Chapter 30
Fall Protection Program

Contents

Approved by Kevin Goodwin
Revised 11/16

30.1 Policy
30.2 Scope
30.3 Applicability
30.4 Exceptions
30.5 Roles and Responsibilities
30.6 Definitions
30.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Fall Protection Equipment Procurement
Work Process C. Authorization and Training
Work Process D. Hazard Assessment
Work Process E. Work Control Requirements
Work Process F. Fall Protection Equipment
Work Process G. Passive Fall Protection Systems
Work Process H. Active Fall Protection Systems
Work Process I. Hazards Requiring Evaluation for Fall Protection
Work Process J. Off-Site Fall Protection
Work Process K. Covers
Work Process L. Protection from Falling Objects
Work Process M. Walking Working Surfaces
Work Process L. Protection from Falling Objects
Work Process N. Leading Edge Work
Work Process O. Hoist Areas
Work Process P. Working Near Holes
Work Process Q. Formwork and Reinforcing Steel
Work Process R. Ramps, Runways, and Walkways
Work Process S. Working Near Excavations
Work Process T. Working Near Dangerous Equipment
Work Process U. Overhead Bricklaying and Related Work
Work Process V. Low Sloped Roofs
Work Process W. Steep Sloped Roofs
Work Process X. Precast Concrete Erection
Work Process Y. Residential Construction
Work Process Z. Wall Openings

30.8 Source Requirements
30.9 Reference Documents
30.10 Related Documents
30.11 Appendices

Appendix 1. LBNL Fall Matrix Permit Acronyms
Appendix 2. Fall Calculation with 6 Ft Lanyard and SRL Models
Appendix 3. EHS OJT FP Safety Monitor Training
Appendix 4. LBNL Trigger Height Chart
Appendix 5. LBNL Active Fall Protection Infeasibility Plan
Appendix 6. Field Hazard Assessment Plan (Model)
Appendix 7. LBNL Fall Protection Matrix Permit Acceptance Letter

NOTE:
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. . . . . . . . Denotes the beginning of changed text within a section.
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30.1 Policy

The Lawrence Berkeley National Laboratory (Berkeley Lab) Fall Protection Program applies to work on any walking or working surface having an unprotected side or edge that is 4 feet high or more for General Industry workers and, 6 feet high or more for construction workers. 

while working using a fall restraint system with radio communication.

30.2 Scope

Berkeley Lab's Fall Protection Program manages the risk of falls while individuals are working at heights through planning, training, installation, use of fall protection and rescue systems, and implementation of fall protection and rescue procedures.

At Berkeley Lab, new work surfaces higher than 4 feet (6 feet for construction) must be designed to eliminate the need for fall protection. When feasible, existing work surfaces higher than 4 feet (6 feet for construction) must be modified to eliminate the need for fall protection. Eliminating the need for fall protection may be accomplished through the application of engineering controls (such as lowering the work surface or providing barriers, such as parapets, that prevent contact with the leading edge) or administrative controls (such as changing a process, sequence, or procedure so that workers do not need to work at heights). 

When it is not feasible to modify existing work surfaces higher than 6 feet, workers must use fall-protection systems when working in any situation that presents an exposure to a fall hazard. Fall-protection work controls include: guardrail systems, safety net systems, personal fall-arrest systems, and platform ladders. For fall-protection work-control requirements and exclusions, see Work Process E, Work Control Requirements.

30.3 Applicability

Berkeley Lab employees, construction contractors, non-construction subcontractors, vendors, and affiliates who work on any walking or working surface having an unprotected side or edge that is 4 feet for General Industry workers and 6 feet high or more for Construction workers must complete the appropriate fall hazard controls:

SJHA QUESTION:

30.4 Exceptions

30.5 Roles and Responsibilities

Role

Responsibilities

Authorized Person

  • Has a working understanding of Berkeley Lab's Fall Protection Program.
  • Has the knowledge and training necessary to properly wear and care for fall-protection equipment.
  • Follows all fall-protection hazard controls developed by a Competent Person.
  • Has successfully completed course EHS0276, Fall Protection (or the equivalent for subcontractors).
  • Is authorized by his or her supervisor through either an Employee Job Hazards Analysis or a Construction Job Hazards Analysis. Service contractors must be authorized by their supervisor through the Subcontractor Job Hazards Analysis (SJHA).
  • Retraining may be required due to changes in LBNL policy, the fall protection industry, or changes to regulatory requirements.
  • Fall Protection Refresher training course (EHS376) is required for all LBNL employees (working at heights greater-than or equal to 4ft.) every 3 years.

Competent Person

  • Is able to identify fall hazards of work tasks by conducting fall hazard surveys.
  • Stops or limits work at the hazard site.
  • Supervises selection and use of fall protection equipment.
  • Verifies equipment is compliant.
  • Verifies workers are trained.
  • Participates in investigations.
  • Conducts equipment inspections and removes damaged equipment from service.
  • Is authorized to take prompt corrective measures to eliminate or mitigate fall hazards.
  • Is knowledgeable in the application and use of fall-protection equipment.
  • Has completed a training program approved by the Berkeley Lab Environment, Health, Safety (EHS) Division's Fall Protection Program Administrator.

Qualified Person

At Berkeley Lab, the Qualified Person is the Facilities Division Structural Engineer and/or EHS Designated Qualified Person who:
  • Supervises the design, selection, installation, and inspection of fall protection equipment.
  • Participates in incident investigations.
  • Has specialized training (to fulfill requirements such as those for registered professional engineers), has extensive knowledge and experience in fall protection, and has successfully demonstrated an ability to solve problems related to fall protection.
  • Is responsible for designing specialized fall-protection systems and equipment, and for evaluating and approving anchorage points.

Program Administrator

At Berkeley Lab, the Fall Protection Program Administrator is assigned by the EHS Division and:
  • Is responsible for developing, implementing, maintaining, and evaluating the Fall Protection Program.
  • Provides guidance to all others involved with the program.
  • Establishes a procedure to identify fall hazards.
  • Develops fall protection and rescue procedures.
  • Ensures training is completed.
  • Participates in incident investigations.

User

A LBNL Authorized Person who:

  • Has completed EHS276
  • Is capable of donning a harness and inspecting fall gear before each use
  • Understands the provisions of the Fall Protection Matrix Permit and the Working Alone Policy.

 

30.6 Definitions

Term

Definition

Active Personal Fall Restraint System

An active personal fall restraint or personal fall-arrest system (PFAS) requires specialized fall-protection equipment that must be fitted to the user and worn to control fall hazards. The user is secured to an anchorage point at all times, even while moving from point to point.

Anchorage

An anchorage is a secure point of attachment for lifelines, lanyards, or deceleration devices. These points of attachment must be independent of any anchorage being used to support or suspend platforms, and must be capable of supporting the employee attached to the anchorage system.

Body Belt

A body belt is a strap with means both for securing it about the waist and for attaching it to a lanyard, lifeline, or deceleration device. Body belts must be at least one and five-eighths (1-5/8") inches wide. Body belts are only effective for fall restraint and work positioning, but must never be used for fall arrest.

Body Harness

A body harness are straps that may be secured about the user in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders and with means for attaching it to other components of a personal fall-arrest system.

Certified Anchorage

A certified anchorage is an anchorage for fall arrest, work positioning, restraint, or rescue systems that has been certified by a Qualified Person (a) to be capable of supporting forces that could be applied during a fall or (b) to have met the criteria per ANSI Z359.2-2007.

Compatible Components

All individual components of a fall-protection system must be manufacturer-approved as compatible components. Substitution with non-compatible component combinations or subsystems is not allowed unless authorized by the Berkeley Lab Fall Protection Program Administrator and approved by the Qualified Person (Berkeley Lab Structural Engineer).

Connector

A connector is a device that is used to couple (connect) a part of a personal fall-arrest system with a part of a positioning device system. It may be an independent component of the system (such as a carabineer), or an integral component of the system (such as a buckle or D-ring sewn into a body harness or a snap hook spliced with or sewn to a lanyard). These items must be made of corrosion-resistant material, and the edges must be smooth to prevent damage to other parts of the system.

Control Access Zone

A control access zone is an area with limited access where certain work may take place without the use of guardrail systems, a personal fall-arrest system, or a safety-net system. A control line (erected not less than 6 feet nor more than 25 feet from a leading edge) defines the control access zone. The control line is approximately parallel to and extends the entire length of the unprotected leading edge.

Deceleration Device

Any mechanism, such as a specially woven lanyard, a tearing or deforming lanyard, or an automatic self-retracting lanyard, that serves to dissipate a substantial amount of energy during a fall arrest or that otherwise limits the energy imposed on a user during fall arrest.

Fall Hazard Analysis

Fall hazard analysis is a general term used to describe a qualitative hazard analysis identifying fall hazards and respective controls.

Fall Restraint System

A fall restraint system prevents a person from falling from an unprotected edge or opening by using a body holding device, a connecting means of suitable length (such as a restraint lanyard), and an anchorage.

Free Fall Distance

The length from the fall arrest attachment point on a user's body belt or harness to the point the system applies a force to arrest the fall. This is known as the free fall distance and does not include deceleration distance or lanyard expansion.

Guardrail System

A guardrail system is a barrier erected to prevent employees from falling to lower levels.

Hole

A hole is a gap or void in a floor, roof, or other walking/working surface that is 2 inches or more in dimension.

Lanyard

A lanyard is a flexible line of rope, wire rope, or strap that generally has a connector at each end for connecting a body harness to a deceleration device, lifeline, or anchorage. For situations in which a fall arrest may occur, Berkeley Lab requires lanyards with built-in shock absorbing mechanisms for added force distribution. For fall restraint systems, lanyards without shock absorbers may be used.

Lifeline

A lifeline is a component consisting of a flexible line that is connected to an anchorage at one end to hang vertically or that is connected to anchorages at both ends to stretch horizontally, and that serves as a means for connecting other components of a personal fall-arrest system to anchorages.

Lifeline Systems (Vertical and Horizontal)

Overhead attachments that allow horizontal movement, such as beam trolleys and slide wires on cables or suspended vertical cables along uncaged equipment ladders are known as lifeline systems.

Noncertified Anchorage

A noncertified anchorage is a fall arrest anchorage that a Competent Person judges is capable of supporting the predetermined anchorage forces.

Non-Conforming Guardrails (NCG)

Non-conforming guardrails safeguards workers from nearing the edge. At 15 feet from the edge or hole (in the case of a hole, measured from the nearest edge of the hole), a warning line system, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge.

Passive Fall Protection System (PFPS)

A PFPS is used to control fall hazards by means other than wearing personal protective equipment (PPE). Examples are guardrails, safety nets, and warning line system.

Personal Fall Arrest System (PFAS)

A PFAS is used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a full-body harness, and a shock absorbing connecting device that may include a lanyard, deceleration device, lifeline, or a suitable combination of these. Body belts must not be used as part of a personal fall-arrest system.

Personal Fall Protection System (PFPS)

A PFPS is any dynamic system used to protect an employee from fall injury. It could be a personal fall-arrest system, a positioning device system, a lifeline system, or a retrieval system.

Positioning Device System

A positioning device system holds a worker in place while allowing a hands-free work environment at heights or that restricts the worker's movement to avoid reaching a location where a fall hazard exists. A typical positioning device system consists of an anchorage, a body support with either a full-body harness or a body belt, and a connecting device (positioning lanyard). Because these systems are not designed for fall arrest, a backup fall-arrest system should be used.

Retrieval System

A retrieval system is used primarily when work is being done in a confined space, such as a tank or a manhole, and may require retrieval from above in an emergency. A retrieval system typically consists of an anchorage and anchorage connector, such as a tripod, a full-body harness, and a lifeline/retrieval unit.

Rope Grab

A rope grab is a deceleration device that travels on a lifeline and, by friction, automatically engages the lifeline and locks to arrest the fall of a user.

Self-retracting Lifeline

 

Self-retracting Lifeline-LE Energy Absorber
LE (Leading Edge)

 

Suspension Trauma

A self-retracting lifeline is a deceleration device containing a drum-wound line that can be slowly extracted from or retracted onto the drum under slight tension during normal employee movement, and that, after the onset of a fall, automatically locks the drum and arrests the fall.
A self-retracting lifeline-LE energy absorber is a self-retracting lanyard tested for horizontal use and falls over a steel edge without burrs. As a result, the device may be used in situations where a fall may occur over similar edges, such as found on steel shapes or metal sheeting.

 

Suspension Trauma, also known as, Harness Hang Syndrome (HHS), or Orthostatic Intolerance, is an effect which occurs when the human body is held upright without any movement for a period of time. If the person is strapped into a harness or tied to an upright object they will eventually suffer the central ischemic response (commonly known as fainting). If one faints but remains vertical, one risks death due to one's brain not receiving the oxygen it requires.  According to SHIB 234-2004, unconsciousness is followed by death in less-than 30 minutes.                                                                 
                     

User

A person at Berkeley Lab who is currently trained in fall protection, has demonstrated appropriate skills in using fall-protection equipment, and has been approved by his/her supervisor to take part in activities that may involve fall hazards.

Warning Line System

An edge-proximity warning line system is used when working on a work surface higher than 6 feet and having an unprotected edge. The warning line physically denotes a 15-foot boundary (6-foot boundary for roofers), inside of which workers can perform tasks without additional fall protection measures.

Work Surface

Work surfaces include: leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 2:1 (horizontal to vertical) hillsides, roofs, and surfaces with open holes or skylights.


30.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Fall Protection Equipment Procurement
Work Process C. Authorization and Training
Work Process D. Hazard Assessment
Work Process E. Work Control Requirements
Work Process F. Fall Protection Equipment
Work Process G. Passive Fall Protection Systems
Work Process H. Active Fall Protection Systems
Work Process I. Hazards Requiring Evaluation for Fall Protection
Work Process J. Off-Site Fall Protection
Work Process K. Covers
Work Process L. Protection from Falling Objects
Work Process M. Walking Working Surfaces
Work Process L. Protection from Falling Objects
Work Process N. Leading Edge Work
Work Process O. Hoist Areas
Work Process P. Working Near Holes
Work Process Q. Formwork and Reinforcing Steel
Work Process R. Ramps, Runways, and Walkways
Work Process S. Working Near Excavations
Work Process T. Working Near Dangerous Equipment
Work Process U. Overhead Bricklaying and Related Work
Work Process V. Low Sloped Roofs
Work Process W. Steep Sloped Roofs
Work Process X. Precast Concrete Erection
Work Process Y. Residential Construction
Work Process Z. Wall Openings

Work Process A. General Requirements

  1. Written Fall Protection Permit.  A Written Fall Protection Permit is required for any task requiring fall protection. Table A-1 below provides a matrix of required Written Fall Protection permits and work authorizations.


    Worker Category

    Required Fall Protection Authorization

    Who Completes

    Who Approves

    PUB-3000 Reference

    Berkeley Lab employee: Facilities Division personnel

    Fall Protection Matrix Permit

    Berkeley Lab Fall Protection Competent Person

    Supervisor

    This Work Process

    Berkeley Lab employee: researcher, PI, others

    Fall Protection Matrix Permit

    Berkeley Lab Fall Protection Competent Person

    Supervisor

    This Work Process

    Construction contractor
    (CFHA)

    Construction Fall Hazard Analysis  or Fall Protection Matrix Permit

    Construction Contractor, Fall Protection Competent Person

    Facilities Division responsible Project Manager

    This Work Process

    Directly supervised non-construction subcontractors, vendors, and affiliates

    Fall Protection Matrix Permit

    Berkeley Lab Fall Protection Competent Person

    Berkeley Lab supervisor responsible for the work activity

    This Work Process

    Not directly supervised non-construction subcontractors, vendors, and affiliates

    sJHA Form (Subcontractor Job Hazards Analysis and Work Authorization Form)

    Subcontractor, vendor, or affiliate who is a Competent Person

    Berkeley Lab Requisitioner

    Chapter 31
    This Work Process

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

     

    Table A-1. Matrix of Required Written Fall Protection Permits


  2. Fall Protection Rescue Plan



    How to Complete the Berkeley Lab Fall Protection

    Step Two: Fall Hazard Controls





     

 

 

The LBNL Fall Protection Permit Matrix

 

Fall Matrix Details

Click here to download a PDF of the Fall Protection Matrix/Permit.


3. Fall Hazard Danger Signs

Work Process B. Fall Protection Equipment Procurement

  1. Identifying Required Fall Protection Equipment
    1. Personal fall-protection systems (PFPSs) consist of three components:
      1. An anchorage commonly referred to as a tie-off
      2. Body support, usually a full-body harness
      3. A connecting device such as a shock-absorbing lanyard
    2. Individually, these components will not provide protection from a fall. However, when used properly in conjunction with each other, they form a personal fall-arrest system (PFAS), an important element of the overall Fall Protection Program.

    3. Five functional categories of PPE for fall protection are available:
      1. Fall-arrest systems
      2. Positioning/restraint systems
      3. Suspension systems
      4. Retrieval systems
      5.  Passive systems e.g. warning lines, non-conforming guardrails, CAZ zones, and Safety monitors.  Passive fall protection systems do not provide a secondary fall protection system, they are designed to warn and keep workers away from fall hazards, see Appendix 3 for Fall Protection Safety Monitor OJT Training Checklist, in conjunction with Appendix 4, the LBNL Active Fall Protection Infeasibility Plan.
    1. Only a fall-arrest system will protect a worker who has fallen from elevation.
    2. The Competent Person must ensure that an Authorized Person who uses fall-protection equipment is provided with appropriate equipment that fits properly. The specific type of fall protection required is determined by the Competent Person.
    3. Usage of horizontal life-lines and SRL-LE's require approval by the LBNL Qualified Fall Protection Engineer.
  2. Obtaining Fall Protection Equipment. Berkeley Lab organizations purchase their own personal fall arrest equipment. The Fall Protection Program administration assists these organizations in selecting the right equipment. An adequate supply of regularly used harnesses, lanyards, anchorage point connectors, and other equipment in appropriate sizes should be available near the work area. PFAS equipment is a controlled item for procurement purposes, and procurement personnel must ensure that the EHS Division approves all purchases.

 Flowchart B-1. LBNL Fall Protection Equipment and Inventory Processes


Work Process C. Authorization and Training

  1. Authorization. An approved Fall Protection Matrix Permit is required for any task requiring fall protection. See Written Fall Protection Matrix  of Work Process A, General Requirements.
  2. Fall Protection Training Requirements. The table below lists required training for Authorized Persons (Berkeley Lab workers, including employees, affiliates, and directly supervised subcontractors):

Who

Requirement

Authorized Person

  • Only trained Authorized Persons may use fall protection equipment.
  • Successfully complete Berkeley Lab training course EHS0276, Fall Protection.
  • Recognize fall hazards.
  • Follow specific procedures to minimize these hazards.
  • Properly select, use, and maintain the equipment.
  • Be authorized by their supervisor or work leader.
  • Successfully complete EHS0376, Fall Protection Refresher Training course every 3 years.

Competent Persons

Must be qualified to:

  • Identify the fall hazards of work tasks.
  • Conduct fall hazard surveys.
  • Stop or limit work at the hazardous site.
  • Supervise selection and use of fall protection equipment.
  • Verify that equipment is compliant and workers are trained.
  • Participate in investigations.
  • Conduct equipment inspections.
  • Remove damaged equipment from service.
  • Must complete EHS377 Fall Protection Competent Person Training or equivalent.
  • Must complete EHS378 Fall Protection Competent Person Refresher every 3 years and/or complete certification maintenance as determined appropriate by the Fall Protection Program Administrator.
  • The Fall Protection Competent Person Program is administered by the Fall Protection Program Administrator.
  • Off-Site Users must complete EHS375 Fall Protection Competent Person for Researchers.
  • Write Fall Matrix Permit on hard copies and/or electronically on I-pads.
  • Record Fall Matrix Permit into the Smart Sheet data base.

Subcontractors Using the SJHA System

All subcontractors are required to provide training documentation for each worker who might be exposed to a fall hazard. Training documents must be provided prior to work and must include a statement documented "Certification of Training".

Work Process D. Hazard Assessment

  1. WPC based hazard analysis and Work Planning Controls. All Berkeley Lab employees are required to perform work according to their approved activities in the Work Planning Control Activity Manager (WPC). The Work Planning Control Activity Manager identifies the tasks, hazards, and controls of a worker's normal work assignments performed on a regular basis. If the Work Planning Control Activity Manager identifies working at heights as a normal job assignment, fall protection training is required.
  2. Scaffolding
    1. The exposure hazard during erection and dismantling of a scaffold is many times greater than the exposure while working on a scaffold. LBNL requires the Competent Person develop a Written Construction Fall Hazard Analysis (CFHA) that meets the OSHA standards. The written CFHA must be submitted for approval by the Berkeley Lab Construction Project Manager for review prior to commencing the operation.
    2. The employer (i.e., LBNL or the subcontractors) must provide safe means of access for each employee erecting or dismantling a scaffold where the provision of safe access is feasible and does not create a greater hazard. The employer must have a Competent Person determine whether it is feasible or would pose a greater hazard to provide and have employees use a safe means of access. This determination will be based on site conditions and the type of scaffold being erected or dismantled. 
  3. Steel Erection
    1. Steel erection is a high fall hazard activity. Written and verbal Plans for steel erection are required prior to commencement of work, at ground level. Coordinate with the fabricator for the attachment of anchorages and cables for the majority of the erection sequence. Written and verbal plan of all routes of travel must occur before the start of work. Use quick-release methods for the release of rigging when possible.
    2. Free climbing up or down columns is prohibited. Walking on beams that have a top flange of less than a 6-inch width is also prohibited.
    3. Installation or modification of decking material is the most dangerous phase of steel erection. A Controlled Decking Zone must be established and all affected workers must be trained. Perimeter cables must be erected as soon as decking is installed.
  4. Tree Trimming
    1. Landscaping personnel at Berkeley Lab must use fall restraint systems when performing elevated tree work from aerial lifts. Working at heights is also done from ladders, and workers must conform to PUB-3000, Chapter 35 Work Processes A-H
    2. A professional tree service must complete a detailed JHA (see Chapter32). The JHA must be submitted to a Berkeley Lab Construction Safety Engineer (CSE) for review and approval by the Berkeley Lab supervisor contracting with the professional tree service prior to the start of work.
  5. Roofing Installation and Repair
    1. Roofers must:
      1. Complete a JHA (see JHA for Roofers). The JHA is to be submitted to the Berkeley Lab EHS Division Construction Safety Specialist (who is a Competent Person) for the supervisor's review and approval prior to the start of work.
      2. Have specified training.
      3. Always set up a warning line system at least 6 feet back from the edge on roofs greater-than 50 feet in width.
      4. Use an approved Safety Monitoring System approved by EHS Managed Fall Protection Program Manager on roofs less-than 50ft. in width.
    2. Roofers may use a monitor system instead of fall protection when working outside the warning line system.
    3.  Roofing Installation and Repair:  The LBNL Roofers may utilize an Emergency Fall Protection Permit during heavy periods of rain to expedite trouble-shooting and repair of multiple leaking roofs.  Passive or Active fall protection procedure still apply when the Emergency Fall Protection Permit has been activated.
    4. Non-roofers Performing Work on Roofs: Non-roofers performing work on roofs must complete a Fall Protection Matrix Permit to help evaluate the hazards of the job and select the most appropriate hazard control. If a warning line is selected as the appropriate work control, the warning line system must be set up 15 feet from the edge of the roof in compliance with Federal OSHA Interpretation of November 15, 2002. This document states "OSHA has determined that 15 feet is sufficient distance from an edge or hole to be expected to prevent workers from unintentionally approaching the edge and would not place the worker in immediate risk of falling off the edge." (For more information, see Section 30.7, References, in this chapter). Note: OSHA interpretations are enforceable as standards, and Berkeley Lab is required to follow OSHA interpretations.
  6. Fixed Ladders
    1. Cages or wells must be provided on ladders of more than 24 feet to a maximum unbroken length of 30 feet. If cages are not feasible, then ladder safety devices may be used on ladders over 24 feet in unbroken length in lieu of cage protection. No landing platform is required in these cases. All ladder safety devices — such as those that incorporate life belts, friction brakes, and sliding attachments — must meet the design requirements of the ladders that they support.
    2. All ladders and ladder safety devices must be maintained in a safe condition and be inspected at 6-month intervals or less, with shorter intervals determined by use and exposure. Inspection records must be maintained by the Facilities Division.
  7. Maintenance at Elevated Locations. Maintenance personnel are often faced with repairs and service of roof-mounted or unguarded platform-mounted equipment. All fall protection requirements stated in this document are required for maintenance personnel, including the specified training and the use and care of equipment. In lieu of using personal fall-arrest systems, other systems are available for the protection of workers, at the discretion of the Competent Person, including: temporary guardrails, safety nets, fall restraints, warning line systems, controlled access zones, and fall protection plans, as discussed in this document. Contact your EHS Fall Protection SME for specific information on fall protection requirements.
  8. Confined Space Considerations. In most confined space situations, the use of harnesses are for rescue and extraction purposes. However, due to the almost unlimited configurations of confined spaces, normal fall protection may also be considered.
  9. Exceptions. These exceptions are applicable only after careful evaluation has determined that fall protection cannot be used.
    1. Provisions do not apply when employees are conducting:
      1. An inspection (no tools or papers)
      2. An investigation
      3. An assessment of workplace conditions either prior to the start of work or after all work has been completed
    2. Work can be done on a flat or low-sloped roof without fall protection if it is performed at least 15 feet from an unprotected edge (NCG/Non-conforming Guardrails are Warning lines with a 15ft. setback) and a warning line has been established.
    3. All workers using a Warning-line, Controlled Access Zone, Safety Monitor, Non-Conforming Guardrail, or Control Zone system must successfully complete FALL PROTECTION SAFETY MONITOR ON-THE-JOB TRAINING

Work Process E. Work Control Requirements

  1. Fall Protection Work Control Requirements
    1. The height triggers for fall protection are 4 feet for General Industry workers, and 6 feet for Construction workers. See the LBNL Trigger Height in Appendix 4 of this program.
    2. Fall protection work controls are required under the following conditions:
      1. Any work task on a walking/working surface with an unprotected side or edge that is above the height limitation.
      2. Any work task on an aerial lift (including a scissors lift only if an engineered anchor point is provided by the manufacturer) or when working above the protection system near floor openings, and unprotected perimeters while operating the aerial lift.
      3. Any work task performed by steel erectors and sheet metal installers at heights greater than 6 feet.
      4. Any work on portable ladders when working above the protection system at floor openings, and unprotected perimeters.
      5. Any use of a portable ladder when working at a height greater than, or equal to 6 feet and below the third rung (from the top of the ladder), when the user cannot maintain three-point contact (consisting of two feet and one hand) at all times. See Elevated Work — Aerial Work Platforms, Ladders, and Scaffolds.
  2. Exceptions. Fall protection work controls are not required under the following conditions:
    1. For non-roofers only. Work on a flat or low-sloped roof (slope of less than 4 in 12) when all of the following conditions are met:
      1. All work is conducted at least 15 feet from any unprotected edge.
      2. A warning line is used to denote the 15-foot distance.
      3. No work activities take place between the warning line and the unprotected edge.
      4. Workers follow the work rule of not going past the warning line.
      5. All workers have successfully completed LBNL Safety Monitor Training.
    2. For Roofers
      1. Work on scissor lifts if an engineered anchor point is not provided by the manufacturer.
      2. During scaffold erection and dismantling, when all of the following conditions are met:
        1. The designated Competent Person overseeing the operation has determined that active fall protection is infeasible.
        2. The Competent Person has drafted a Written Fall Protection Plan meets the Cal/OSHA requirements 8 CCR 1635.1-1667.
        3. The Competent Person has submitted the Written Fall Protection Plan to Berkeley Lab Project Management for review and approval prior to commencing the operation.
      3. Climbing up and down ladders.
      4. Work from ladders above 6 feet and below the third rung when the worker can maintain three-point contact (consisting of two feet and one hand) at all times.
      5. Work from platform ladders when the worker can demonstrate that work can be done safely inside the rails of the ladder.
    3. Fall Protection Plan. This option is available only to employees engaged in:

      1. Leading edge work, precast concrete erection work, or residential construction work.
      2. When the employer can demonstrate that it is infeasible or creates a greater hazard to use active fall protection systems.
      3. The employer shall develop and implement a fall protection plan, which meet the requirement of the (link to Appendix 5) LBNL Active Fall Protection Infeasibility Plan.
      4. The LBNL Active Fall Protection Infeasibility Plan must be reviewed and signed by the Fall Protection Program Manager, the Fall Protection Qualified Person, and the Responsible Individual for the project.
    4. All work can be performed from the platform or podium ladder under the following conditions:
      1. The worker(s) have completed an approved ladder training course.
      2. The ladder has been inspected before use by the worker(s).
      3. There are no additional hazards that affect the stability of the ladder, e.g. slopes, or unprotected edges (ladders near guard railed areas), or uneven surfaces, and or unprotected machinery in which a worker could be injured by during a fall. 
      4. The worker can maintain stability as work is performed inside the safety envelope of the platform or podium ladder, e.g. by not over extending the worker's center of gravity from the ladder's center of gravity.  
  3. Work Control Processes. Berkeley Lab's Fall Protection Program is implemented through three work-control processes applicable to the three categories of workers who may perform work tasks requiring fall protection. These three worker categories are: (a) Berkeley Lab employees (See Work Control Process for Berkeley Lab EmployeesWork Control Process for Berkeley Lab Facilities Division Employees, and Work Control Process for Other Employees); (b) construction contractors (See Fall Protection Work Control Process for Construction Contractors);  and (c) non-construction subcontractors, vendors, and affiliates performing hands-on work (See Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, and Affiliates).
  4. Work Control Process for Berkeley Lab Employees
    1. The fall-protection work-control process for Berkeley Lab employees performing work tasks at heights is managed through the Activity Manager Work Planning Control (WPC) process and the Maximo® work-request system, as illustrated in Flowchart E-1, below.
    2. Berkeley Lab employees who perform work at heights requiring fall protection work controls, which can be grouped into two broad categories:
      1. Facilities Division maintenance or construction employees
      2. Other employees, including researchers
  5. Work Control Process for Berkeley Lab Facilities Division Employees
    1. Fall-protection work controls for Berkeley Lab Facilities Division employees are managed through the Maximo® work-request system and consist of:
      1. Identifying work activities in the Activity Manager to indicate job assignments that require working at heights.
      2. Determining that such work can be accomplished as a Work Planning Control, with the subsequent completion of the work by an employee having an appropriate WPC.
      3. Determining that such WPC activities developed in the Activity Manager, approve employee to acquire a Fall Protection Matrix Permit or perform work through the application of an Engineered Fall Protection Plan (e.g., for roofing and HVAC work) as applicable.
      4.  Berkeley Lab employee must use fall restraint systems (with adjustable 6ft. lanyards) when performing elevated tree work from aerial lifts, or performing work on hillsides using rope-grab systems (RGS) or Safety Monitor System for Hillside Work  when applicable.
    2. The Fall Protection Matrix Permit is developed by a Berkeley Lab Fall Protection Program Competent Person and approved by the employee's supervisor or work lead.
    3. When required, an Engineered Fall Protection Plan is developed by the Qualified Person (Berkeley Lab Structural Engineer) and implemented by a Berkeley Lab Fall Protection Program Competent Person.
  6. Work Control Process for Other Employees. Fall protection work controls for other employees are managed through the Fall Protection Matrix Permit process and consist of:
    1. Using the Activity Manager WPC process to identify job assignments that require working at heights.
    2. Following the WPC by completing a Fall Protection Matrix Permit. The Fall Protection Matrix Permit is developed and implemented by a Berkeley Lab Fall Protection Competent Person and approved by the employee's supervisor or work lead.
  7. Fall Protection Work Control Process for Construction Contractors
    1. The fall protection work control process for construction contractors performing work tasks at heights is managed through the Berkeley Lab contractor bid, selection, and Construction Fall Hazard Analysis (CFHA) approval process illustrated in Flowchart E-2, below.
    2. When a construction project requires working at heights, Berkeley Lab notifies project bidders of such tasks during the bid job walk. Requirements for fall protection work controls are then identified through the construction package documents and the Construction Safety Checklist. A Written Construction Fall Hazard Analysis (CFHA)is then developed by the contractor and submitted to the EHS Construction Safety Engineer who is also a Berkeley Lab Fall Protection Program Competent Person. Upon review and approval of the Written Construction Fall Hazard Analysis (CFHA), the contractor is issued a notice to proceed, and the Written Construction Fall Hazard Analysis (CFHA)is implemented by the contractor Competent Person.
  8. Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, and Affiliates. The fall protection work control process for non-construction subcontractors, vendors, or affiliates performing work tasks at heights is managed through the Work Control Process for Berkeley Lab Non-construction Subcontractors, Vendors, or Affiliates described in Flowchart E-3, below.
    1. While working at Berkeley Lab, non-construction subcontractors, vendors, or affiliates are either under the direct supervision of Laboratory personnel or work independently of such supervision.
    2. Fall protection work controls for non-construction subcontractors, vendors, or affiliates who are under the direct supervision of Lab personnel are managed through the Fall Protection Matrix process, which consists of:
      1. Identifying job assignments, through the Individual Baseline JHA process, that require working at heights.
      2. Developing a Task-Based JHA through completion of a Fall Protection Matrix. The Fall Protection Matrix is developed and implemented by a Berkeley Lab Fall Protection Program Competent Person.
    3. Fall protection work controls for non-construction subcontractors, vendors, or affiliates who are not under the direct supervision of Lab personnel are managed through the Subcontractor Job Hazards Analysis and Work Authorization (SJHA) Form, which requires:
      1. Identifying job assignments that require working at heights by the requisitioner.
      2. Submitting the blank SJHA Form by the Berkeley Lab Buyer to the subcontractor or vendor.
      3. Completing the SJHA Form by the requisitioner.
      4. Determining low- or high-hazard tasks by the requisitioner.
      5. Review and approval of the SJHA Form by:
        1. The SME and Program Manager if the work involves high hazard tasks.
        2. The SJHA Form by the Requestor, DSA and Program Manager if the work involves low-hazard tasks.

Flowchart E-1. Fall Protection Work Control Process for Berkeley Lab Employees


Flowchart E-2. Fall Protection Work Control Process for Construction Subcontractors


Flowchart E-3. Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, or Affiliates
 

Work Process F. Fall Protection Equipment

  1. Control of Fall Protection Equipment: Any equipment found to be defective, damaged, or in need of maintenance must be immediately removed from use, marked as "UNUSABLE," and immediately destroyed or repaired if possible according to manufacturer's directions.
  2. Storage and Maintenance of Fall Protection Equipment: The Competent Person and Authorized Person must ensure that PFPS equipment is stored to avoid cutting, excessive bending, stress on components, excessive heat, and contact with water or chemicals. Maintenance, including cleaning, must be performed only as directed by the manufacturer.
  3. Inspection of Fall Protection Equipment: Two types of inspections, formal and pre-use, are required:
    1. Formal inspections are performed by a Competent Person. The Competent Person performing the formal inspection must inspect each piece of personal fall-arrest system (PFAS) equipment annually. The EHSS Occupational Safety Group maintains a PFAS equipment inventory that also serves as an inspection database. When equipment is inspected, a metal tag with the inspection expiration date is placed on equipment. Equipment should only be used if the inspection is current. The formal inspection procedure is specified below in Procedures for Formal Inspection of Fall Protection Equipment.
    2. Pre-use inspections. Prior to each use, users must inspect their own fall protection equipment for damage, wear, and other defects. CAUTION: Only the manufacturing company or parties with written authorization from the manufacturer may make repairs to the equipment.
  4. Procedures for Formal Inspection of Fall Protection Equipment: The formal inspection procedure is similar to the pre-use inspection. However, it differs in three important respects:
    1. It is performed by a Competent Person who is trained and authorized to perform a formal inspection for the user's organization.
      1. The equipment must be inspected by a Competent Person, other than the user, at least annually. The Competent Person should perform a methodical and thorough visual and tactile inspection by following the appropriate inspection procedure (see the paragraphs below in this section). If the equipment passes Formal Inspection, the Competent Person must attach an inspection tag to the equipment.
    2. It is more detailed and is methodically recorded in a Formal Inspection Log that is kept on file for future reference.
      1. Inspection recordkeeping is needed to trace detected defects to their causes. An inspection log must be kept, and inspection forms must be maintained for one year after the date of inspection. The Formal Inspection Log has been developed following the guidelines set forth by and in compliance with the manufacturer's instructions. (Click here to download an example of the Formal Inspection Log.)
    3. It results in final disposition of the equipment as either "acceptable" or as "not acceptable" followed be destruction of the product.
      1. Harness Inspection: Hold the harness by the back D-ring. Starting at the top of the harness, grasp one strap and run your hand along the entire length. While running your hand along the strap, bend the webbing over your index fingers. The resulting surface tension makes damaged fibers or cuts easier to see. Follow this procedure for all shoulder straps, back straps, leg straps, and the chest strap. Watch for frayed edges, broken fibers, pulled stitches, cuts, or chemical damage.
        1. D-Rings: Check D-rings and their metal or plastic wear pads (if any) for distortion, cracks, breaks, and rough or sharp edges. The D-ring bar should be at a 90-degree angle to the long axis of the belt and should pivot freely.
        2. Attachments of Buckles: Attachments of buckles and D-rings should be given special attention. Note any unusual wear, frayed or cut fibers, or distortion of the buckles or D-rings. Rivets should be tight and immovable with fingers. The body-side rivet base and outside rivet burr should be flat against the material. Bent rivets will fail under stress.
        3. Inspect for Frayed or Broken Strands: Broken webbing strands generally appear as tufts in the webbing surface. Any broken, cut, or burned stitches will be readily seen. See Table F-1 for detailed information on visual inspections for chemical, heat, and corrosive damage.
        4. Tongue or Billet: The tongue or billet of a belt or strap receives heavy wear from repeated buckling and unbuckling. Inspect for loose, distorted, or broken grommets. Belts and straps should not have additional punched holes.
        5. Buckle Tongues: Buckle tongues should be free of distortion in shape and motion. They should overlap the buckle frame and move freely back and forth in their sockets. The roller should turn freely on its frame. Check the roller for distortion or sharp edges.
        6. Friction and Mating Buckles: Inspect the buckle for distortion. The outer bars and center bars must be straight. Pay special attention to corners and attachment points of the center bar. Look for burrs and cracks.
        7. Lanyard Inspection: When inspecting lanyards, begin at one end and work to the opposite end. Slowly rotate the lanyard so that the entire circumference is checked. Spliced ends require particular attention.
        8. Hardware Inspection
          1. Snaps: Visually inspect the hook and eye for distortions, cracks, corrosion, or pitted surfaces. The keeper (latch) should seat into the nose without binding and should not be distorted or obstructed. The keeper spring should exert sufficient force to firmly close the keeper. Keeper locks must prevent the keeper from opening when the keeper lock is not depressed.
          2. Thimbles: The thimble must be firmly seated in the eye of the splice. The splice should have no loose or cut strands. The edges of the thimble must be free of sharp edges, distortion, or cracks.
          3. Steel Lanyard: While rotating the steel lanyard watch for cuts, frayed areas, or unusual wearing patterns on the wire. Broken strands will separate from the body of the lanyard. With a gloved hand, slide a piece of cotton, swabbing along the length of the lanyard. Cotton tufts will indicate the presence of broken wire strands.
          4. Web Lanyard: While bending the webbing over a pipe or mandrel, observe each side of the webbed lanyard. This will reveal any cuts or breaks. Examine the web for swelling, discoloration, cracks, and charring. These are signs of chemical or heat damage. Observe closely for any breaks in the stitching.
          5. Shock-Absorbing Lanyards: Shock-absorbing lanyards should be examined using the method described above for web lanyards. However, also look for the warning flag or signs of deployment. If the flag has been activated, remove the shock-absorbing lanyard from service.

            Table F-1. Examples of Lanyard Damage

            Type of Webbing

            Heat

            Chemical

            Molten Metal or Flame

            Paint and Solvents

            Nylon, Polyester (Dacron*), Dura- flex

            In excessive heat, nylon becomes brittle and has a shriveled brownish appearance. Fibers will break when flexed. Should not be used above 180°F.

            Change in color usually appearing as a brownish smear or smudge. Transverse cracks when belt is bent over a mandrel. Loss of elasticity in belt.

            Webbing strands fuse together. Hard shiny spots. Hard and brittle to the touch.

            Paint that penetrates and dries restricts movement of fibers. Drying agents and solvents in some paints will appear as chemical damage.

            Note: Lanyards made of nylon or polyester rope will show the same visual indications of damage as nylon webbing. *Du Pont trademark.

  5. Procedure for Pre-use Inspection of Fall Protection Equipment

Step 1: Inspect the labels to verify that they are present and legible. Check to be sure a Formal Inspection has been performed within 12 months. This can be indicated by colored tape on the item or inspection labels indicating the date inspected or date due. If the Formal Inspection has not been performed within 12 months or if any labels are missing or illegible, remove the equipment from use and mark it as "UNUSABLE" until a formal inspection is performed by a Competent Person.

Step 2: Inspect all webbing and stitching for cuts, fraying, pulled or broken threads, abrasion, excessive wear, altered or missing straps, burns, and heat or chemical exposures.

Step 3: Inspect all metallic parts (e.g., D-rings, oval rings, buckles, adjusters, and grommets) for deformation, fractures, cracks, corrosion, deep pitting, burrs, sharp edges, cuts, deep nicks, missing or loose parts, improper function, and evidence of excessive heat or chemical exposure.

Step 4: Inspect all plastic parts (e.g., strap collars, labels, tool belt support clips) for cut, broken, excessively worn, missing, and loose parts. Inspect for evidence of burns and excessive heat or chemical exposures.

Step 5: Inspect each component and subsystem of the complete system in accordance with the associated manufacturer's instructions.

CORRECTIVE ACTION: Defects, damage, excessive wear, and/or aging are generally not repairable. If detected, immediately remove the equipment from use, and mark it as "UNUSABLE" until destroyed. For final disposition, submit the equipment to a Competent Person who is authorized to perform a Formal Inspection.

Work Process G. Passive Fall Protection Systems

Using a passive fall-protection system (PFPS) indicates the fall hazard is controlled by means other than the wearing of personal protective equipment (PPE). Examples of a PFPS are: guardrails, safety nets, and warning lines.

All passive fall-protection systems require vigilance, whether through pre-work inspections, group instructions, or other means of communication.

  1. Guardrails
    1. The most common passive fall-protection system is a guardrail. The height of the top rail of a guardrail system must be 42 inches (plus or minus 3 inches) above the walking/working surface. When conditions warrant, the height may exceed a height of 45 inches if all other criteria are met.
    2. Mid-rails, screens, mesh, or intermediate vertical members must be installed midway between the top rail and the walking/working surface, unless a parapet wall of 21 inches or higher has been installed.
    3. Top rails must be a minimum of a 1/4-inch in diameter (preferably a 3/8-inch cable) or a suitable thickness to meet the strength and rigidity requirements. If wire rope is used, it must be flagged at 6-foot intervals with high-visibility material.
    4. Many roof activities, such as servicing HVAC units, HEPA filters, and fans, are done on a semiannual or as-needed basis. If the activity does not warrant the installation of a permanent guardrail, temporary guardrail systems are available from the Facilities Division Maintenance Department. Personal fall-arrest systems may also be used, but the walking/working area must be surveyed by a Competent Person, and approved anchorages must be designated either by a Competent Person or a Qualified Person.
  2. Safety Nets. Safety nets are an option in certain cases. For specific information, see the Work Smart Standard B106, OSHA 29 CFR 1926 Subpart M, Fall Protection.
  3. Warning Line Systems
    1. Roofers
      1. A warning line must be erected not less than 6 feet from the roof edge.
      2. No worker is allowed in the area between the warning line and the roof edge without active fall protection or a safety monitor (see Work Process H, Active Fall Protection Systems).
      3. The warning line must meet or exceed the requirements in 1926.502(f)(2), which requires that the warning line: (1) be constructed of rope, wire, or chain and flagged at intervals no greater than 6 feet; (2) be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches above the walking/working surface and its highest point is no more than 39 inches above the walking/working surface; (3) be capable of resisting a knock-over force of at least 16 pounds applied horizontally against the stanchion at 30 inches above the walking/working surface perpendicular to the warning line and in the direction of the floor, roof, or platform edge; (4) have a minimum tensile strength of 500 pounds; and (5) be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.
    2. Non-roofers
      1. The warning line must be erected not less than 15 feet from the roof edge.
      2. No employee is allowed in the area between the warning line and the roof edge without active fall protection. There are no exceptions.
      3. The warning line must meet or exceed the requirements in 1926.502(f)(2), which requires warning line (1) constructed of rope, wire, or chain and flagged at intervals no greater than 6 feet; (2) rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches above the walking/working surface and its highest point is no more than 39 inches above the walking/working surface; (3) capable of resisting a knock-over force of at least 16 pounds applied horizontally against the stanchion at 30 inches above the walking/working surface, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge; (4) having a minimum tensile strength of 500 pounds; and (5) attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.
    3. Hole Opening Covers
      1. The following must be covered: any gap or void 2 inches or more in its least dimension in a floor, roof, or other walking/working surface, and any gap or void in a wall or partition 30 inches or more in height and 18 inches or more in width through which a person may fall.
      2. Hole opening covers in roofs, floors, and other walking/working surfaces must be secured in place and capable of supporting the weight of any load that may be imposed at any one time. All hole opening covers must have "HOLE" or "COVER" clearly written on the cover to provide warning of the hazard.
      3. Temporary covers for roadway holes are to be steel street plates capable of supporting twice the axle weight of the heaviest vehicle expected to cross the cover.
    4. Ladder Wells/Cages. Design criteria for ladder wells and cages vary greatly depending on the type, height, and/or use of the ladder. For guidance on specific design criteria for ladder wells and cages, contact the EHSS Occupational Safety Group, or refer to 29 CFR 1910 Subpart D, Walking-Working Surfaces (1910.27).
    5. Safety Monitors
      1. A safety monitor is a trained and authorized worker who must be competent in recognizing fall hazards. A safety monitor's only job on a roof is to ensure that previously trained roofers are warned when moving too close (within 6 feet) to a dangerous edge. He or she must be positioned on the same level of all workers being monitored, and must be within vocal distance of them. Constant vigilance is required, because lateral and backward movement of 4 to 5 feet per second is not uncommon.
      2. Safety monitors are not permitted to work on roofs of a pitch greater than 4 in 12 or that have equipment that obstructs vision or has a noise level that prevents any worker from immediately hearing a verbal warning of danger. Duties of the safety monitor include:
        1. Warning the worker when it appears that the worker is unaware of a fall hazard or is acting in an unsafe manner.
        2. Remaining on the same walking/working surface and within sighting distance of the worker being monitored.
        3. Remaining close enough to communicate verbally with the worker.
        4. Having no other responsibilities other than serving as a safety monitor.
        5. Monitoring not more than six employees in a controlled area (area between the warning line and the roof edge).

Work Process H. Active Fall Protection Systems

An active fall-protection system or personal fall-arrest system (PFAS) requires the use of specialized fall protection equipment that must be fitted to the user and worn to control fall hazards. In other words, a user is secured to an anchorage point at all times, even while moving from point to point. Fall-protection systems and equipment are used for personnel protection only.

  1. Active Systems. Active systems may include the following:
    1. Positioning devices
    2. Lifeline systems (standard and self-retracting)
    3. Rope grabs
    4. Retrieval systems
    5. Full body harnesses
    6. Body belts (note: body belts are not to be used for fall arrest at Berkeley Lab)
    7. Connectors
    8. Lanyards
    9. Snap hooks
    10. Ladder safety devices
    11. Anchorages
  2. Fall Dynamics. The following elements combine to make a fall hazardous:
    1. Lanyard length
    2. Free-fall distance
    3. Shock absorption at impact
    4. Body weight
    5. Swing
    6. Suspension Trauma
      1. Lanyard Length. The lanyard length must be selected to allow freedom of movement to do the work, yet be short enough to minimize the fall distance. The maximum length of the lanyard and shock absorber combination is 6 feet. The minimum total vertical distance from the anchor point with a 6 foot lanyard is 18.5 feet, allowing a 3 foot safety factor.
      2. Free Fall Distance
        1. If the trigger height for fall protection is 6 feet above the walking/working surface, a 6 foot lanyard does not offer good protection if the anchor point of the lanyard is connected at head height. To be effective, the anchor point is required to be as high as practicably possible above the user's head without interfering with the work being done.
        2. The D-ring on the harness moves from the back at shoulder blade height to a position at the head when supporting full body weight. A 6-foot fall can result in forces exceeding 10 times body weight. A worker weighing 200 pounds can experience more than 2,000 pounds of dynamic force from the harness unless the user has a shock-absorbing lanyard. A 2,000 pound force is capable of causing heart damage, a severe internal injury, and possibly a fatal injury.
        3. Serious consideration must be given to the equipment being approved for each situation evaluated based on the total fall distance and impact forces that could be encountered. A good rule of thumb is to limit the free-fall to 2 feet whenever possible, by using a minimum lanyard length and/or raising the anchor point. Consider using self-retracting lanyards, some of which can activate within 1-2 feet.
        4. Use the following formula as a guide for Minimum Anchorage Point Height (MAPH):

          MAPH = (6′ + L) - H + D + S + C

          6′ = Harness D-ring height

          L = Lanyard length (typically is 6 feet)

          H = Anchorage point height (positive if below D-ring)

          D = Deceleration or shock absorbing distance (typically is 3.5 feet)

          S = Harness stretch (typically 1 foot)

          C = Min. required clearance to lower level (3 feet)


      3. Shock Absorption at Impact. Even a relatively short free-fall distance of 6 feet on a solid lanyard, or cable can create serious impact problems, as described above. Shock absorption devices stretch by more than 3 feet 6 inches depending on the type of unit. The use of shock-absorbing lanyards is required at Berkeley Lab.
      4. Body Weight. Body weight adds to the impact load on the body of a worker and on the fall-arrest system. How the harness is worn and the tightness of the straps, if adjusted for comfort, can create harmful stress and abrasions on the body during a fall arrest. The correct size harness must be worn and all harness straps are to be adjusted for a snug fit.
      5. Swing. If a fall is not a direct drop, pendulum action will come into play. The worker may be relatively uninjured from the fall due to the fall-protection system, but then could swing into another object and become impaled or forcibly strike a solid object. Use the shortest lanyard practical for the task to minimize swing effect.
      6. Suspension Trauma
        1. A person suspended immobile in a harness may experience suspension trauma leading to death in as little as 5 minutes. Whenever a worker is suspended for longer than 5 minutes in an upright posture with legs relaxed straight beneath the body, gravity pulls blood into the lower legs, which have a very large storage capacity. Enough blood eventually accumulates so that return blood flow to the right chamber of the heart is reduced and the heart's output begins to fall. The harness leg straps compound the problem by restricting the flow of blood up to the heart. To minimize the effects of Suspension Trauma, the worker should be trained to try to move the legs in the harness, push against any object, and, if possible, raise the legs to a horizontal position.
        2. For prolonged suspension, a harness with a seat rather than straps alone should be used to help position the upper legs (and lower legs if conscious) horizontally.
        3. Workers using fall arrest systems are required to be fitted with trauma suspension straps as part of a self-rescue system.  Use of trauma suspension straps can increase a fallen worker's survival time from 15 minutes to more than an hour if the fallen worker is alert.
  3. Work Planning. A written permit (Fall Protection Matrix Permit or Construction Fall Hazard Analysis) is required when a Personal Fall Protection System (PFPS) is to be used. A Competent Person selects the appropriate PFPS equipment for the fall scenario and ensures that it properly fits each user. General work planning guidelines are as follows and are carried out by the Competent Person:
    1. Determine whether an engineered fall-protection system is required. In collaboration with the Qualified Person (Berkeley Lab Structural Engineer), ensure it is satisfactory (for example, determine whether guardrails or cages are necessary). If an engineered fall-protection system is not required, list each fall scenario that workers will be exposed to.
    2. For each fall scenario, analyze the fall hazards and determine the PFPS components that will be needed.
    3. Maintain and inspect the PFPS components needed to ensure that equipment is available when needed.
    4. Determine the worker's vertical and horizontal movement requirements in each scenario.
    5. Plan the anchoring system. Identify and evaluate the strength of all anchor points.
    6. Select and obtain the appropriate equipment (e.g., harness, lanyard, or self-retracting lifeline).
    7. Confirm training status of all users. The requirements are Berkeley Lab fall protection training (EHS 276) and written training documentation by the subcontractor.
    8. Review the planned work with workers to ensure their understanding of the requirements and approach to the job.
    9. Review the planned method of self rescue, anticipated time of hanging in the harness, and personal actions to minimize Suspension Trauma.
  4. Limits on Use of Personal Fall Protection Systems Equipment
    1. Competent Persons must ensure that PFPS equipment is used only for worker safeguarding. This safeguarding includes harnesses that combine the features of a full-body harness and a body belt.
    2. Competent Persons and/or Supervisors must ensure that any device that has been subjected to a fall load (i.e., a device that has protected a worker in an actual fall) has all components immediately removed from service, destroyed, and not used again for worker safeguarding.
  5. Active Fall Protection System Components

    Note: All components must be from one manufacturer unless the Qualified Person (Berkeley Lab Structural Engineer) determines otherwise in writing with supporting calculations.

    1. Full Body Harness
      1. The full body harness has been designed to distribute arresting forces over the buttocks and shoulders. Typically, newer harnesses can be worn by men and women alike. The chest strap serves a retainer function and should be worn high on the chest, but under the collarbone.
      2. D-ring locations may vary, so make sure the harness is the correct one for your task. Most harnesses have the D-ring on the upper back, but for ladder climbing systems the D-ring is located on the chest or rib area. D-rings on the hips are for work positioning and on the shoulders are for retrieval. Long hair may be caught in the D-ring, so the hair must be worn under the hardhat.
      3. The most common misuse of the harness involves failure to connect the leg straps. This is also the most dangerous practice, as slipping through and out of the harness when the actual arresting action takes place is a very real possibility if the leg straps are not connected. The common practice of having loose leg straps is also dangerous, as it can lead to severe contusions to the upper thighs and groin area.
      4. Note: Body belts are not to be used for fall arrest at Berkeley Lab.
      5. Body belts are NOT fall arrest devices! Body belts, waist belts, or safety belts, as they are sometimes called, are only to be used as work positioning supports, that is, when the worker is standing, leaning out, and needs support to hold a position—thus the term "work positioning."
      6. A single D-ring on the body belt should be positioned in the middle of the waist in front of the body. More commonly, the body belt will have two D-rings to be connected to two lanyards, one from each side, similar to that used for a window washer. Body belts have either a tongue buckle or a friction buckle, both, if worn properly, will support the weight of a worker.
    2. Connectors. Two shock-absorbing lanyards, at least one of which is always attached to a secure anchorage, are required for foot travel beyond the limits of a single lanyard when exposed to a fall greater than 6 feet. The use of a positioning device and an additional shock-absorbing lanyard while climbing is also acceptable.
    3. Lanyards
      1. A lanyard is a short, flexible rope or strap webbing that connects a worker's body harness to an anchorage point or the grabbing device on a lifeline. There is no limit to the length of a lanyard, but lengths of 2, 4 and 6 feet are common to help limit falling beyond a maximum free-fall of 6 feet. The lanyard should be as short as possible, without restricting movement. An adjustable lanyard provides workers with the flexibility to adjust the length of their lanyard to suit any fall arrest application. The design of the adjustable lanyard must allow the user to easily identify the length of the adjustment at a glance through a "tape measure" feature or similar design.
      2. The minimum attachment height should be at or above the D-ring height to ensure the free-fall distance will be less than 6 feet.
      3. Unlike basic cable, web, or rope lanyards, shock-absorbing lanyards not only significantly reduce arresting forces on the body, but also provide a means to determine in-service use. Obvious deformation makes it evident that they have been stressed. All lanyards are to be destroyed and replaced after having been shock loaded.
    4. Y-Lanyards
      1. A Y-lanyard is two or three lanyards, generally shock-absorption types, connected to a center ring or snap hook that allows workers to move horizontally from one anchorage point to another.
      2. The user must be trained in the use of the Y-lanyard and constantly be aware of the location of both lanyards. There have been several instances of the lanyards becoming entangled or actually causing a fall when they have snagged on an obstruction and thrown a worker off balance.
      3. Do not connect the lanyard to an unauthorized anchorage as travel progresses. Consider a horizontal lifeline system as an alternate solution.
    5. Snap Hooks
      1. Snap hooks must be of a self-closing and self-locking type. The self-locking gate meets the 3600-pound breakage strength requirements and must not be directly connected to: webbing, rope, or wire rope; horizontal lifelines (a separate ring or carabineer should ride on the horizontal lifeline); or to any object whose shape or dimensions are incompatible with the snap hook such that unintentional disengagement (e.g., roll-out) could occur. A snap hook must not be connected directly to another snap hook.
      2. Snap hooks may only be used with compatible components. Snap hooks are not to be attached directly to cables, ropes, chains, or the lanyard itself—as in looping the lanyard over a pipe and hooking the snap hook on the lanyard—unless approved by the manufacturer. Only approved anchor points must be used to connect to the lanyard snap hook.
    6. Retractable Lifelines. Self-retracting Lanyards (Locking): Self-retracting lanyards with locking devices are designed to arrest free falls within inches by eliminating the slack inherent in fixed-length lanyards. The Competent Person will determine the free fall distance. One main consideration is that for self-retracting lanyards to be effective overhead installation is required. A major advantage is that arresting forces can be kept to the 650-pound range, almost one-third of that associated with a 6-foot free fall. This system is especially attractive when working near the edge on roofs and when frequent ladder climbs are required.
    7. Lifeline Systems
      1. Lifeline systems provide a means for connecting components of a personal fall-arrest system to an anchorage. They consist of either:
        1. A flexible line to hang vertically (vertical lifeline) for connecting to an anchorage at one end
        2. A flexible line to stretch horizontally (horizontal lifeline) for connecting to anchorages at both ends.
      2. For all lifeline systems, vertical or horizontal, a Qualified Person must approve the anchorages and the selection of the type of lifeline to ensure proper design of the system.
        1. Vertical Lifeline Systems
          1. A vertical lifeline allows the worker to move up and down the entire height of the line rather than having to disconnect and find a new tie-off point on the tower or ladder being climbed. Workers connect to the lifeline by a "rope grab" deceleration device that travels along with the worker as he or she moves higher or lower.
          2. The diameter and composition of the line may vary, but it must have a 5,000-pound breaking strength. Although polypropylene rope is a popular tool, its stretch factor must be taken into account.
          3. The rope grab is a deceleration device that travels on a lifeline and automatically, by friction, engages and locks the lifeline to arrest the fall of the user. A rope grab usually employs the principle of inertial locking, cam/level locking, or both. Rope grabs can be either manual or mobile and must be suited to the lifeline fabric. Squeezing and releasing a locking cam operates the manual grabs. The grab should be located above shoulder height and a short (3-foot) lanyard is recommended to prevent exceeding the 6-foot free fall requirement.
        2. Ladder Safety Devices. Ladder safety devices are similar to vertical lifeline systems with the exception that they attach to the front harness D-ring with a 9-inch maximum connector and are limited to 2-foot free falls.
        3. Horizontal Lifeline Systems
          1. A horizontal lifeline is a flexible line rigged in a horizontal plane and secured at each end to an anchorage. It provides fall protection for work requiring horizontal mobility along elevated surfaces. A worker connects to the line using a personal fall-arrest system that moves with the worker between the two anchorages. By providing a sliding connection along the entire walkway, the anchorage is kept overhead, reducing the hazard of dangerous swing falls that can occur if the worker moves to a location where the anchorage is no longer directly overhead.
          2. Horizontal lifeline systems are common in work areas lacking overhead anchor points available for personnel tie-off. In its simplest form, the horizontal lifeline consists of a cable attached to two or more anchor points on a rooftop, crane runway, bridge, outdoor construction site, or any other elevated work area that poses a fall risk to personnel. When used in combination with personal protective equipment, a horizontal lifeline can arrest a fall, limiting the amount of force that is transferred to both the worker and the fall-arrest system.
          3. Horizontal lifelines must be designed, installed, and used under the supervision of a Qualified Person, and be part of a complete personal fall-arrest system that maintains a safety factor of at least two. Although installing a horizontal lifeline may appear to be as simple as stringing a line between two supports, determining the loads applied to the anchorages and the clearance required below the working surface in the event of a fall can be extremely complicated. In this respect, horizontal lifelines are among the most complex types of fall protection equipment.
        4. Anchorages
          1. Personal fall-protection systems are dependent on an adequate anchor point. Without it, harnesses, lanyards, and shock absorption are useless.
          2. ONLY ANCHORAGE POINTS IDENTIFIED BY A QUALIFIED OR COMPETENT PERSON ARE TO BE USED.
          3. Guardrails, handrails, fire sprinkler piping, and roof ducting are NOT acceptable anchorage points. Questions on anchorages should be directed to a Fall Protection Program Competent Person.
          4. Anchorages are to be:
            1. Independent from the work object whenever possible.
            2. Clearly marked if permanent, and identified as approved by a Qualified Person.
            3. Located at suitable attachment heights.
            4. Of sufficient strength for its intended purpose.
            5. Inspected regularly and before each use.
          5. Connecting devices (e.g., shock absorbing lanyards) should be secured above the point of operation to an anchorage or structural member capable of supporting a minimum dead weight of 5,000 pounds per worker and limiting the fall distance to 6 feet or less.

 

Work Process I. Hazards Requiring Evaluation for Fall Protection

Additional fall protection hazard controls may be required under the following fall hazard conditions:

Work Process J. Off-Site Fall Protection

  1. Employees tasked to perform elevated work at off-site field locations are required to follow all LBNL fall protection policy and work processes regardless of the host institution's fall protection policy or procedures. Contact your Division Safety Coordinator and EHS Liaison for assistance with submitting a "Field Hazard Assessment".
  2. Each division must submit a Fieldwork Hazard Assessment (FHA) to EHS which describes the following:    
    1. A full description of the work hazard(s).                        
    2. A full description of the work process.                         
    3. A full description of all work controls.                             
    4. Emergency Rescue provisions, first responders, and nearest medical facilities.                                                      
    5. Permit work process, e.g. Fall Protection Matrix Permit.
  3. EHS375 Off-site Fall Protection Competent Person training is available for researchers tasked with writing fall protection permits at off-site research facilities    
    1. Fall protection permits can be submitted electronically via smart technologies.                                                           
    2. EHS support is available via smart technology e.g., FaceTime on iPhones or Skype.

Work Process K. Covers

Requirements for covers of holes in floors, roof and other walking working surfaces include the following:


Work Process L. Protection from Falling Objects

When using toe boards as falling object protection:

Work Process M. Walking Working Surfaces

The Facilities Division Structural Engineer must determine if the walking/working surfaces on which employees walk or work have the strength and structural integrity to support employees safely.  Employees are only allowed to work on those surfaces when the surfaces have the requisite strength and structural integrity.

Fall protection is required for each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 4 feet for General Industry workers or 6 feet for Construction workers.

Guard ladder ways floor opening or platforms with standard railing with standard toe board  on all exposed sides (except at the entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.

Prevent material from falling through a wall hole less than four inches above the floor, and the hole is more than five feet above the next lower level, with a standard toe board or other effective means.

Guard every open-sided floor or platform 4 feet or more above adjacent floor or ground by a standard railing or equivalent, on all open sides except where there is entrance to a ramp, stairway, or fixed ladder.  

Where walkways, platforms, or runways are adjacent to dangerous equipment, tanks or similar hazards, regardless of height, guard open-sides with standard railing and toe board.

Cover floor holes to leave no opening greater than one inch in width. Guard wall openings where there is a drop of more than four feet to a lower level. 

Work Process N. Leading Edge Work

Protect employees who are constructing a leading edge 4 feet for General Industry workers or 6 feet for Construction workers or more above a lower level from falling by the use of guardrail systems, safety net systems, or personal fall protection systems.  Exception: when it is demonstrated with an LBNL Active Fall Protection Infeasibility Plan that it is infeasible or creates a greater hazard to use these systems.

There is a presumption that it is feasible and will not create a greater hazard to implement; use at least one of the fall protection systems listed in Work Process H. Active Fall Protection Systems.

Protect employee on a walking/working surfaces, 4 feet for General Industry workers or 6 feet for construction workers, above a lower level where leading edges are under Construction, but who is not engaged in the leading edge work, by the use of guardrail systems, safety net systems, or personal fall protection systems. If a guardrail system is chosen to provide fall protection, and a controlled access zone has already been established for leading edge work, the control line may be used in lieu of a guardrail along the edge that parallels the leading edge.

Work Process O. Hoist Areas

Protect employees in a hoist area from falling 4 feet for General Industry workers or 6 feet for Construction workers or more to lower levels by guardrail systems or personal fall arrest systems.   Protect employees with a personal fall arrest or personal fall restraint system when guardrail systems, [or chain, gate, or guardrail] or portions thereof, are removed to facilitate the hoisting operation (e.g. during landing of materials), and the employee must lean through the access opening or out over the edge of the access opening (to receive or guide equipment and materials, for example).

Work Process P.  Working Near Holes

Protect employees on walking/working from falling through holes (including skylights) more than 6 feet above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.

Protect employees on a walking/working surface from objects falling through hole (including skylights) by covers.

Work Process Q. Formwork and Reinforcing Steel

Protect employees on the face of formwork or reinforcing steel from falling 6 feet or more to lower levels by personal fall arrest systems, safety nets systems, or positioning device systems.

The duties of the controlling contractors under Work Process Q will protect workers from the hazards associated with steel erection activities following the regulatory requirements covered by OSHA 29 CFR 1926.750 Subpart R- Steel Erection.

Work Process R.  Ramps, Runways, and Walkways                 

Protect employees on ramps, runways, and other walkways from falling, 4 feet for General Industry workers or 6 feet for Construction workers, 6 feet or more to lower levels by guardrail systems.

Work Process S.  Working Near Excavations

Protect employees at the edge of an excavation 6 feet or more in depth from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barriers.  

Protect employees at the edge of a well, pit, shaft, and similar excavation 6 feet or more in depth from falling by guardrail systems, fences, barricades, or covers.

Work Process T. Working Near Dangerous Equipment

Protect employees from falling when working above dangerous equipment shall from falling into or onto the dangerous equipment by guardrail systems, equipment guards, personal fall arrest systems, or safety net systems.

Work Process U. Overhead Bricklaying and Related Work

Except as otherwise provided in Work Process N, Leading Edge Work, protect employees performing bricklaying and related work 4 feet for general industry workers or 6 feet for construction workers or more above lower levels from falling by guardrail systems, safety net systems, personal fall arrest systems or shall work in a controlled access zone.

Work Process V. Low Sloped Roofs

Protect employees engaged in roofing activities on low-slope roofs, with unprotected sides and edges 4 feet or more for General Industry or 6 feet or more for construction workers above lower levels from falling by guardrails, safety net systems, personal fall arrest systems, or a combinations of warning line system and guardrail system, warning line and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring.

Work Process W. Steep Sloped Roofs

Protect employees on a steep roof with unprotected sides and edges 4 feet for general industry workers or 6 feet for construction workers, above lower levels from falling by guardrail systems with toe boards, safety net systems, or personal fall arrest systems.

Work Process X. Precast Concrete Erection

Fall protection systems such as guardrails, safety net systems, and personal fall arrest systems must be used to protect employees engaged in the erection of precast concrete members (including but not limited to the erections of walls, panels, columns, beams, and floor and roof "tees") and related operations, such as grouting of precast concrete members, that are 4 feet or more above lower levels  for general industry workers, or 6 feet or more above lower levels for construction workers.

Work Process Y. Residential Construction 

Protect employees engaged in residential construction activities more than 6 feet above lower level by guardrails, safety net, or personal fall arrest system unless another provision e.g. Work Process E.2.c, Exceptions: Fall Protection Plan, has been demonstrated by the employer that the work creates an additional hazard or that active fall protection systems are infeasible.

Work Process Z. Wall Openings

Use a guardrail system, safety net system, or a personal fall arrest system to protect employees working on, at, or near wall openings (including those with chutes attached) where the inside bottom edge of the wall opening is less than 39 inches above the walking/working surface, and the outside bottom edge of the wall opening is 4 feet or more above lower levels for general industry workers or 6 feet or more above lower levels for construction workers.

30.8 Source Requirements

Other Driving Requirements

 

30.9 Reference Documents

Document Number

EH&S Reference

Title

Type

07.07.007.001

PUB-3000, Chapter 10, Appendix A, Section A.13

Ladders

Procedure

 

PUB-3000, Chapter 10, Appendix A, Section A.21

Protection of Openings and Open Side Floors and Decks

Procedure

 

PUB-3000, Chapter 10, Appendix A, Section A.22

Scaffolding

Procedure

 

PUB-3000, Chapter 10, Appendix A, Section A.6

Fall Protection

Procedure

07.07.006.001

Chapter 34

Confined Spaces

Program

07.07.001.001

PUB-3000, Chapter 45

Elevated Work Locations

Program

 

 

ANSI A14.3, Ladders – Fixed – Safety Requirements

Consensus Standard

 

 

ANSI A14.4, American National Standard for Job Made Wooden Ladders

Consensus Standard

 

 

ANSI A92.2, Vehicle-Mounted Elevating and Rotating Aerial Devices

Consensus Standard

 

 

ANSI A92.3, Manually Propelled Elevating Aerial Platforms

Consensus Standard

 

 

ANSI A92.6, Self-Propelled Elevating Work Platforms

Consensus Standard

30.10 Related Documents

30.11 Appendices

Appendix 1. Fall Protection Matrix Permit Acronym Index
Appendix 2. Fall Calculation with 6 Ft Lanyard and SRL Models
Appendix 3. EHS On-the-Job Fall Protection Safety Monitor Training
Appendix 4. LBNL Trigger Height Chart
Appendix 5. LBNL Active Fall Protection Infeasibility Plan
Appendix 6. Field Hazard Assessment Plan (Model)
Appendix 7. LBNL Fall Protection Matrix Permit Acceptance Letter

 Appendix 1. Fall Protection Matrix Permit Acronym Index


Appendix 2: Fall Calculation with 6 ft Lanyard Model and SRL Models


 


Appendix 3. EHS On-the-Job Fall Protection Safety Monitor Training


Appendix 4. LBNL Trigger Height Chart

 

Appendix 5. LBNL Active Fall Protection Infeasibility Plan

Appendix 6. Field Hazard Assessment Plan (Model)


Appendix 7. LBNL Fall Protection Matrix Permit Acceptance Letter

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