Safety Considerations for Working at Height

Across all industries, falls remain the leading cause of series injuries and fatalities, according to the Occupational Health and Safety Administration (OSHA). In fact, fall protection continues to top the list of OSHA’s list of the Top 10 most frequently cited workplace standards, coming in at number one in 2023 for the 13th year in a row, according to OSHA data. That is the same year OSHA announced a National Emphasis Program directed to reduce and prevent workplace falls.

Specifically, within the United States Construction Industry, data from the Center for Construction Research and Training (CPWR) shows since 2013, workers in the construction industry have suffered 300 fatal and 20,000 non-fatal fall-related injuries annually.⁴ Further, from 2011 to 2022, 70 percent of fatal fall injuries occurred among those working for establishments with 10 or fewer employees, according to the CPWR.

With such a focus on fall protection and safety related to working at heights, there can be a lot for those in the roofing, contracting, building, facility management and related industries to navigate when it comes to standards, regulations, personal protective equipment and safety plans.

To help mitigate risks associated with working at height, OSHA regulatory standards and American National Standards Institute (ANSI) voluntary standards exist to guide organizations in developing safety plans to help keep workers safe on the job. Understanding OSHA requirements and ANSI standards, along with identifying the risks of a jobsite and application through a comprehensive hazard assessment—and what OSHA and ANSI require for those specific applications—are factors in helping to keep workers safe at height.

Fall Protection Standards

For example, OSHA 1926.501 addresses fall protection for the construction industry, requiring the use of guardrail systems, safety net systems, or personal fall arrest systems for employees working at a height of 6 feet or more. While separate from OSHA, ANSI is a private, non-profit organization that administers and coordinates the U.S. voluntary standards and conformity assessment system. ANSI works in close collaboration with stakeholders from industry and government to identify and develop standards- and conformance-based solutions to national and global priorities.

ANSI Z359 fall protection and fall restraint standards address “fall protection equipment and systems for climbing, work positioning, fall arrest, rescue, evacuation and other fall hazards. These standards also address training, and how to identify and abate hazards to prevent injuries when working at height.”

OSHA often references these ANSI standards as providing guidance related to worker protection.⁸ 

The below considerations about fall protection ABCs, industry standards, leading edge vs. non-leading edge and other unique applications, are additional factors that may be beneficial to keep in mind when choosing proper PPE and safety equipment.

The ABCs of Fall Protection

Selecting proper fall protection begins with an understanding of the components of a personal fall arrest system, often referred to as the “ABCs of Fall Protection” including anchor points, body harnesses and connecting devices.

Anchor Points: These are the foundation of any fall arrest system. Positioned securely on the structure being worked on, anchor points must be capable of supporting the considerable forces exerted during a fall. According to OSHA, there are two options when considering the strength of an anchor point for fall arrest: A Non-Certified Anchor Point is one that has been evaluated by a competent person and judged to be capable of supporting 5,000 pounds. A Certified Anchor Point requires analysis from a Qualified Person to determine if the structure can withstand two times the force at impact that will result from a fall – known as a safety factor of two.

Body Harnesses: Acting as the primary connection between the worker and the fall protection system, body harnesses help distribute the force of a fall across the more resilient parts of the body, such as the thighs, chest, and shoulders. This distribution helps reduce the risk of injury. 

Connecting Devices: These include energy absorbing lanyards, self-retracting lifelines (SRLs), and personal fall limiters (PFLs), and serve as the link between the harness and the anchor point. Their flexibility and functionality help provide freedom of movement while working at height.

Leading Edge vs. Non-Leading Edge Applications

OSHA defines a leading edge as “the edge of a floor, roof, or formwork for a floor or other walking or working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed.”

Due to the nature of the work, installing a guardrail around the edge of a surface under construction may not be feasible. However, workers are required by OSHA to wear fall protection when approaching the unprotected “leading edge.”

Leading edge work adds additional considerations that users should be aware of when selecting fall protection:

If a worker falls over the leading edge, the sharp edge can sever a lifeline on impact or from the worker swinging back and forth.

The anchorage for leading edge applications is usually (though not always) below D-ring level, often at foot level, because there is not always an overhead, approved attachment point, such as a wall or ceiling joist, and the lower anchor point does not interfere with a worker’s arm movement.

Choosing and Using Fall Protection PPE

Conducting a comprehensive hazard assessment is an important step in choosing fall protection. Determining the unique risks and concerns associated with a specific jobsite and application, and understanding the relevant OSHA requirements and ANSI standards, can help identify which fall harnesses, self-retracting devices (SRDs), and additional safety equipment and training may be right for the job site.

Harnesses: An employer may consider factors including wearer comfort and mobility, as well as how easily the harness can be adjusted for a proper fit. A wider variety of size options may also be an important consideration, especially in light of OSHA’s rule proposal that would explicitly require that PPE fit workers properly.

SRLs: An employer may consider devices with features such as color-coded housing or iconography, in addition to the Class shown on the product label, to help a user to determine whether the device is intended for leading edge or non-leading edge use (for example, green housing may signify leading edge, while gray signifies non-leading edge). An employer may also desire PFLs made with lightweight materials in a compact design, which may enable enhanced user mobility.

Having a Rescue Plan

Another recommendation is to develop and document a rescue plan. The plan should be communicated to all personnel who may participate in a rescue. It’s also a good idea to train the personnel on the plan; not just inform them of it.

Some of the issues that the plan should address are:

• Limiting the suspension time 
• Planning for a worker that is unconscious or injured and, therefore, unable to self-rescue or assist in their rescue
• Ensuring that all rescue equipment is onsite and easily deployed
• Making sure there is a person designated to call emergency services whenever a fall occurs
• Remember that when a fall happens, time is of the essence. The ability to rescue a person as quickly as possible may help reduce additional issues.
• The training should include:
• Fall hazards associated with the facility and the work done
• Methods used for fall hazard protection
• Proper use of personal fall arrest, positioning, or fall restraint systems
• The OSHA standards for their industry concerning fall protection

Additionally, the employee training must include proper donning and doffing of the equipment. While worker education is essential, there may be other required responsibilities for the employer.

As a final note, training and proper use of the selected PPE help to maintain safety while working at height. National standards and state, provincial, and federal laws may require the user to be trained before using fall protection products. 

By placing suitable fall prevention equipment and practices in place, it can help prevent a worker from becoming a fall statistic. Excellent choices of equipment and solutions exist in the market. Above all, nurture a culture of safety to help facilitate in using that equipment daily.

 Dennis Capizzi is marketing manager of fall protection PPE, MSA Safety, Cranberry Township, Pa. He began his career with MSA nearly two decades ago as the marketing event coordinator before transitioning into a product management role and finally into segment marketing. He has been responsible for respiratory, thermal imaging cameras, communications, head/eye/face/hearing, and fall protection equipment across both the industrial and first responder market. For more information, go to www.MSAsafety.com.