Compliance vs. Safety: How to Work (Safely) at Heights

Oct. 27, 2015
Compliance means meeting the industry's minimum safety requirements. A safety-based approach starts with getting the worker to where they need to be, and choosing the right approach from there, not taking a good tool and using it for every application.

For many years now, working safely at heights has been at the forefront of issues that regulators and inspectors review for job site safety. Recognizing that even relatively small falls can result in devastating injuries, lost production, and larger fines, employers are more likely than ever to look for different options for fall protection solutions to keep workers safe. In an effort to simplify this goal, however many employers get sidetracked by setting oversimplified goals intended to meet the letter of the law.

How to provide safety for workers at height usually starts with evaluating the applicable legislation – the “when do we need fall protection” question.

Typically the default height given by federal (OSHA) or regional regulations is cited as the rule, when in fact, it is only a starting point or a minimum requirement. If the only target is to be “tied off above 6 feet,” the employer is missing the point.

They are aiming for “compliance” rather than “safety,” and workers may not be getting all the protection they need.

A safety-based approach looks beyond the minimum requirements to see what is truly ‘safe’ for a worker to be doing. Just because OSHA says fall protection is required above 6 feet, does not mean that a fall from 5 feet is perfectly safe.

Risk of Injury

Anyone who has ever slipped on an icy sidewalk can verify that there is a risk of injury even at height “zero,” if someone happens to fall awkwardly. As workers get higher above the ground, the energy involved in a fall increases, as does the potential for a more serious injury.

When there are any additional risks, more stringent requirements need to be considered.

When evaluating any elevated work, the minimum height for fall protection must be considered, but for work situations near or even below that height, there are often many opportunities to work safer. With toolboxes, equipment, or other hazards near where a worker may fall from a short distance, there is an increased risk of injury for even a short fall.

A proper assessment of the task is required to determine what risks there are for the employee during the task, including getting to or from the work area.

Once the risks are more fully understood, then a more organized approach to finding solutions can be used.

The standard hierarchy of solutions is based on keeping things as simple as possible:

• Review of process – is there another way to do the task?

• Barrier between hazard/worker

• Active travel restraint/restriction system

• Active fall arrest system

Review the Maintenance Process

Too often, tasks are just done the way they’ve always been done. Taking a couple minutes to see if a given task could be performed in a different way that does not involve being at height is the first step. Remote technologies have come up with many ways maintenance workers are able to do things remotely. From light-bulb changing baskets on a painters’ pole, to using chains for overhead valves, new innovations are constantly being developed to help make some tasks much easier, quicker and safer. More recently, small remote controlled drones are being used with cameras to allow inspection of hard to see/access areas with workers safely on the ground. Based on this initial inspection it can be determined if more time-consuming hands-on work is required.

Compliance–based objectives seek only to see if fall protection is “needed” for a certain job, whereas a safety-based approach looks to see if it can be done another way, which could be both safer and easier/faster.

Reviewing the job process should be done at regular intervals to see if there are any new technologies or approaches that may now make things easier.

What is the Simplest Solution?

If the work must be done with a worker at height, the next simplest solution is to provide a safe work area, with a fixed barrier between the worker and any potential hazard. This could be a fixed or mobile work platform with guardrails to prevent the worker from being able to accidentally fall from the work platform.

Setting up a safe platform for an aircraft can be a large undertaking however, so grouping of similar jobs is another approach. Where changing a wiper blade may not be worth bringing out a scissor lift, if five small jobs can all be done at the same time, then it makes more sense.

The use of a stable work platform with guardrails provides the worker the simplest solution for working while at height, effectively simulating on-the-ground conditions. Many situations however utilize a mobile platform, but then require a worker to lean out, or climb up on the rails to reach the work area. Often the use of an “approved” platform is being confused with using the “appropriate” tool for the job. A safety-based approach starts with getting the worker to where they need to be, and choosing the right approach from there, not taking a good tool and using it for every application.

Fall Arrest vs. Fall Restraint Systems

Where the work is in an area where a flat, stable platform is not possible, the next step is to try to provide a system that will get the worker to the area, but prevent them from being able to fall by incorporating an active restraint system. Custom access ladders or even some horizontal lifeline systems can be set up so that workers using them are able to reach their work area but can NOT fall.

Working from a custom ladder, the worker has a restraint system to keep them from falling.

Use of “pre-engineered” lifeline kits can be useful to solve specific problems, but again, caution must be used to not try to apply one solution to too many different problems or it may not fit. A restraint lifeline may work well along the wings of a large aircraft, where workers cannot fall, but on a smaller plane, the same system and lanyard would allow the worker to fall.

As we move from a barrier to a restraint system, the worker has greater responsibility to ensure they are wearing the harness, and actively secure to the system. The system must be set up so that when working, the range of motion does not allow the worker to ever be in a situation where a fall is possible. This ability to fall is the critical distinction between fall arrest, and fall restraint – despite the two terms being commonly interchanged as if they were the same, they are not.

In cases where workers must be at height, and need the freedom to move around and will have the ability to fall, a fall arrest system is employed. Fall arrest systems are far more complex as they must consider a worker's free-fall distance, clearance, energy, and more. These systems require the most input from end users, as they must not only be designed, inspected, and operated properly, but subsequent rescue is a mandatory requirement for use of a fall arrest system. If a worker can fall, there must be a way to safely get them to the ground.

Fall arrest systems alone are a broad enough topic for discussion, but from a safety perspective, fall arrest must not be ‘fully’ designed (taking into account the end location of a fallen worker) but be paired with rescue, as having one without the other is often a symptom of just trying to meet a compliance target.

Too often the task of overhauling ‘working at heights’ at the workplace is a highly intensive, time-consuming process, and the appeal of simplifying it all with a single line in the sand (at a certain height) is tempting. Unfortunately, this can lead to situations where workers may still not have the right tools for the job, or are working in an unsafe condition despite attempts to meet a false compliance target. A safety-based approach is admittedly more time-consuming, involving evaluating each task, but has the more enviable target, which is to ensure the job is being done safely.

Brad Lawrence, P.Eng., is senior engineer (fall protection and safety audits) of Liftsafe Group of Companies. He has been a critical member of the company since 2007 and manages the Fall Protection Division of Liftsafe Fall Protection Inc. As an active participant on the CSA Standards Committee for Fall Protection Solutions, he utilizes his extensive experience to assist in developing fall protection standards throughout Ontario. For more information visit