Brad Mang, Safety and Loss Control Consultant, FRSA Self Insurers Fund
Each year falls to a lower level are the leading cause of death among construction workers and account for one third of all construction fatalities. According to a new report from the Bureau of Labor Statistics, the fatality rate for workers killed because of falls rose to 38.7 percent (384 of 991 total deaths for 2016) an increase of 6 percent from 2015. Along with this troubling data, OSHA’s recent release of their Top 10 violations for 2017 included “general requirements for fall protection” as the number one violation, and a new entry for “fall protection training requirements” at number 9.
In addition to the loss of life, a fatality from a fall can easily bankrupt a company. More than 40 billion dollars in workers’
compensation benefits are paid out each year from employers and their insurance companies. OSHA has come down hard on employers who violate the fall protection standards through monetary fines. 2016 saw the agency’s fines adjusted for inflation, resulting in a 78 percent increase that lifted the maximum penalty for a serious violation from $7,000 to $12,934 and repeat or willful violations, to a maximum of $129,336.
In a recent study conducted by OSHA of almost 100 fall related fatalities, it was shown that all of these deaths could have been prevented if fall protection, such as guardrails or personal fall arrest systems, had been used on the job site. With this being said, it is vital that each worker exposed to a fall hazard has the proper training required to understand how to recognize, set up and use their fall protection equipment.
OSHA standards state that an employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed to minimize these hazards. Training should provide in depth sessions on regulations, potential hazards, equipment selection and instruction on how to use the equipment correctly. The training must be implemented by a "Competent Person" qualified in the following areas:
1. Procedures for erecting, maintaining, disassembling, and inspection of fall protection systems to be used.
2. Use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other possible protection to be used.
3. The role of each employee in a safety monitoring system.
4. The limitations on the use of mechanical equipment for low slope roofs.
5. Correct procedure for handling and storage of equipment and materials.
6. Role of employees in the fall protection plan.
Along with the standard, I must point out a brief description of what OSHA defines as a “Competent Person” “One who is capable of identifying existing and predictable conditions in work areas which are unsanitary, hazardous, or dangerous and who has the authorization to take prompt corrective action.” This is a very important detail to point out because roofing contractors need to consider who is training their employees and to ensure they are compliant with OSHA standards. The amount of time required for “Competent Person” training varies based on the scope of work performed but on average is 8 to 40 hours. The training will need to combine discussions, demonstrations by an instructor, testing, and hands-on demonstration by employees for each fall protection system used by the employer. A certification of training will also need to be completed. The employer shall create a written certification identifying each employee trained, the dates of training, and the signature of the person who conducted the training or the signature of the employer. All materials used in the training should be maintained with the company records for documentation in the event of an OSHA inspection.
The result of an effective fall protection training program is a competent employee who can control fall hazards resulting in a higher level of safety and compliance. By investing in safety training, companies can avoid serious injuries and save lives, decrease insurance modification ratings and improve working conditions. A solid fall protection training program is a sound investment and not just another added expense to the company bottom line.
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