Fall Protection

Responsibilities

Environmental Health & Safety

Environmental Health & Safety is responsible for developing, implementing, and administering the Fall Protection Program. This involves:

• Training all operators in the associated hazards and general safe work practices.
• Maintaining centralized records of training and certification records.
• Providing technical assistance to university personnel.
• Evaluating the overall effectiveness of the program on a periodic basis.

Departments

Departments are expected to maintain a safe and healthy living, learning, and working environment for faculty, staff, students, and visitors to Virginia Tech.

Departments must identify fall hazards in the area, or tasks involving work at heights, and ensure personnel are properly trained to use fall protection equipment provided.

A designated responsible person(s) to coordinate the requirements of this program with employees is recommended. Designated persons must attend Environmental Health and Safety Fall Protection User training.

Employees

• Employees using personal fall arrest systems must attend Environmental Health and Safety Fall Protection User training and use the equipment in a safe and responsible manner. 
• Employees must report all falls involving personal fall arrest systems to their supervisor and remove the equipment from service. 
• Where personnel are working in an area where potential fall hazards exist, but workplace policy does not permit employees to be exposed, Environmental Health and Safety Fall Hazard Awareness level training is required.

Contractors

Contractors must comply with all local, state, and federal safety requirements, and assure that all of their employees performing work on Virginia Tech properties have been suitably trained and are provided with appropriate personal protection. Contractors must also comply with the requirements outlined in Virginia Tech's Contractor Safety Program. Contractors working at heights, or exposed to a fall hazard situation, on-campus must coordinate such work with their project manager to assure both parties are informed and work activities are coordinated, where necessary. Access to any roof on campus, for example, must be coordinated due to chemical/biological exhausts, RF, noise hazards, fall hazards, and the use of anchor points. Refer to the Roof Access Policy for more information.

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Training

Fall Hazard Awareness Training

Personnel who have existing or potential fall hazards in their work area must complete Fall Hazard Awareness level training. This training is intended to inform personnel of existing fall protection systems that are in place, and must not be overridden. For example, personnel accessing building roofs, which have a sufficient parapet wall around the perimeter, must complete awareness level training to understand the expectations and limitations of existing systems.

Fall Protection User Training

Competent persons and personnel who will be using personal fall arrest systems must attend Fall Protection User training offered by Environmental Health & Safety prior to being assigned such responsibilities.

Training will address the following topics:

• Recognition and nature of fall hazard situations in the work area;
• Fall hazard evaluation to determine feasible controls;
• Various types of fall protection systems that may be used;
• Components of a personal fall arrest system; and
• Inspection of personal fall arrest systems.

Refresher training is required every 3 years, or under the following conditions:

• There are changes in the workplace that make previous training obsolete;
• There are changes in the types of fall protection systems or equipment used that render previous training obsolete; and/or
• There are inadequacies in the employee's knowledge or use of the fall protection system or equipment that indicate a lack of understanding or skill.

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Fall Protection Options

When selecting a means of fall protection for any given hazard, the hierarchy of controls should be considered in order of elimination first, passive fall protection systems next, then active fall protection systems or administrative controls last. There may be situations where more than one control measure is necessary to reduce the risk of a fall. 

Existing building-specific fall hazard conditions and available fall protection information is available in the Roof Access Program. 

Elimination or Substitution

Removing the fall hazard, or the hazardous work practice or task is the most effective control measure for eliminating the risk of falls from heights. It should always be considered first.  Examples include relocating gauges or valves to ground level, installing gutter guards to reduce or eliminate routine maintenance, using extended pole saws, trimmers, or light bulb changers, or the use of drones for inspections of elevated surfaces.

Passive Fall Protection Systems 

Passive fall protection options should be considered next, and include those where the hazard is isolated or separated from personnel. Examples include:

Guardrails

OSHA-compliant guardrails or parapet walls of sufficient height (on roofs) provide a permanent means of fall protection, which are sufficiently provided that they are not misused (i.e. leaning through or over guardrails or walls which could result in a fall). Guardrails may be temporarily installed for the length of the project, or permanently installed where access is more frequent.

Permanent Locations

Guardrails systems for permanent locations should be installed to address fall hazards in accessible areas where maintenance activities must be performed. Where aesthetics are of concern, consider options to minimize the visibility of fall protection systems, such as:

• Portable guardrails with permanent mounts installed for easy rail installation.
• Free-standing, non-penetrating (roof membrane) systems.
• Collapsible or folding guardrails.
• Architectural guardrails which curve away from the roofline to decrease visibility.

Temporary Locations

For construction and/or renovation projects, guardrails may need to be installed on a temporary basis, and must meet the following criteria:

• Top rails shall be 42 inches, plus or minus 3 inches, above the walking-working surface.
  • Must withstand a force of at least 200 pounds applied in a downward or outward direction.
  • Must be at least 0.25 inches in diameter or in thickness.
  • Midrails shall be installed halfway between the top rail and walking-working surface when there isn't a wall or parapet that is at least 21 inches high.
    • Must withstand a force of at least 150 pounds applied in a downward or outward direction.
  • Toeboards shall be installed where there is the potential for tools, materials, debris to fall onto workers below.
    • Must withstand a force of at least 50 pounds.
    • Shall be a minimum of 3.5 inches in height.

Steel or plastic banding shall not be used for top or mid-rails. Number 9 tie-wire is permitted to be used to secure guardrails in place due to its rated strength.

Note: If a section of the temporary guardrail must be removed to perform a task, personal fall arrest systems must be used to provide fall protection.

Openings in walls greater than or equal to 30 inches in height and at least 18 inches wide require a guardrail system or other appropriate means of protection. 

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Covers

Holes (i.e. a gap or open space in a floor, roof, horizontal walking-working surface, or similar surfact that is at least 2 inches in its least dimension) must be effectively covered.

• Covers must be capable of supporting, without failure, at least two times the maximum intended load (personnel, equipment, materials, etc.) that may be imposed on the cover at any one time.
• Covers used for temporary protection, such as on construction projects, shall be secured in place and marked with the word "Hole" or "Cover" to identify the potential hazard. 
• Close roof hatches (unless guarded on all sides by a guardrail system) when on the roof to eliminate fall hazards. 

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Active Fall Protection Systems

Fall restraint

Fall restraint systems involve securing the person to an anchorage using a lanyard short enough to prevent the person's center of gravity from reaching the fall hazard. Examples include:

Travel Restraint Systems

Travel restraint systems consist of an anchorage, anchorage connector, connecting device (ex. lanyard), and the body harness to eliminate the possibility of a person from going over the edge of a walking-working surface. They must be capable of sustaining a tensile load of at least 5,000 pounds. 

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Positioning Systems

Positioning systems are used on vertical surfaces, such as window cleaning, climbing poles, or working on rebar to prevent the worker from free-falling more than two feet. A fall positioning system is defined as a body belt or body harness system rigged to allow a person to be supported on an elevated vertical surface and work with both hands free while leaning. 

A fall positioning system is defined as a body belt or body harness system rigged to allow a person to be supported on an elevated vertical surface and work with both hands free while leaning. Fall positioning systems shall conform to the following criteria:

• Anchorage for positioning systems must be capable of supporting at least twice the potential impact load of an employee's fall, or 3,000 lbs., whichever is greater.
• Connecting assemblies must have a minimum tensile strength of 5,000 lbs.
• Only locking-type snap hooks shall be permitted.
• Restraint lines shall have a minimum breaking strength of 3,000 lbs.
• The system must be inspected before each use for wear, damage, and deterioration. Defective components shall be removed from service immediately.
• Any system component subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection.
• Personnel using positioning systems must be trained in the limitations, proper hook-up, anchoring and tie-off techniques, methods of use, inspection, and proper storage.

When the temporary anchor point systems used on campus are used for positioning/restraint, specific training on the proper use and limitations of the system must be completed. Information on Weightanka mobile anchor points is available from the Division of Campus Planning, Infrastructure, and Facilities and Environmental Health & Safety.

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Ladder Safety Systems

Where Ladder Safety Systems are provided for fixed ladders extending more than 24 feet, or as provided on new installations after November 19, 2018, personnel must be trained on the proper use of the system. 

Ladder safety systems may be installed in some locations on campus. Upon initial installation, personnel from the department, along with representatives from Environmental Health & Safety, shall be trained by the manufacturer on the proper use and maintenance of the system. This training shall be documented. Subsequent training of users shall be the responsibility of the department in conjunction with Fall Protection User training provided by Environmental Health & Safety. Only components recommended by the system manufacturer may be used, such as a full-body harness with chest D-ring, if specified.

When ladder safety systems are installed, the following requirements must be met:

• The connection between the carrier/lifeline and the point of attachment to the body harness shall not exceed 9 inches in length.
• Mountings for rigid carriers shall be attached at each end of the carrier, with intermediate mountings spaced as necessary along the entire length of the carrier so the system has the strength to stop employee falls.
• Mountings for flexible carriers shall be attached at each end of the carrier and cable guides installed at least every 25 feet apart, but not more than 40 feet apart along the entire length of the carrier.
• The ladder safety system must be capable of withstanding, without failure, a drop test consisting of an 18-inch drop of a 500-pound weight.

System-specific Information:

Health and Safety Building

• Miller Saf-T-Climb Ladder System

Indoor Athletic Training Facility

• Miller Vi-Go Ladder Climbing Safety System

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Personal Fall Arrest Systems

Fall arrest systems are designed to stop a person after a fall has begun. The three components that make up a personal fall arrest system are the anchor point, bodywear (i.e. harness), and the connecting device (i.e. lanyard or fall limiter). Harnesses and connecting devices must be in compliance with national standards, inspected regularly, and properly worn, stored, and maintained. For information regarding personal fall arrest system equipment, see Appendix F of the Personal Protective Equipment Program.

The free fall distance shall be limited to no more than 6 feet, nor shall the person contact a lower level. To avoid contacting the next lower level, determine the fall clearance distance and compare it to the height of the anchor point from the ground or the next lower level. The configuration of the fall protection system chosen must be less than the fall distance (typically the height of the anchor point). The fall clearance distance consists of:

• Length of the anchor point (if using a strap, etc.);
• Length of the connecting device;
• Length of shock-absorber (after deployment);
• The average height of a worker (estimate 6 feet); and
• Safety factor (estimate 3 feet).

Anchor Points

Many roofs on university buildings will have a designated anchor point already installed. Others may have a mobile anchor point that personnel must be trained on prior to use, and some roofs may not provide any fall protection (and temporary systems must be implemented by the personnel accessing it). Available information on fall protection systems per building is provided on the Roof Access Chart.

Bodywear

Full body harnesses are approved for fall arrest, positioning, confined space rescue, and with ladder climbing devices. The combined body weight and tool weight of the person wearing the harness must be less than 310 lbs.

The back D-ring is the only connection point that can be used for fall arrest. Other D-rings on the harness are for:

• Confined space rescue (shoulder D-rings)
• Ladder climbing devices (front, chest D-ring)
• Positioning (side, hip D-rings)

The webbing used on some harnesses are burn resistant (ex. welding), chemical resistant, or flame-retardant (ex. arc-flash protective). Choose a harness that is suitable for the work to be performed and the materials to be used.

Connecting Device

Connecting devices (i.e. lanyards and self-retracting lifelines) are attached to the back D-ring of the harness and to the hardware of the anchor point. They must be inspected prior to use by the user and at least annually by a competent person. There are two primary types of connecting devices:

• Lanyards are typically 6 feet in length and must be used with a shock-absorber when used for fall arrest. The shock-absorber may expand up to three and a half feet during deployment. They may be made of steel wire, webbing, or rope. Snap hooks must have a self-locking gate.
• Fall limiters are self-retracting lifelines (SRL) that operate in a similar manner as a seatbelt. Falls are limited to two feet or less. The shock-absorber may expand up to 2-and-a-half feet during deployment. Because fall limiters restrict the free fall distance to two feet and the shock-absorber expansion to two and a half feet, they are considered more protective and therefore a better choice.

Falls and Rescue

Personnel working at heights where personal fall arrest systems are implemented must have a rescue plan. The rescue plan will specify how to summon emergency services, what responses can be taken by personnel in the area, and what responses should not be taken by personnel in the area. If rescue equipment, such as controlled descent devices or rescue poles are provided, personnel must be trained by their department on how to use it.

The buddy system (i.e. at least two persons on-site) must be implemented for fall protection options which could leave a person "stranded" or where a fall may not be detected for some time and emergency services delayed, such as when personal fall arrest systems are worn, an aerial lift is used, or warning lines/controlled access zones are used. Other options, such as the use of a safety monitor, require at least two people to implement.

For personnel wearing harnesses, remember to pull your knees up into a sitting position to avoid the effects of suspension trauma. If a self-rescue is possible, proceed with caution. Otherwise, lighten the load by removing tool belts or equipment and wait for emergency services to respond.

All components of the personal fall arrest system must be removed from service once it has experienced a shock-load from a fall.

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Safety Nets

Safety nets may also be used to prevent falls to the next lower level; however, they typically are not a feasible option for fall hazard situations on campus.

Safety Monitor System

Safety monitor systems are used as a last resort, where other positive means of fall protection are not available or feasible. It must only be considered when all other options have been eliminated, and requirements must be strictly followed.

A "competent person" must be designated to monitor the safety of other personnel on the roof (i.e. safety monitor).

The safety monitor must:

• Be on the same walking/working surface as the personnel working, and be within visual sighting distance of personnel being monitored;
• Wear a high-visibility vest for easy identification;
• Remain inside the safe zone of the roof (i.e. more than 6 feet away from the edge);
• Ensure that personnel do not engage in unsafe practices, and warn them when it appears that they are unaware of a fall hazard situation;
• Be close enough to communicate orally with personnel; and
• Not have other responsibilities which could take their attention from their monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor personnel engaged in roofing operations on low-slope roofs.

No personnel, other than personnel engaged in roofing work (on low-sloped roofs), or personnel covered by a Fall Protection Plan, shall be allowed in an area where personnel are being protected by a safety monitoring system.

Personnel working under a safety monitoring system shall comply promptly with fall hazard warnings from safety monitors.

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Definitions

Anchor point: A secure point of attachment for equipment such as lifelines, lanyards, deceleration devices, and rope descent systems. 

Authorized: An employee who the employer assigns to perform a specific type of duty, or allows in a specific location or area.

Competent person: An individual who has been trained to identify hazards related to scaffolding, or working conditions that are unsafe, unsanitary, hazardous, or dangerous for employees, and who has the authority to have these hazards eliminated or controlled.

Connecting device: A flexible line used to secure a body harness to a lifeline or directly to a point of anchorage. 

Deceleration device: (Shock-absorber) any mechanism which serves to dissipate energy during a fall. 

Deceleration distance: The additional vertical distance a falling person travels, excluding lifeline elongation, before stopping, from the point at which the deceleration device begins to operate.

Designated area: A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.

Fall arrest: A system used to stop a fall from heights and decrease the impact of forces on a body to minimize the extent of injury. It consists of an anchor point, connecting device (i.e. lanyard or fall limiter with shock absorber), and full body harness. 

Fall hazard: Any condition on a walking-working surface that exposes an employee to a risk of harm from a fall on the same level or to a lower level.

Fall protection: Any equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall.

Fall restraint: Equipment used to keep a person from reaching a fall point, such as the edge of a roof or the edge of an elevated working surface. 

Free fall: The act of falling - before the personal fall protection system begins to arrest the fall.

Free fall distance: The vertical distance a person falls before the fall arresting system begins to arrest the fall.

Guardrail system: A barrier erected along an unprotected or exposed side, edge, or another area of a walking-working surface to prevent employees from falling to a lower level.

Hardware: Buckles, D-rings, snap-hooks, and associated components which are used to attach parts of the personal fall arrest system together. 

Harness: Equipment that has straps that secure around the person wearing it in a manner to distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders, with a means for attaching the harness to other components of a personal fall protection system.

Hole: A gap or open space in a floor, roof, horizontal walking-working surface, or similar surface that is at least 2 inches in its least dimension.

Lifeline: A component of a personal fall protection system consisting of a flexible line for connection to an anchorage at one end so as to hand vertically (vertical lifeline), or for connection to anchorages at both ends so as to stretch horizontally (horizontal lifeline), and serves as a means for connecting other components of the system to the anchorage.

Low-slope roof: A roof that has a slope less than or equal to a ratio of 4 to 12 inches, vertical to horizontal.

Lower level: A surface or area to which an employee could fall (ex. ground levels, floors, roofs, ramps, runways, excavations, pits, tanks, materials, water, equipment, and similar surfaces and structures, or portions thereof).

Opening: A gap or open space in a wall, partition, vertical walking-working surface, or similar surface with dimensions that are at least 30 inches high and at least 18 inches wide, through which an employee can fall to a lower level. If the inside bottom edge of the opening is less than 39 inches above the walking-working surface, and the outside bottom edge of the opening is 4 feet or move above the next lower level, fall protection is required.

Personal fall arrest system: A system used to arrest an employee's fall. It consists of an anchorage point, connectors (i.e. lanyard or connecting device), and a body harness. 

Positioning system: A system of equipment and connectors that, when used with a body harness, allows an employee to be supported on an elevated vertical surface, such as a wall or window sill, and work with both hands-free.

Retractable lifeline: An automatic tensioning line that pays out and retracts a line at a certain speed and locks or brakes when the speed is exceeded. A type of connecting device. 

Qualified person: One who by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to solve or resolve problems related to the subject matter, the work, or the project. 

Self-retracting lifeline/lanyard: A deceleration device containing a drum-wound line that can be slowly extracted from, or retracted onto, the drum under slight tension during normal movement by a person. At the onset of a fall, the device automatically locks the drum and arrests the fall.

Shock-absorbing lanyard: A design that elongates during a fall to significantly reduce fall arresting forces. Also known as a deceleration device. 

Snap-hook: A self-closing device with a keeper, latch, or another similar arrangement which will remain closed until manually opened. 

Travel restraint system: A combination of an anchorage, anchorage connector, lanyard (or other means of connection), and body support that a person uses to eliminate the possibility of a person going over the edge of a walking-working surface.

Unprotected sides and edges: Any side or edge of a walking-working surface (except at entrances and other points of access) where there is no wall, guardrail system, or stair rail system to protect an employee from falling to a lower level.

Walking-working surface: Any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area in which work may take place without the use of other means of fall protection.

Warning line: A barrier erected to warn employees that they are approaching an unprotected side or edge, and which designates an area in which work may take place without the use of other means of fall protection.

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Documents

Contact Information

Robin McCall-Miller, Occupational Safety Program Manager

Phone: 540-231-2341
Email: rmmiller@vt.edu