The Closest Thing to Wings
Guidelines for establishing a fall protection program
By Keith Jackson
Although the issue has received little attention in the aerospace industry until now, fall protection has, for decades, been a major concern for workers regularly exposed to dangerous heights. According to the National Safety Council Accident Facts, in 1997, falls to lower levels were the third leading cause of fatal occupational injuries. In fact, falls are the number two overall cause of death in the American workplace, just behind employee violence. A recent OSHA study involving 99 fall-related deaths indicates that nearly all of those deaths could have been prevented by using proper fall protection equipment. To reduce these numbers, OSHA has mandated the installation and use of fall protection equipment where workers are exposed to hazards of falling more than six feet.
Though it may be an added expense, consulting with the manufacturer of your system on training issues, or contacting an outside source, will pay big dividends in increased worker awareness, efficiency and productivity. Listed here are a few web sites to visit for information on training and consulting services. Many of the companies also provide training packages for sale via the web site.
www.FallSafety.com – Dynamic Scientific Controls, Inc. offers fall protection consulting, engineering, installation and institute training.
www.arguspacific.com – Argus Pacific offers company-wide, customized and site-specific health/ safety plans.
www.hawaiisafety.com/personal – Sun Industries offers training and installation of fall protection systems.
www.allind.com/training.htm – All Industrial Safety Products, Inc. offers group seminars, or individual seminars can be arranged at the customers location.
www.nasa-inc.com – North American Safety Associates offers training and certification in practical fall protection systems applications.
www.safetyconnection.com – Safety Connetion, Inc. offers actual hands-on exercise of rescue techniques and usage of equipment.
www.safetyonline.net/buyersguide – provides links to products and services of fall protection manufacturers.
www.safetyontheweb.com – Summit Training Source, Inc. offers training and safety videos.
www.puresafety.com – PureSafety develops new training packages, or programs based on your in-house materials.
FAA and OSHA regulatory background
Maintenance facilities fall under the jurisdiction of FAA, but FAA does defer to OSHA concerning this and other workplace safety issues to the extent allowed under 4(b)(1) of the Occupational Safety and Health Act of 1970 (OSH Act). Maintenance facilities must comply with the existing OSHA Requirements listed under the Code of Federal Requirements No. 29 Parts 1910 and 1926.
There are several OSHA regulations and American National Standards Institute (ANSI) guidelines (though ANSI is not a regulatory body) that apply to fall protection. Click on www.safetyconnection.com for links detailing this information. Employers need to understand these regulations and standards when selecting the appropriate fall protection equipment. David May, OSHA Area Director for New Hampshire, says, "Employers must be aware of the hazards faced by their employees on the jobs they require them to do; and they especially must be aware that the law compels them to do everything they can to protect their workers from those hazards. Anything less is unacceptable."
Different levels of protection
Fall protection can be subdivided into two basic categories: fall restraint and fall arrest.
A fall restraint system is a work positioning system designed to prevent a worker from falling from a work position. This can include such simple precautionary measures as installing guardrails, safety nets, or establishing a control zone (the area between an unguarded edge of a building or structure and a line that is set back a safe distance), or other OSHA-approved procedures. A major drawback to this type of system is that it may restrict the work area, making it impractical to perform tasks like working on top of a fuselage or engine.
On a more advanced level, workers can be equipped with a fall arrest system designed to protect them in the event of a fall. These systems are put into place in order to maintain maximum mobility and efficiency.
Fall arrest may consist of body supports, lanyards, self-retracting lifelines, rope grabs, anchorage components, and horizontal fall arrest lines — either flexible or rigid — engineered to slow and stop the victim after an accident. These systems generally have five components; a full body harness reduces the impact caused by a fall by spreading pressure evenly over your thighs, chest, shoulders and pelvis; a lanyard attached to the body harness between your shoulder blades and to an anchoring point; snaphooks, connect the lanyard to your body harness; an anchorage point, the place where your lanyard is attached to a solid, unmovable object that can support up to 5,000 lbs. Even though you may weigh only 200 lbs, in a fall, that 200 lbs can become 2,000 lbs. of force, depending on the distance and speed of the fall. The most critical element in determining an anchorage point is the swing factor, or how far the victim might swing from side to side in a fall. This pendulum effect could do some serious damage, so never anchor the lanyard to a guardrail or any other dubious anchor point. Also, equipment
should be set up so that a fall is no more than 6 feet before the victim is slowed and stopped.
A mobile anchor system will protect the worker and still allow for maximum mobility.
This brings us to the final component: knowledge. Mechanics should be sure to know how the equipment works, and how to properly inspect all components. If something is found to be wrong with a piece of equipment, it should be replaced before the job can continue. A detailed description of these elements can be found at www.safetyinfo.com.
When compliance is an issue
Another option is a fall protection plan and essentially, it should function as a backup program. In situations where other options may not work, the employer is required to provide a training program for any employee exposed to fall hazards.
Listed below are some common situations, provided by www.safetyinfo.com, where work procedures may be acceptable because other forms of fall protection are impracticable:
· Installation or removal of fall protection equipment (first person up/last person down).
· Light-duty work for short duration, i.e. The performance from portable ladders of light-duty tasks such as inspection, touch-up paint, etc., for less than 15 minutes. The worker must not remove both hands from the ladder at the same time, nor move the body’s center of gravity past the outside rails of the ladder.
· Brief transfers between fall protection systems where the worker is protected by having a "3-point stance" (two feet placed firmly on the work surface, one hand supporting the worker and the other transferring to the next system).
· Work requiring constant repositioning, such as the primary connection of skeletal structures.
· Only workers employed in the initial placement of skeletal members requiring climbing and walking on the bare structure are likely to be covered by Section 11.2(5)(c), i.e.: scaffold erectors, tower erectors, blow-pipe ventilation erectors, structural steel erectors, tower crane erectors. All other workers on the structure engaged in welding, bolt installation, other fitting out work and climbing or walking on skeletal members must use the fall protection methods referred in the rest of Section 11.2.
· Emergencies such as firefighting, or the correction of an unsafe condition.
· When use of normal fall protection methods results in greater hazard. For example, cleaning gutters on a very steep roof where there may be greater hazard from climbing to the top of the roof to install anchors for fall protection equipment than working without the equipment.
Fall Protection Terms
Aerial lift device: Equipment such as powered platforms, vehicle-mounted elevated and rotating work platforms, boom platforms and powered industrial truck platforms.
Deceleration device: Any mechanism, such as a rope, grabbing device or ripstitch lanyard, which serves to dissipate a substantial amount of energy during a fall arrest.
Designated area: Space which has a perimeter barrier erected to warn employees when approaching an unprotected side or edge, and defines area where work may be performed without additional fall protection.
Lanyard: Flexible line of rope or strap that generally has a connector at each end for connecting the body harness to a deceleration device, lifeline or anchor point.
Rope grab (grabbing device): Deceleration device that travels on a lifeline and automatically, by friction, engages the lifeline and locks to arrest a fall.
Self-retracting lifeline/lanyard: Deceleration device containing a drum-wound line that can be slowly extracted from, or retracted onto, the drum under minimal tension during normal movement and which automatically locks the drum and arrests the fall (usually within two feet or less).
Standard railing: Vertical barrier erected along exposed edges of a floor opening, wall opening, ramp, platform, or runway to prevent falls of persons.
Tie-Off: A procedure of connecting directly or indirectly to an anchorage point.
A safety monitoring system is another way to prevent falls. You must have a competent person designated as a safety monitor whose job it is to actively patrol the work area and warn others of any possible danger. While employees are exposed, this is a full-time job — the monitor must be able to recognize fall hazards and cannot perform other work duties.
A competent person qualified in fall protection should explain all hazards in the work area, the correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used, and the use and operation of guardrail systems, personal fall arrest, warning line systems, safety monitoring systems, controlled access zones and any other methods used.
An example of a fall protection plan is available from OSHA at www.osha-slc.gov/OshStd_data/1926_SUBPART_M_APP_E.html.
Getting it done
If you’re just getting started, there are four basic steps to consider;
1. Identify the tasks performed at elevated heights.
2. Select options that will protect employees from these hazards.
3. Identify the employees that perform these tasks and activities. Addressing the individual strengths and weaknesses of those involved will maximize the effectiveness of your program.
4. Training. Mechanics should be able to recognize the inherent fall hazards and know how to implement the options you select. This isn’t just a good idea: it’s required. OSHA 1926.503 states, "The 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 in order to minimize these hazards."
Realize that even if you have a state-of-the-art system, if it isn’t used correctly, it’s more dangerous than not having anything at all. Your first step should be to look to the manufacturer of your system for training.
You’ve covered all the bases as far as developing a program and training employees on the equipment. So what happens if someone does fall off a wing or fuselage and injure themselves? Assuming the system has done its job, a rescue plan is necessary to ensure the employee can be retrieved quickly and without endangering the rescuer. You may need a crane or hoist, as well as some method of attaching a rescue rope to the individual. The extent of any injuries should be determined and first aid administered before moving the victim. If there are no serious injuries requiring medical attention, refer to guidelines of your program and safety equipment to rescue the worker.
Developing a fall protection program requires a commitment to safety and no shortage of hard work, but the benefits will far outweigh the costs. Know the regulations, identify the particulars of your situation, implement a fall protection plan, and train using ALL of your resources. Follow all of these steps, and productivity and shop safety will soar, and you can take pride in knowing you’ve equipped your mechanics with a set of "wings" nearly as effective as the real thing. AMT
For more information...
There are a number of manufacturers out there offering fall protection systems and training packages that can be specifically designed to suit any hangar environment. Check out the site list below to get started.
CAI Safety Systems (www.caisafety.com) manufactures Turn-key Safety systems, and offers Aerolution, a mobile, hydraulically-driven unit that requires no pushing or pulling around the hangar.
DBI/SALA (www.salagroup.com) offers fully customizable components, vacuum anchor systems that won’t damage airplane fuselages, and both on-site and in-house training.
Dalloz Fall Protection (www.christiandalloz.com) provides products, custom-engineered systems and professional training to ensure proper equipment use and maximum worker protection.
Fall Protection Systems, Inc. (www.fallprotectionsystems.com) offers its Trolley Rail, Triangular Truss and Lifeline and Harness Systems.
JLG Industries, Inc. (www.jlg.com) offers fall protection gear, and the 740AJ boom lift with an integrated fall arrest system that allows for work outside the platform, complete with optional air compressor and AC generator.
Klein Tools (www.kleintools.com) has fall arrest, position, suspension and retrieval systems designed to arrest free falls and distribute impact forces over thighs, pelvis, waist, chest and shoulders as required by OSHA.