While fall protection remains at the top of the violations list again for 2018, fall hazard training is also a top violation — coming in at number eight with 1,982 violations issued last year. The Occupational Safety and Health Administration’s (OSHA’s) final rule in 2016 extended the range of the walking and working surface standard for general industry and added a fall protection standard for general industry. In doing so, OSHA recognized that many general industry workers face comparable fall hazards as those in construction.
The 2016 rule requires general industry employers to identify fall hazards in their workplace and establish plans and procedures to prevent slip and fall hazards on floors, roofs, stairs, ramps, dockboards, scaffolds, elevated platforms and other walking-working surfaces. The rule also created training and equipment requirements for workplaces that use personal fall protection systems — namely, components and devices must be adequately rated, and employees must be properly trained to use them.
The original rule was created in 1971, and guardrails were the primary method of required fall protection. Now the standard is performance-based because guardrails alone didn’t protect workers from falls adequately. Today, OSHA allows employers the flexibility to determine the most effective ways of preventing specific fall hazards.
This flexibility and performance-based rule has long been in place for the construction industry. Its recent introduction to general industry has created both compliance challenges for employers as well as opportunities to improve workplace safety. To help avoid confusion, the general industry rule mirrors the construction standard wherever possible.
An important step in preventing accidents involves creating plans and procedures, which rely on effective training. Employees won’t know about or understand the plans and procedures without proper communication and education. Therefore, OSHA requires training that outlines what employees must know before they are exposed to a fall hazard.
Because the standards are performance-based (and therefore flexible), they allow employers to choose the methods that they feel make the most sense for their workplace. Employers can meet the requirements with classroom or web/computer-based training, audio-visual, demonstrations, field training, or other forms of training. The one thing all programs should have in common is a qualified professional to conduct the training or answer questions when video or computer-based resources are used.
A formal degree is not required for the training professionals, but they must possess abundant knowledge of what OSHA describes as "the types of fall hazards, how to recognize them and the procedures to minimize them; the correct procedures for installing, inspecting, operating, maintaining and disassembling personal fall protection systems and other equipment." Employers can use professionals on staff, third-party vendors, or a combination to satisfy the training requirements.
Make sure the training is clear and easy to understand. This might involve offering the training sessions in multiple languages, based on the needs of your workforce, as well as using different training methods to accommodate each worker’s learning style.
Because the OSHA standard is performance-based, focus on what employees will be able to do when trained properly. Training should provide employees with the ability to identify and recognize fall hazards in the workplace and the areas where falls are likely to occur. Employees also must understand how following established procedures will protect them from injury or death for each identified fall hazard.
What specifically must the training include? It should focus on how to properly use tools and equipment, such as:
The instruction must also teach employees about each device’s limitations and how misuse can cause injury or death. If employees are using personal fall protection systems, then the training must also include effective techniques for:
Make the most of equipment instruction manuals for this part of the training. The manuals can help simplify the proper methods of caring for, inspecting, storing, and using each item.
Year after year, falls are a leading cause of injury and death in the workplace. The problem won’t go away completely, but employers can minimize the risk by continuously training employees. While OSHA does not specify any continuous training requirements, employers should nevertheless train all employees on a consistent basis and require immediate retraining for workers who have been involved in a fall or near-miss incident, or have performed a job or operated equipment in an unsafe manner.
Looking for a training resource to help you meet your risk management and safety requirements? The Associated Compass learning management system offers a wide range of safety and risk management courses, including Fall Protection Awareness training. Contact us to learn more.
Jim assists client with identifying and mitigating risk and implementing comprehensive loss prevention programs. He began his career as an occupational health nurse and quickly transitioned into managing occupational safety and health services.
Jim assists client with identifying and mitigating risk and implementing comprehensive loss prevention programs. He began his career as an occupational health nurse and quickly transitioned into managing occupational safety and health services. He worked for divisions of two Fortune 500 Companies, PPG Industries, Inc. and Rockwell Automation (Allen Bradley). He was responsible for general safety, OSHA compliance, ergonomics, industrial hygiene, industrial security and emergency response.
If you could give human form to your safety culture, what would it look like?
Maybe it would be a thick-set, shirtless brute named Trog with a foul disposition beating out a drum cadence to keep your employees rowing in-sync.
Or would it be more like a fussy and constantly disapproving Dickensian paper-pusher named Fizzlewhite who has never met a rule or procedure he didn’t like, even though he hasn’t done most of the things he creates rules to address?
If you were to search the various “mommy blogs” and parenting advice websites out there, how many of them do you think would endorse the following practice?
A child’s safety should always be a top priority for any parent. When leaving children under the age of 10 alone in the house for lengthy periods of time, be sure to provide the kids with a loaded pistol with the safety off in case a stranger should happen by. In a pinch, recently sharpened knives can be substituted for the pistol.
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