CTC/DTE.

3. Authorized Employees will:

   1. Complete training required for the authorization level (e.g. Basic Fall Prevention and Protection Training or Advanced Climber Training) as specified in this Program and always use proper safety measures.

   2. Follow specific Region/SLTC/CTC/DTE fall prevention and protection procedures.

   3. Select the right equipment for the task as specified by the manufacturer and inspect and verify that it is in good working condition before using it. Authorized Employees will not use defective equipment, incompatible components or personal fall protection equipment provided by an employer other than OSHA.

   4. Follow this Program’s policy for using another employer’s equipment, with the exception that Authorized Employees will only use personal fall protection equipment provided by OSHA.

4. OSHA Employees that are not Authorized Employees, those not trained as Basic or Advanced Climbers, will complete annual SHMS fall protection awareness training and are allowed to use ladders at their discretion.

Training

This Program’s effectiveness relies on OSHA’s commitment to training including initial training and continued education that is, at a minimum, in compliance with 29 CFR 1926.503, Fall Protection Training Requirements and 29 CFR 1926.1060 Stairways and Ladders. Training requirements for OSHA employees are based on approved work activities. RAs/Directors can provide training in local procedures, in addition to training specified in this Program for employees.

Training sources must have the knowledge, expertise and experience to provide proper training to employees that meet the objectives described in this Program. Training sources may include the OSHA Training Institute, equipment manufacturers, unions, OSHA cooperative programs (e.g. Wind and Communication Tower Training), third-party and in-house sources such as trained, experienced and competent managers, or Compliance Safety and Health Officers that is, at a minimum, in compliance with 29 CFR 1926.503(a)(2).

Responsible OSHA Managers/designees will maintain Annual SHMS Fall Prevention Awareness Training records and prepare a training certification record for Authorized Employees (e.g. Basic Climbers and Advanced Climbers) upon successfully completing initial training, annual refresher, and biennial recertification as applicable, including any additional fall prevention and protection training mandated by RAs/Directors per 29 CFR 1926.503(b). The training documentation will include the means used to verify that the employee understood the training.

1. Annual SHMS Fall Prevention Awareness Training

   All OSHA employees covered by the OSHA Field Safety and Health Manual must complete Annual SHMS Fall Prevention Awareness Training. This includes employees who may encounter worksites at heights, but are not authorized to gain access to work at heights to the extent that authorized employees are permitted to do and/or OSHA employees who may encounter fall hazards in their workplaces. Authorized Employees will also complete Annual SHMS Fall Prevention Awareness Training in addition to required advanced training.

   Minimum training requirements include how to identify fall hazards in the workplace, fall hazard avoidance and fall prevention measures, the requirements specified in this Program and any specific fall prevention and protection procedures implemented by the Region/SLTC/CTC/DTE. Current OSHA employees are approved to give training if they have completed Basic Fall Prevention and Protection Training or Advanced Climber Training, have experience with fall prevention and protection mechanisms, and have knowledge about this Program.

2. Authorized Employee Training

   Authorized Employees (i.e., Basic Climbers and Advanced Climbers) will receive fall prevention and protection training that includes classroom and hands-on activities. Fall prevention and protection training will emphasize the importance of considering alternatives to working at heights, fall prevention and protection options, and self-rescue methods that minimize risk. Training on fall protection and self-rescue mechanisms will involve various field applications and exercises designed to introduce and reinforce how to safely use equipment and system components for fall protection and self-rescue. All Authorized Employees will demonstrate via practical examination to subject matter experts during training proper selection, usage, storage, maintenance, inspection, assembly, and dismantling procedures for fall protection and self-rescue equipment and systems currently in use.

   Additional training is necessary if conditions change, such as, the work type or practice, workplace, or fall protection methods. Retraining will occur when the Responsible OSHA Manager determines that an Authorized Employee does not have an adequate understanding and skill to work safely at heights.

   1. Basic fall Protection and Protection Training

      Initial Training: Before working at heights, Basic Climber Authorized Employees will complete Basic Fall Prevention and Protection Training from a proficient training source that meets objectives described below. This may require combining the OSHA Training Institute’s fall protection course with training from other sources as necessary.

      Refresher Training: Basic Climber Authorized Employees will complete Annual SHMS Fall Prevention Awareness Training.

      Basic Fall Prevention and Protection Training objectives must include at least the following:

      1. OSHA’s Fall Protection standards and other applicable guidance, this Program, local fall prevention and protection procedures, as well as manufacturer’s instructions, warnings, cautions, and equipment limitations for the specific equipment that Authorized Employees will use, with emphasis on the importance of following equipment manufacturers’ instructions.

      2. Safe alternatives to working at heights when feasible.

      3. Worksite assessment, recognizing fall hazards and other site specific hazards such as electricity, radio frequency, noise, hazardous chemicals, water and environmental hazards.

      4. Fall hazards elimination, avoidance, and control.

      5. Fall prevention measures and evaluation.

      6. Fall arrest system components: anchorage, body support or harness, and connection mechanisms such as lanyards (e.g. shock absorbing, retractable and Y lanyards).

      7. How to properly assess anchorages and engineering consultation that may be required to satisfy dynamic loading capability, especially where multiple individuals may be involved in simultaneously using the same anchor point.

      8. Personnel lifting devices.

      9. Fixed ladder (e.g. above 10 feet) climbing safety.

      10. Fall protection and self-rescue equipment inspection, maintenance, and storage. Equipment identification (e.g. markings/labels).

      11. Proper equipment selection and use for specific work environments. Avoiding incompatible connections/components that could cause equipment failure. For example, how to prevent snap hook roll-out and/or burst-out.

          NOTE: The locking type snap hook with a self-closing, self-locking latch which remains closed until pressed open for connection or disconnection is required. Opening the snaphook requires a double action to prevent unintended disengagement. The non-locking type is not permitted.

      12. Equipment limitations and requirements for proper functioning. Equipment withdrawal from service.

      13. Free-fall distance calculation and reduction. Maximum arresting force reduction.

      14. Practical exercises essential for Authorized Employees to understand fall protection and self-rescue equipment capabilities and limitations. Training will incorporate live hands-on activities for Authorized Employees to demonstrate proficiency in fall protection and self-rescue techniques, proper anchor point evaluation, anchorage selection, and anchoring procedures demonstration

      15. Pre-determined task-specific fall protection and rescue plan, including appropriate rescue options and demonstrated self-rescue techniques

      16. Procedures to locate first aid supplies and contact Emergency Medical Services

      17. Other applicable procedures specific to the worksite such as lockout/tagout procedures (see Chapter 13, Control of Hazardous Energy Sources)

      18. Proper documentation of fall hazards and abatement methods

      19. Use of alternative technology to document hazards

      20. Contact methods for OSHA fall protection subject matter experts.

   2. Advanced Climber Training

      Advanced Climber Authorized Employees undergo highly specialized and rigorous fall protection training such as the Wind and Communication Tower Training. Advanced Climbers will obtain medical clearance with a biennial expiration date through the OSHA Medical Examination Program (OMEP) before completing initial training and performing associated duties, and biennially thereafter. The medical clearance is labeled as Wind Tower Clearance in the Compliance Safety and Health Officer Health Information System (CHIS). OSHA employees not in the OMEP may obtain assistance from the Office of Occupational Medicine and Nursing to make arrangements with Federal Occupational Health (FOH) for medical clearance. However, employees’ RAs/Directors are responsible for securing funding for FOH’s services. Advanced Climbers will not participate in training or perform associated duties if the medical clearance has expired.

      The OSHA Training Institute will provide guidance upon request on how to register for and complete specialized training for Advanced Climbers and the biennial recertification (e.g. Wind and Communication Tower Training).

      Initial Training Requirements: Advanced Climbers will complete the Basic Fall Prevention and Protection Training. This will be followed by specialized training such as the Wind and Communication Tower Training that meet the objectives listed in this Program for Advanced Climber Training. Advanced climbers must receive training from a proficient training source before working at heights.

      Recertification Training: Advanced Climbers will complete specialized training recertification biennially from a proficient training source such as Wind and Communication Tower Training recertification.

      Refresher Training: Advanced Climbers will complete Annual SHMS Fall Prevention Awareness training.

      Advanced Climber Training objectives include:

      1. Fall hazard recognition, assessment, and avoidance

      2. Tower climbing and self-rescue equipment selection, inspection, use, and storage, application limitations, proper anchoring, tie-off techniques, proper rigging practices, elongation, deceleration distance determination, free-fall distance, and total fall distance determination

      3. Climbing proficiency demonstration. Explanation and demonstration for equipment used for climbing and positioning. Personal preparedness, climbing, resting, and proper positioning

      4. Equipment installation/assembly, stresses and resultant effects, and safety margins

      5. Methods to recognize energized power lines, auxiliary equipment, and other apparatus

      6. Emergency procedures, proper self-rescue technique for the situation, and suspension trauma management

      7. Basic first aid and methods to contact Emergency Medical Services

      8. Personnel lifting devices

Procedures for Working at Heights

1. Hazard Assessment

   When OSHA employees need to conduct inspection and investigation work activities at heights as in described section IV.B., the RA/Director or Responsible OSHA Manager will conduct a hazard assessment in collaboration with Authorized Employees (i.e., Basic Climbers and Advanced Climbers). A sample hazard assessment form can be found here. Some safety considerations for completing a Hazard Assessment are described below:

   1. Recognize activities and areas where Authorized Employees (e.g. Basic and Advanced Climbers) may require fall protection, including:

      Activities Requiring Basic Fall Prevention and Protection Training Level at a minimum:

      1. Commercial/Residential construction sites with fall hazards

      2. Excavations, wells and pits, holes

      3. Floor openings (e.g. in walking surfaces)

      4. Grain silos –equipped with guardrails

      5. Maritime cranes –equipped with guardrails

      6. Personnel lifting devices (e.g. aerial lifts, scissor lifts)

      7. Ramps, runways and other walkways

      8. Tanks and containments (e.g. water tanks) –equipped with caged ladders and work platforms with guardrails

      9. Tower cranes – equipped with guardrails

      10. Unprotected edges in hoist areas

      11. Walking and working surfaces unprotected sides and edges

      12. Wall openings

      Activities Requiring Advanced Climber Training Level:

      1. Grain Silos –not equipped with guardrails

      2. Maritime Cranes –not equipped with guardrails

      3. Tanks and containments (e.g. water tanks) – without caged ladders or work platforms with guardrails

      4. Towers (e.g. water towers, communication towers)

      5. Wind Turbines

   2. Determine if there is a safe alternative to working at a height to perform duties (e.g. using a camera connected to a trench rod). Implement safe alternatives if feasible.

   3. Determine if it is necessary to work at heights, for example, to conduct safety evaluations or training exercises.

   4. If it is deemed necessary to work at a height requiring fall protection, ensure that an effective task-specific fall protection and rescue plan is developed, reviewed, approved, and implemented before giving permission to Authorized Employees. This includes the following:

      1. Ensure that only Authorized Employees with appropriate training, knowledge, expertise and experience with the specific fall hazard(s) are permitted to gain access to work at heights.

      2. Complete a site-specific hazard assessment.

      3. Evaluate each situation, planning in advance how to protect the Authorized Employee from falling, appropriate mitigation, avoidance, and control measures, as well as rescue procedures.

      4. Identify other site-specific hazards and how to protect Authorized Employees (e.g. noise, electricity). Determine if employees with specialized expertise to mitigate specific hazards are needed, for example, to verify proper lockout/tagout of hazardous energy sources and proper Radio Frequency (RF) monitoring.

      5. Evaluate if there is a safe means to reach the worksite and if the worksite is safe to access. The assessment will include any ladders or personnel lifting devices Authorized Employees will use.

      6. Determine if fall prevention measures are adequate. For example, carefully inspect guardrails to check if they are properly installed, in good condition and in compliance with specifications in applicable OSHA standards. Implement necessary measures to protect Authorized Employees if existing fall protection measures are inadequate.

      7. Identify, select, and provide Authorized Employees with the appropriate equipment in optimal working condition for the specific task, including fall protection and self-rescue equipment, and personnel lifting devices if necessary.

      8. Determine whether a Personal Fall Restraint System (PFRS) or a Personal Fall Arrest System (PFAS) is needed.

         NOTE: Fall restraint is preferred over fall arrest.

      9. Determine the appropriate emergency response personnel and rescue procedures needed to ensure that, if necessary, a rescue proceeds quickly and efficiently.

      10. Notify the necessary emergency response team or trained Fire Department with the capability and equipment to support the planned rescue in the area (e.g. ladder truck high enough to gain access to rescue an employee).

      11. Brief all personnel on methods to contact Emergency Medical Services.

   5. Review the fall protection and rescue plan with Authorized Employees and make any necessary adjustments before starting work.

2. Equipment Selection

   Selected components will be compatible with the fall protection systems in use in accordance with the manufacturer’s recommendations (e.g. components for PFAS/PFRS, ladder safety devices/systems).

   1. Personal fall protection equipment includes:

      1. Personal Fall Arrest Systems:

         1. Anchorage

         2. Connectors

         3. Full-body harness

         4. May include a shock absorbing lanyard, a retractable lanyard, Y lanyard, deceleration device, or suitable combinations

      2. Personal Fall Restraint Systems:

         5. Anchorage

         6. Connectors

         7. Full-body harness

         8. Other necessary equipment, e.g. lanyard, other devices

   2. Tower (e.g. wind turbine, tower crane, communication tower) climbing equipment includes:

      1. Personal fall protection equipment for tower climbing:

         1. Full body harness (specific tower climbing harness have additional features for comfort and safety)

         2. Anchorage devices

         3. Connecting devices: carabiners, carrier rail, hooks (attachment points), safety sleeve

         4. Lanyards (Y-lanyards, self-retracting lanyards, shock absorbing lanyards, positioning lanyards)

         5. Cable/Rope grabs

         6. Ropes and lifelines

         7. Gloves

         8. Safety shoes/boots (appropriate for tower climbing)

      2. Appropriate self-rescue equipment.

      3. Additional personal protective equipment based on specific worksite hazards include:

         1. Head protection (chinstrap required)

         2. Eye protection (safety glasses)

         3. Face protection (face shield)

         4. Hearing protection (ear plugs and/or muffs)

         5. Burn protection (flame-retardant clothing if applicable, e.g. wind towers)

      4. Personal radio frequency monitors, properly selected, and calibrated for towers with active transmitters or unknown status.

      5. Communication equipment such as properly functioning portable two-way radios that are hands free (e.g. headsets) or cellular phones to dial the direct access number for Emergency Medical Services for the local area.

      6. Properly fitting weather appropriate clothing (e.g. loose but not baggy, free from snag hazards such as loops, and suitable for the hot or cold weather condition).

3. Equipment Inspection, Maintenance, Storage, and Disposal

   Procedures for proper equipment inspection, maintenance, storage, and disposal will comply with applicable OSHA standards and manufacturers' instructions.

   These procedures will include:

   1. A regular inspection schedule with documentation for fall protection and self-rescue equipment in accordance with applicable OSHA standards and manufacturers’ recommendations.

   2. Equipment inspection before and after each use to identify indicators for when to remove equipment from service such as:

      1. Alteration, damage, or defects to hardware elements, for example, straps, ropes, buckles, or stitching.

      2. Absent or improperly functioning mechanical devices, connectors, or other components.

      3. Chemical damage, sharp edges, cracks, corrosion, or deformation.

   3. Proper maintenance and storage in accordance with manufacturer’s instructions, for example, hanging-up cleaned harnesses in a designated storage location after use.

   4. Equipment disposal, removal and return to service procedures that are in accordance with OSHA standards and manufacturer’s recommendations (see 29 CFR 1926.502(d)(19)). For example, equipment removal from service if activated in a fall, or involved in any incident that could cause damage or when defects or damages are identified during inspection.

4. Policy on Using Other Employers' Equipment

   1. OSHA employees will avoid using equipment provided by an employer other than OSHA, such as personnel lifting devices, at an inspection, investigation, or training location.

   2. In rare instances when there are no alternatives and it is essential to use equipment, except ladders, owned by an employer other than OSHA, Authorized Employees must follow specific procedures for the Region/SLTC/CTC/DTE and verify that the equipment is safe to use before using it.

      Specific procedures for the Region/SLTC/CTC/DTE will include how to obtain permission from the RA/Director or the Responsible OSHA Manager before using equipment, except ladders, provided by an employer other than OSHA.

      An OSHA employee with training, knowledge, expertise, and experience about the specific piece of equipment will verify that it is in optimal working condition; ensure that the proposed use is in accordance with manufacturer’s specifications; components are compatible; and a qualified operator is available to run the equipment, if applicable.

   3. OSHA employees may use ladders at their discretion. Safety evaluation and determination before using a ladder will include inspecting the ladder to ensure that it is in good condition, properly installed or positioned, and the load rating is sufficient to withstand equipment/tools and the OSHA Employee’s weight.

      Authorized Employees may attach to an existing anchor point upon inspection and verification that it is adequate for the specific task (see 29 CFR 1926 Subpart M, Appendix C (II(h)), Tie-off considerations, 29 CFR 1926.502(d)(15) to (d)(15)(ii), (e)(2)). Authorized Employees may seek assistance from their supervisors or other knowledgeable persons, such as engineers, to properly assess anchor points.