Fall Prevention & Protection Program
Last Update: 07/18/2019
The purpose of the Injury Illness Prevention Program (IIPP) is to outline Cal Maritime's environmental health and safety requirements, expectations, and responsibilities in order to achieve effective campus safety performance through Integrated Safety Management (ISM). The Fall Prevention & Protection Program is a subject specific component the supports the overall University IIPP.
Note: Training Ship Golden Bear (TSGB) is regulated under MARAD. For operations pertaining to the TSGB - Refer to Shoreside Administration Manual (SAM) and Vessel Operations Manual (VOM).
About Fall Prevention & Protection Program
Falls present significant workplace hazards. The Federal Bureau of Labor Statistics states that in 2009, 608 people died from falls. That's 14% of the total workplace fatalities in the USA that year! In California, of the 54 falls that occurred that year, 41 could have been avoided by proper use of fall protection equipment (FPE).
The use of fall protection equipment (FPE) poses physical and physiological hazards that could result in permanent injury or death to the wearer when used incorrectly or without adequate preparation for rescue after a fall.
The Cal Maritime developed this program to describe all aspects of secondary FPE use, inspection, personnel accountability for the condition and use of the equipment, safe work practices, training requirements, and record keeping.
There are two types of FPE, primary and secondary. Primary FPE refers to stationary objects that act as engineering controls for the prevention of falls. This includes guardrails, floors, ramps, platforms, and lifts or scaffolding. Secondary FPE refers to devices attached to structures whose sole use is for fall protection anchorages, and any devices used for fall protection that a user attaches to them (lanyards harnesses, elbow straps, etc.). This program primarily applies to secondary fall protection equipment worn by the FPE user and attached to structural anchor points.
This Program applies to any activities being conducted in elevated locations by University personnel where fall hazards that require wearing of FPE for protection are part of research/work activities. This includes contract employees and graduate students performing research related activities in field stations and remote research facilities.
Employers must set up the work place to prevent employees from falling off of overhead platforms, elevated work stations or into holes in the floor and walls. Fed/OSHA requires that fall protection be provided at elevations of four feet in general industry workplaces, five feet in shipyards, six feet in the construction industry and eight feet in longshoring operations. In addition, OSHA requires that fall protection be provided when working over dangerous equipment and machinery, regardless of the fall distance. Cal/OSHA requirements depends on the activities for example 7.5-feet in construction
Please Note: As a means of best management practice, Cal Maritime will be adopting the Fed/OSHA construction standard of six feet for all land-base/shore-side operations.
OSHA defines fall protection as "any equipment, device, or system that prevents a worker from falling from an elevation or mitigates the effect of such a fall." Under the final rule, employers may choose from the following fall protection options:
- Safety net system
- Personal fall arrest system
- Positioning system
- Travel restraint system
Proper training, maintenance and inspection of all components of FPE are crucial in creating a safe work environment. The following procedures outline activities to be followed when implementing this program.
Owner Department Requirements
The Department owning FPE designates the "Fall Protection Program Coordinator(s)" responsible for the following actions:
- Ensures that FPE purchased and used in the department are code-compliant and appropriate for the needed safe-work tasks.
- Consults with the SRM Fall Protection Program Manager as needed to assess proper FPE use and procurement specifications.
- Coordinates with SRM to provide documented fall protection safety training, or provides FPE training themselves (by JSA or other presentation), to all department personnel who use FPE. Periodically audits departmental compliance with the Fall Protection Program.
- Only allows persons who have successfully completed documented Fall Protection training to use FPE and conduct work requiring use of FPE.
- Informs SRM when new equipment is purchased so it can be added to the SRM FPE inventory.
- Ensures that all FPE owned by the department has documented FPE inspections completed by SRM every 6-months.
- At least annually reminds the FPE users of their requirements under this program.
Fall Protection Program Coordinator
The Owner Department's Fall Protection Program Administrator is trained on their roles and responsibilities in the management of the Fall Protection Program as it applies to their department, and maintenance requirements and the semi-annual equipment inspections outlined in this program.
Are trained as part of their work activities once on the contents of this program and the general safe-work procedures it contains. In addition, site-specific or task-specific safe- work orientation as well as tail-gates trainings may be needed in the use of FPE for unusual operations. Annual review of the general requirements and safe-work rules of this program is recommended for tailgate meetings or periodically scheduled safety meetings.
Who Must be Trained?
Any employees who are expected to utilize FPE s as part of their job duties must be adequately trained prior to using such equipment.
- Employees should be trained in the following areas:
- Be able to recognize hazards associated with different types of tools and equipment; and the safety precautions necessary for use.
- The PPE required to be worn during the use of tools.
- The proper use of hand and power tools and other hand-held equipment
- Be able to recognize defects in tools, which may render them out of service.
- When applicable, provide access to the manufacturer specifications and manual's for specific equipment to be used.
- Department-developed standard operating procedures (SOPs) outlining specific safety precautions for certain tools or activities.
When is Training Required?
Fall Protection and Prevention Program Training is categorized as Initial/ Reassignment / Refresher Training and is required in the following circumstances whenever they occur:
- Initial: Taken initially when an employee begins work,
- Reassignment: Taken when an employee is reassigned, changes jobs or the hazards to which they are exposed during their job changes (i.e. equipment changes, material changes etc.)
- Refresher: As determined by regulatory standards and or when there are updates to the Program, employees must be trained on the changes and will be notified when that occurs.
The Department of Safety and Risk Management (SRM) offers training in the form if Initial/Reassignment and Refresher Training to all employees and is comprised of two parts; classroom and practical demonstration of skills.
Training content is determined by the Department of Safety and Risk Management, as well as Department Management which is based upon observed hazards, type of equipment, Department need, and work requirements.
The Department owning the FPE has the option of providing Part 1 of the FPE Training from:
- Providing training from within the department, or
- Training provided by University SRM, or
- A training provider outside the University.
- Note: All outside trainer venders are to be reviewed and content approved by SRM.
Part 2: Practical skills demonstration is to be scheduled with SRM. The user will be expected to demonstrate knowledge, skills and abilities of safe use of the eqiipment.
Regardless of the source, the complete contents and safe-work procedures outlined in this program must be part of any fall protection safety training at Cal Maritime. Training content and attendance is documented and kept in a readily accessible location by the Owner Department for reference as needed by department management, SRM, or regulatory agency (e.g. Cal/OSHA).
For any FPE/Fall Protection Safety Program training, a list of training attendees with their name, employee identification number, their supervisor's name and employee identification number must be provided to SRM for inclusion in the L.M.S. Master training records database.
Training is to be documented and kept in a readily accessible location by the Department designee for access reference as needed by Department Management, Department of Safety & Risk Management, or regulatory agency (e.g. CalOSHA). Submit the completed training roster of attendees to the Department of Safety & Risk Management.
Program Coordinators are trained on their roles and responsibilities in the management/maintenance of the requirements and inspections outlined in this program.
Refer to Cal/OSHA Safety & Health Training and Instruction Requirements as outlined in Appendix C of the Injury Illness Prevention Program.
Any equipment, device, or system that prevents a worker from falling from an elevation or mitigates the effect of such a fall." Under the final rule, employers may choose from the following fall protection options
Guardrail System – A barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent workers from falling to a lower level.
Safety Net System – A horizontal or semihorizontal, cantilever-style barrier that uses a netting system to stop falling workers before they make contact with a lower level or obstruction.
Personal Fall Arrest System – A system that arrests/stops a fall before the worker contacts a lower level. Consists of a body harness, anchorage, and connector, and may include a lanyard, deceleration device, lifeline,
Positioning System – A system of equipment and connectors that, when used with a body harness or body belt, allows a worker to be supported on an elevated vertical surface, such as a wall or window sill, and work with both hands free.
Travel Restraint System – A combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support to eliminate the possibility of a worker going over the unprotected edge or side of a walking-working surface.
Ladder Safety System – A system attached to a fixed ladder designed to eliminate or reduce the possibility of a worker falling off the ladder. A ladder safety system usually consists of a carrier, safety sleeve, lanyard, connectors, and body harness. Cages and wells are not considered ladder safety systems or a suitable combination. Like OSHA's construction standards, the final rule prohibits the use of body belts as part of a personal fall arrest system.
- Active systems include personal fall arrest, positioning devices, and personal fall restraint. All three active systems consist of a full body harness, connecting device (i.e. shock absorbing lanyard, fall limiter, self-retracting lifeline, etc.), and an anchorage point.
- Personal fall arrest systems: used to arrest an employee in a fall from a working level and rigged so an individual cannot free fall more than six feet
- Personal fall restraint systems: used to prevent an employee from falling and rigged so an individual cannot free fall more than two feet
- Positioning systems: rigged so that employee movement is only as far as the sides of a working level or area.
Active fall protection systems require routine inspection and maintenance. Employees are required to inspect their system daily before use. A "competent person" is required to inspect systems every six months. A "competent person" is a trained individual capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary or dangerous to employees, and who has the departmental/project authority to take prompt corrective measures to eliminate such hazards. Defective equipment or any equipment involved in a fall is required to immediately be removed from service. Additionally, the American National Standards Institute (ANSI) requires full body harnesses and lanyards to be in use no more than five years from the first date of service.
A "Fall Protection Plan" can be used if it can be shown that the use of conventional fall protection is impractical or creates a greater hazard. The plan must be prepared by a qualified person and developed specifically for the site. The fall protection plan shall document the reasons why the use of conventional fall protection systems are infeasible or would create a greater hazard and should include measures that will be taken to reduce or eliminate the fall hazard. Alternative systems used under a fall protection plan include controlled access zones and safety monitoring systems.
FPE is selected so that it fits comfortably, can be adjusted so that it is comfortable and has the attachment points appropriate for its use (positioning, fall arrest, etc.).
Prior to use each FPE device is inspected for the following:
- Operation of snap-hooks or any other means of attachment
- Condition of webbing, straps and buckles
- Operation of brakes and ratchets in self-retracting lanyards and winches
- Damaged, defective, or in any way questionable FPE is removed from use and Owner Department management is notified of the problem.
- The work area is prepared and cleared of unnecessary obstructions.
- Cordon off the area below to alert people passing below of potentially falling items.
- Clear or shield obstacles that could affect the safe use of the FPE. This includes obstacles at a landing point if using a controlled decent device or sharp/abrasive surfaces that could impact a lanyard.
- Lanyards are never clipped together.
- If using FPE while working off a ladder, the Ladder Safety Program is referred to for the safe use of the ladder and fall protection on ladders.
- When working aloft, tools and supplies are secured with tool lanyards so they cannot fall.
- FPE is not used for any operation that it was not designed for.
FPE is not stored in the sunlight or in another source of ultraviolet light. Ultraviolet light degrades the condition of synthetic webbing. Store FPE in a dry clean place not subject to dust or weather. Hanging on storage hooks is a good idea for webbing devices.
- FPE is not stored with weight over folded webbing. The webbing can be creased and therefore be damaged.
- FPE is not exposed to any solvents that could breakdown webbing. This includes products containing acetone, MEK, lacquer thinner or other similar solvents.
- FPE is not subjected to hot surfaces or welding splatter. Any burn marks on or stiffening of webbing due to heat will make the device unusable.
- Always keep FPE ready for use by following the safe-cleaning and storage procedure
The Ladder Safety Program outlines information on the use of fall protection when working from a ladder including very specific activities that must be followed to work without fall protection.
Safe-Work Rules For Use of a Ladder:
- Select a ladder that is the proper length and duty rating for the intended work.
- The leaning-ladder must extend at least 36" above the edge of a roof/mezzanine when properly installed. A step ladder must be tall enough so that you don't have to stand on the top or the top two rungs of the ladder to access your work.
- Do not use electrically conductive (e.g. aluminum) ladders for electrical work or near live electrical parts.
- Inspect the ladder for broken of defective parts prior to each use.
- Remove damaged or defective ladders from use and notify department management of the problem ladder.
- Do not place ladders where they can be accidentally struck or displaced.
- If the ladder is used in an area where anyone could walk under it, the area must be cordoned off with a visual barrier such as yellow caution tape to alert pedestrians to the hazard of something falling from the ladder.
- Ladders must not be placed in passageways, doorways, driveways, or any location where they may be displaced by activities conducted on any other work, unless protected by barricades or guards.
- Tie, block, or otherwise secure portable ladders while in use.
- Do not splice ladders together.
- Face the ladder while ascending and descending.
- Do not stand on the top two rungs of a single ladder, extension ladder or the top cap and top step of a step ladder.
- Do not stand on the top three rungs of ladders unless there are members of an adjacent structure that provide a firm handhold, or the ladder user is protected by a personal fall protection system (e.g., positioning device or fall restraint system) tied off to a CalOSHA certified fall protection anchor.
- If working outside of the ladder's footprint, or when standing on the upper-most parts of the ladder as noted above, use an appropriate fall protection system as described in the Cal Maritime Fall Protection Program.
- Do not place planks on the top cap or any other part of a ladder.
- Do not use the X-bracing or other structures on the rear section of a stepladder for climbing unless the ladder is designed to be climbed from both sides. (See Extension Trestle Ladders and similar.)
- Make sure that the stepladder is properly set up and that the spreader is locked in place before use.
- Do not use the stepladder as a lean-to ladder.
- Always use a tool belt and other ‘hands-free' carrying devices when ascending and descending a ladder.
- When working aloft secure tools and supplies so they cannot fall from the ladder
Refer to Ladder Safety Program for more in depth details
Types of Fall Protection Equipment (FPE)
A Personal Fall Protection System is comprised of three (3) key components:
- Anchorage connector
- Body wear
- Connecting device to join them
FPE is selected and used to meet the design requirements for the following five categories of Fall Protection Systems:
- Arrest System
- Positioning System
- Restraint System
- Suspension System
- Retrieval System
Fall Arrest System
A personal Fall Arrest System is used to slow and stop a person during a fall from an elevated location. As a general rule, it is recommended that a Fall Arrest System be used at working heights of four (4) feet or more; however, regulatory agencies vary the height-use requirements based on tasks or industries. Contact SRM to assure compliance with codes prior to procuring and using Fall Arrest Equipment.
The Fall Arrest System consists of:
A positioning system is used to hold a worker in place while allowing a hands-free work environment at elevated heights. The positioning systems are not designed for fall arrest and, therefore, a back-up fall arrest system must be used.
A typical positioning system consists of:
A restraint system is used to restrict the worker's movement to prevent reaching a location where a fall hazard exists. The restraint systems are not designed for fall arrest and, therefore, a back-up fall arrest system must be used.
A typical restraint system consists of:
Suspension systems are used widely in the window washing and painting industries and are designed to lower and support a worker while allowing a hands-free work environment. The positioning and suspension systems are not designed for fall arrest and, therefore, a back-up fall arrest system must be used. A typical suspension system includes:
The retrieval system is primarily used in confined space applications where workers must enter tanks, manholes, etc., and may require retrieval from above should an emergency occur. Retrieval Systems may also be used in rescue after a fall has occurred and the victim is hanging by the Fall Arrest System in suspension. A retrieval system typically consists of:
Fall Protection Rescue Plan
A rescue plan must be developed whenever fall arrest systems are in use and when personnel may not be able to self-rescue should a fall occur. Rescue plans are required because if a person has fallen and is suspended in a harness for a relatively short period of time, even two to ten minutes, the result could be suspension trauma. Suspension trauma can result in loss of consciousness and potential death; therefore, a rescue plan and its implementation are required by code whenever someone using FPE may not be able to rescue themselves after a fall.
What is the emergency contact information of professional rescue services available, such as the local Fire Department, and what are the instructions for summoning immediate assistance?
A rescue plan must be written) and include the following:
- A second person (attendant) must accompany the person using the FPE and be in direct communication with that person.
- The attendant must have been trained in the recognition of the pre-fainting symptoms (pre-syncope).
- The attendant must have immediate access to paramedic emergency services.
- The attendant must have some means of immediate rescue assuming the person who has fallen is not able to assist in the rescue.
Cal Maritime and its subcontractors shall comply with the following requirements.
In case of conflict or overlap of the below references, the most stringent provision shall apply.
- Occupational Safety and Health Act (OSHA), 1904, 1910, 1915,1917,1918,1926
- California Code of Regulations (CCR), Title 8, GISO, CSO, ESO
- · §1620. Design and Construction of Railings.
- · §1621. Railings and Toe-boards.
- · §1660. Suspended Scaffolds for Loads of 425 Pounds or Less.
- · §1662. Boatswains' Chairs.
- · §1663. Float Scaffolds.
- · §1664. Needle-Beam Scaffold.
- · §1669. General Requirements for Fall Protection Use.
- · §1670. Personal Fall Arrest Systems, Personal Fall Restraint Systems and Positioning Devices.
- · §1671. Safety Nets.
- · §1671.1. Fall Protection Plan.
- · §1671.2. Controlled Access Zones and Safety Monitoring Systems.
- · §1704. Pneumatically Driven Nailers and Staplers.
- · §1710. Erection of Structures.
- · §1712. Reinforcing Steel and Other Similar Projections.
- · §1716. Bolting, Riveting, Fitting-Up and Plumbing.
- · §1730. Roof Hazards.