Programs, incident lessons and capstone: a rooftop fall protection plan

Individual pieces of fall protection, a guardrail here, a harness there, protect workers only when they are part of a system that is planned, maintained and enforced. This final lesson looks at how employers manage fall protection as a program, what investigations of real falls teach, and how to bring everything in the course together in a written fall protection plan for a typical rooftop job.

A managed fall protection program

ANSI/ASSP Z359.2, Minimum Requirements for a Comprehensive Managed Fall Protection Program, describes what a well-run program looks like and is widely used as a model, alongside OSHA's training and design requirements. Larger employers often write a formal program that covers every site; smaller ones may rely on site-specific plans. Either way, the elements are the same.

• a policy that commits the organization to eliminating fall hazards where possible and protecting workers where not;
• defined roles: a program administrator, competent persons who assess hazards, inspect equipment and supervise, qualified persons or engineers who design anchors and lifelines, and authorized workers who use the systems;
• hazard surveys of each site, building or project, identifying every fall hazard and the controls chosen;
• written procedures and fall protection plans for tasks and locations;
• equipment selection, purchasing standards and compatibility checks;
• inspection, maintenance, storage and retirement of equipment;
• rescue procedures, equipment and drills;
• training for each role, with records and refresher intervals;
• incident reporting and investigation, including near misses and arrested falls;
• regular program audits and management review.

Equipment care and retirement

Fall protection equipment is life-saving equipment, and it wears out. Build a simple system: issue harnesses to individuals where possible so that they fit and are cared for; inspect before each use; have a competent person inspect every item at least once a year, or more often in harsh conditions, and record the result on a tag or log; send self-retracting devices for manufacturer service or revalidation as required; store equipment clean, dry, away from sunlight, chemicals and sharp objects; and retire equipment that fails inspection, has arrested a fall, or has reached the end of the service life set by the manufacturer. Destroy retired items, for example by cutting webbing, so that they cannot drift back into use.

Lessons from incidents

The incidents below include a well-documented public case and several composite cases. The composites combine features from many investigations and are labeled as such; they do not describe a single real event.

Case 1: the Toronto swing stage collapse (public case)

On December 24, 2009, a swing stage carrying six workers collapsed on a balcony repair project at a Toronto apartment building. Four workers fell 13 stories and died, and a fifth was seriously injured; the sixth, who was tied off, survived. Investigations and the court cases that followed found that the stage was defective, it was overloaded, only two lifelines were available for six workers, and several workers lacked adequate training. The company and, later, the project manager were convicted of criminal negligence. The case led to sweeping reforms in Ontario, including mandatory Working at Heights training.

Lessons: every worker on a suspended platform needs an independent lifeline and anchor; equipment must be designed, inspected and loaded within its limits; supervisors must stop work when protection is missing; and the legal consequences of ignoring fall protection can be criminal.

Case 2: the skylight during a service call (composite case)

An HVAC technician was sent alone to service a rooftop unit on a single-story warehouse in winter. The roof had several plastic skylights, partly covered by snow. While carrying a toolbox back to the hatch, the technician stepped onto a skylight hidden under snow and fell 7 m to the concrete floor. The building owner had no roof plan showing skylights, the service company had no procedure for roofs with skylights, and the skylights had no screens.

Lessons: building owners should identify and protect skylights permanently with screens or guards; service companies should require a roof hazard assessment before rooftop work; snow must be cleared and skylights located before anyone walks across a roof; and workers should not work alone on roofs where a fall is possible.

Case 3: the arrest that did not stop in time (composite case)

A worker on a 4 m high mezzanine used a 1.8 m energy-absorbing lanyard attached to a beam clamp at foot level so that he could reach over the edge to guide a pallet. He slipped, fell, and the lanyard and absorber deployed fully, but he struck the floor below before the system stopped him. The fall protection system worked as designed; the design was wrong for the situation. A calculation like the one in lesson 9 would have shown that an anchor at foot level with a 1.8 m lanyard needed far more than the available clearance.

Lessons: calculate clearance before choosing equipment; anchor overhead where possible; use self-retracting devices or restraint where clearance is short; and do not allow work that requires leaning over an edge when a pallet gate or other passive control would remove the need.

Case 4: the vent pipe anchor (composite case)

A roofer installing flashing on a low-slope roof tied a rope lanyard around a plumbing vent pipe because the permanent anchors were on the other side of the roof. When he lost his footing near the edge, the pipe snapped at the roof line and he fell two stories. The crew had a horizontal lifeline in the truck but had not set it up because the job was expected to take an hour.

Lessons: never anchor to pipes, vents or conduit; plan anchor locations for every part of the job; set up the planned system even for short tasks; and supervise the use of fall protection, not just its presence on site.

Common threads

Across many investigations, the same contributing factors appear again and again: no hazard assessment, protection not provided, protection provided but not used, incorrect anchors, inadequate clearance, removed guardrails and unsecured covers, fragile surfaces not identified, poor training, workers alone, time pressure, and no rescue plan. Very few fatal falls involve a failure that no one could have foreseen. Most involve a gap between what the employer knew should happen and what actually happened on the day.

Writing a fall protection plan

A written fall protection plan records how a specific job will be protected. Regulations in many jurisdictions require one for certain heights or methods, and it is good practice wherever fall arrest or restraint is used. A typical plan includes:

• the location, task, dates, employer and the competent person responsible;
• the fall hazards identified, with heights and what lies below;
• the controls chosen for each hazard, following the hierarchy, and why higher controls were not practicable where relevant;
• the equipment to be used, with standards and capacities;
• anchor locations, types and strengths, and who certified them;
• clearance calculations for each fall arrest arrangement;
• procedures for installing, using, moving and removing the protection;
• the rescue plan, equipment and people;
• training and competency requirements for each worker;
• inspection arrangements and sign-off.

Capstone: a rooftop unit replacement

A mechanical contractor will replace a rooftop unit on a four-story office building. The roof is flat, about 100 ft × 65 ft, 46 ft above grade. A parapet 42 in high runs along the two long sides; the two short sides have a parapet only 12 in high. There are two skylights near the unit, a roof hatch reached by a fixed ladder from the top floor, and three permanent engineered roof anchors certified for 5,000 lb each, located 13 ft from one short edge. A mobile crane will lift the old unit off and the new unit on. The work will take two days. Draft the main elements of the plan.

Bringing it together

The capstone shows the course in miniature. The best plan for this roof barely uses fall arrest at all. Parapets, temporary guardrails, skylight screens and a hatch rail protect most of the work passively, restraint protects the short phase when guardrails are installed, and rescue is planned for what remains. Wherever you work at height, the same sequence applies: find the hazards, eliminate what you can, put physical barriers in place, restrain before you arrest, calculate before you choose, plan the rescue, train the people, and check that it all happens on the day.