PowerPoint Presentation Conference/PC02 John Lindstrom F… · 01 - Introduction 01:01 ... 1910.23(c)(2) states that "every runway shall be guarded by a standard railing on all open

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PC02 FALL PROTECTION

Course Introduction

• Instructor(s)

• Classroom Rules

• Restrooms

• Breaks

• Emergency Procedures

• Emergency Exits

• Evacuation Wardens

• Severe Weather Shelter

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Disclaimer

• Hennepin Technical College and the North Dakota Safety Council are NOT endorsing any of the products shown in this training program. They are used for demonstration purposes, ONLY.

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01 - Introduction

01:01

Construction Worker Dies In Fall At U.S. Bank Stadium

• One worker was killed and another injured after falling during construction Wednesday morning on the roof at the new Minnesota Vikings stadium.

August 26, 2015


• The workers, from Berwald Roofing, fell about 7:45 a.m. on the stadium’s north side, said a statement from John Wood, senior vice president for Mortenson Construction.

August 26, 2015

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• Both were treated at the scene and taken to nearby Hennepin County Medical Center, Wood said.

• The surviving worker was in serious condition, he added.

August 26, 2015

Grim Facts

• 2009 Bureau of Labor Statistics:

– 605 worker deaths

– 212,760 workers seriously injured

– $70 billion annual cost

• Non-fatal injuries

– 80% require surgery

– 60% have fractures

– 30% have spinal fractures

– 10% permanently disabled

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Grim Facts

• Of the 4,383 worker deaths in 2012, 668 workers died from falls (15%)

• In construction alone, over 100,000 workers are injured each year due to falls.

• Most workers who fall sustain multiple injuries – many never return to work.

Grim Facts

• The greatest number of falls occur to workers between 25-34 years of age.

•WHY?

Three Dangerous Attitudes that Lead to Fatal Falls

• “I Don’t Work Very High”

• “I Have Good Balance”

• “I’ll Catch Myself”

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“I Don’t Work Very High”

• While it’s true that in 2012, 25% of fatal falls occurred in falls greater than 30 feet, it is also true that 25% of fatal falls occurred in falls less than 10 feet.

• There’s a reason OSHA’s fall protection rules don’t begin at 20 or 30 feet – because you don’t have to fall far to be seriously injured or killed.

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“I Have Good Balance”

• In your job do you have perfect conditions and a perfectly controlled environment? – An unexpected gust of wind– A misty rain that’s making your walking surface

slippery. – A co-worker or piece of equipment may have spilled

an oily substance that you are unaware of. – Something could swing into you or your path, such as

a rigged load on a crane, or equipment being set by a forklift.

– You could back up and trip into a skylight and fall several stories to your death.

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“I Have Good Balance”

• Anybody who has ever experienced an attack of low blood sugar can tell you that it can be both dizzying and unexpected.

• A mild heart attack could be survivable, but probably not at 30’ with no fall protection.

• Who hasn’t moved just a little too quickly and experienced a ‘head rush’?

• Any of these things could result in an otherwise ‘balanced’ worker plummeting to their death.

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“I’ll Catch Myself”

• Some people actually believe that their reaction time is so good that if they were to fall, they would just catch themselves.

• While this might work if – a) you felt like you were about to fall and

– b) there was actually something nearby to grab onto,

• The fact of the matter is if you do fall, you are out of arms reach in a blink of an eye.

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Distance (feet) Time (in seconds)

6 0.5

16 1.0

36 1.5

64 2.0

100 2.5

144 3.0

256 4.0

How far and fast would you fall?

At Time

(Seconds)

Distance of

Fall

(Feet)

0.25 1

0.35 2

0.50 4

0.61 6

0.79 10

1.12 20

1.76 50

• The time required for a person to see the stimulus,

• react to it by contracting muscles

• and the time required for the response to begin usually will be on the order of 0.75 sec.

200 Pound Falling Body

Falling a distance of 6 ft. = 3,919 ft. / lbs.

Falling a distance of 10 ft. = 5,060 ft. / lbs.

Falls from as little as 4 to 6 feet can cause serious lost-time accidents and

sometimes death.

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My Favorite Quote

• “If you fall from 11 feet you have a fifty percent chance of being killed.

• If you fall from 45 feet you have a ninety percent chance of being killed.

• We will be starting from the seventh floor of the building…

• Check Your Knots!”

Roco Rescue Training – Reno, NV (1983)

Fall ProtectionCompetent Person Training

• This course is for individuals that are responsible for the supervision, implementation and monitoring of a managed fall protection program.

• Students will expand their knowledge and ability to identify hazardous conditions, develop programs and make equipment selections to properly deal with fall hazards.

Fall ProtectionCompetent Person Training

• This course is a pass/fail program, it incorporates extensive classroom and hands-on training and both written and practical examinations that are based on the requirements of the US OSHA Regulations, ANSI Z359.2 standard and CSA.

• Upon successful completion of this course, the student will receive a certificate acknowledging they have met or exceeded OSHA, ANSI and CSA requirements as a Competent Person.

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Course Outline

• Fall protection standards

• Competent person responsibilities

• Fall protection plans and programs

– Hazard elimination

– Hazard control

– Personal fall arrest systems

Course Outline

• Detailed equipment inspection

• Selection and use of non-certified anchorages

• Fall protection rescue procedures

FALL PROTECTION STANDARDSFall Protection – Competent Person Training

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General Duty Clause

• (a) Each employer

– (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

– (2) shall comply with occupational safety and health standards promulgated under this Act.

General Duty Clause

• (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

1910 vs. 1926

• Although 29 CFR 1910 and 1926 are separate standards, there are notable differences.

• Some standards are covered in duplicate, and some go into more depth than the other.

• Although both 1926 & 1910 have versions of the fall protection standard, the construction industry standard is far more detailed than the General Industry standard.

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Fall Protection Standards

• 29 CFR 1910

– Subpart D• Walking-Working Surfaces

– Subpart F• Powered Platforms,

Manlifts and Vehicle-Mounted Work Platforms

• 29 CFR 1926

– Subpart M• Fall Protection

– Subpart X• Stairways and Ladders

29 CFR 1910 SUBPART DWALKING – WORKING SURFACES

Fall Protection – Competent Person Training

29 CFR 1910 Subpart D - Walking-Working Surfaces

• 1910.23 - Guarding floor and wall openings and holes.

• 1910.27 - Fixed ladders.

• 1910.28 - Safety requirements for scaffolding.

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1910 - Fall Protection Standards

• The General Industry standard 1910.23(c)(2) states that "every runway shall be guarded by a standard railing on all open sides 4 feet or more above floor or ground level" referring to when guardrails are required on a platform or runway.


• OSHA standard 1910.27(d)(1)(ii) requires fixed ladders be equipped with cages or wells on ladders of more than 20 feet (to a maximum unbroken length of 30 feet).

– However, fixed ladders on towers, water tanks, and chimney ladders that are over 20 feet in unbroken length may be equipped with suitable safety devices such as lifebelts, friction brakes, and sliding attachments in lieu of cages.


• There are also numerous OSHA general industry standards for various types of scaffolding which require guardrails be installed along open sides and ends of work platforms, but only if they are located greater than ten (10) feet above the ground or floor.

– 1910.28(b)(15), (c)(14), (d)(7), (f)(15), (g)(5), (h)(8), (k)(5), (m)(7), (o)(2), and (p)(7)

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29 CFR 1910 SUBPART FPOWERED PLATFORMS, MANLIFTS AND VEHICLE-MOUNTED WORK PLATFORMS



• 1910.66(f)(5)(i)(G) requires that each working platform of powered platforms used for building maintenance be provided with a guardrail system on all sides.


• When using a scissor lift, the employee need not use any type of restraint.

• However, the employee MUST remain on the platform and within the guardrail system.

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• 1910.66(f)(5)(ii)(M) requires a vertical lifeline be provided as part of a fall arrest system… for each employee on a working platform suspended by two or more wire ropes.


• Employees on working platforms shall be protected by a personal fall arrest system meeting the requirements of 1910.66 Appendix C, Section I, of this standard, and as otherwise provided by this standard.


• OSHA standard 1910.67(c)(2)(v) for aerial boom-lifts requires the user(s) to wear a body belt with lanyard attached to the boom or basket when working in the basket. – There is no height

specified for this requirement.

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Only Dummies…

01:46

29 CFR 1926 SUBPART MFALL PROTECTION


Subpart M – Fall Protection

• 1926.501(b)(2)(ii)

– Each employee on a walking/working surface 6 feet (1.8 m) or more above a lower level where leading edges are under construction, but who is not engaged in the leading edge work, shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system.

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Can You Be Hurt

29 CFR 1926. Comments

NO 502(b) Guardrail systems

MAYBE

502(h) Safety Monitor Systems

502(g) Controlled Access Zones

502(f) Warning Line Systems

YES

502(e)Positioning Device Systems• Allow a 2 foot limited fall• 3,000# anchor

502(d)

Personal Fall Arrest Systems [PFAS]• Allow 6 foot free fall OR• 2 foot limited fall• 5,000# anchor• 1,800# arresting force

502(c)Safety Net Systems• Allow 30 foot free fall

29 CFR 1910 SUBPART XSTAIRWAYS AND LADDERS


Subpart X – Stairways and Ladders

• 29 CFR 1926.1053(a)(19) states that fall protection must be provided whenever the length of climb on a fixed ladder equals or exceeds 24 feet. – A fixed ladder is "a ladder that

cannot be readily moved or carried because it is an integral part of a building or structure" (1926.1050(b)).

– Also, even if the length of climb is less than 24 feet, under 1926.1053(a)(18), cages, wells, ladder safety devices, or self-retracting lifelines must be provided where the top of the fixed ladder is greater than 24 feet above lower levels.

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Subpart X – Stairways and Ladders

• 1926.1053(a)(18)

• Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels.

• 1926.1053(a)(19)

• Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:

• 1926.1053(a)(19)(i)

• Ladder safety devices; or• 1926.1053(a)(19)(ii)

• Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or

• 1926.1053(a)(19)(iii)

• A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).

COMPETENT PERSON RESPONSIBILITIES


Competent Person

• 29 CFR 1926.32(f)

– "Competent person" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

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Competent Person Responsibilities

• The "Competent Person" is capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as in their application and usewith related equipment.

• Fall hazard surveys and procedures

• Fall protection system assessments

• Fall protection component inspections

Java!Java!Java!

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FALL PROTECTION PLANS AND PROGRAMS


02 - Work Plan

01:55

Fall Protection Planning

• Identify fall hazards that you can’t eliminate.

• If you can’t eliminate fall hazards, you must ensure that someone who does fall doesn’t die

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• Ways to eliminate fall hazards:– Perform construction work

on the ground before lifting or tilting it to an elevated position.

– Install permanent stairs early in the project so that workers don’t need to use ladders between floors.

– Use tool extensions to perform work from the ground.


• There are two ways:

– Prevent falls with covers, guardrails, handrails, perimeter safety cables, and personal fall-restraint systems.

– Control falls with personal fall-arrest systems, positioning-device systems, and safety-net systems.


• Use these fall-protection systems only when you can’t eliminate fall hazards or prevent falls from occurring.

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05 - Work Procedures

01:19

Good Work Practices

• Perform work at ground level if possible

• Use passive fall protection

• Tether (or restrain) workers so they can't reach the edge

• Position / suspend workers to prevent falls

• Designate and use safety monitors (spotters)

– This is less desirable of all the systems

FALL HAZARD ELIMINATIONFall Protection – Competent Person Training

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01 - Introduction

Fall Hazard Elimination

Elimination

• Controlled Access Zones– Control line or by any other

means that restricts access (1926.502(g))

• Safety monitor system (1926.502(h))

• Guardrail systems (1926.502(b))

• Restraint

Top Rail

Mid- Rail

Toeboards

Guardrails

• Top rails between 39 and 45 inches tall

• Toeboards at least 3-1/2 inches high

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Restraint

• This technique aims to keep the worker from entering a zone wherethere is a risk of falling.

– Leash principle

03 - Fall Restraint

02:16

FALL HAZARD CONTROLFall Protection – Competent Person Training

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Fall Hazard Control

Elimination

• Controlled Access Zones– Control line or by any other

means that restricts access (1926.502(g))

• Safety monitor system (1926.502(h))

• Guardrail systems (1926.502(b))

• Restraint

Control

• Positioning systems

• Suspension systems

• Safety net systems

• Personal Fall Arrest System [PFAS]

• Retrieval system

Work Positioning

• This technique allows the worker to work while hanging in his equipment, hands free:

– Where there is no risk of falling into space

– Where there is a risk of falling into space

Positioning

• This system holds the worker in place while keeping his/her hands free to work.

• Whenever the worker leans back, the system is activated. – However, the personal

positioning system is notspecifically designed for fall arrest purposes.

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Suspension

• This equipment lowers and supports the worker while allowing a hands-free work environment, and is widely used in window washing and painting industries.

Suspension

• This suspension system components are not designed to arrest a free fall, a backup fall arrest system should be used in conjunction with the suspension system.

Fall Arrest

• Reduce the distance required to arrest the fall

• Absorb the energy of the fall in order to limit the impact transferred to the human body

• Maintain the victim in a position that limits the effects of inert suspension

• Fall Factor and Clearance– The fall factor is the

relationship between the height of the fall and the length of the rope or lanyard available for absorbing the energy of the fall.

– Height of fall / Length of rope or lanyard

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04 - Fall Arrest

03:14

Safety Nets

• Can be used to reduce the fall exposure when working where temporary floors and scaffolds are not used and the fall distance exceeds 25 feet. – Place as close as

possible, but no more than 30 feet below where employees work

Safety Nets

• In 1936, when delays slowed construction, Strauss invested over $130,000 in a novel safety feature: a vast net --similar to a circus net --suspended under the bridge. – The safety net extended

ten feet wider than the bridge's width and fifteen feet further than the roadway's length.

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Safety Nets

• It gave workers an abiding sense of security as they moved more freely -- and quickly -- across the slippery, half-constructed steel. – Some workers were

positively giddy about the innovation, so much so that they had to be threatened with dismissal so they wouldn't dive into the net for thrills.

00:38

Breaktime

• You have 10 minutes to go to the bathroom, get a cup of coffee, grab a snack, rotate your tires, check your e-mails, and call home.

• BEGIN!

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PERSONAL FALL ARREST SYSTEM [PFAS]


Personal Fall Arrest System [PFAS]

• A fall arrest system is required if any risk exists that a worker may fall from an elevated position, as a general rule, the fall arrest system should be used anytime a working height of six feet or more is reached.

GRIM FACTS

• The terminal velocity of the mass before arresting a fall at 6 feet is 5.99 m/s (19.65 ft/sec),

• Which is the equivalent of hitting a brick wall at almost 14 mph.

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• Thorough employee training in the selection and use of personal fall arrest systems is imperative.

• Employees must be trained in the safe use of the system.


• This should include the following:

– application limits;

– proper anchoring and tie-off techniques;



– estimation of free fall distance, including determination of deceleration distance, and total fall distance to prevent striking a lower level;

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– methods of use; and inspection and storage of the system.

• Careless or improper use of the equipment can result in serious injury or death.

Personal Fall Arrest System (PFAS)

• Anchor– Must withstand 5,000#

per person

• Body Harness– Must keep person

upright

– May apply 1,800# of force

• Connection– Fall Limiting / Arresting

Devices

04 - Anchorage

03:49

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Anchorage

• Must be independent of any platform anchorage and capable of supporting at least 5,000 lbs. per worker

Anchorage

Anchorage

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Anchorage

Anchorage

06 - Harness

01:28

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Body Belt

• Body belts (single or double D-ring) are designed to restrain a person in a hazardous work position and to reduce the possibility of falls.

– They should not be used when fall potential exists; positioning only.

Suspension Belts

• Suspension belts are independent work supports used to suspend a worker, such as boatswain's chairs or raising or lowering harnesses.

• Separate fall arrest is required.

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Body Harness

• A full-body harness with a shock-absorbing lanyard or a retractable lifeline is the only product recommended. – A full-body harness

distributes the forces throughout the body, and the shock-absorbing lanyard decreases the total fall arresting forces.

05 - Lanyard

03:07

Connection

Positioning Devices

• 1926.502(e)(1)– Positioning devices shall be

rigged such that an employee cannot free fall more than 2 feet.

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Connection

Fall Limiting Devices

• 1926.502(d)(12)– Self-retracting lifelines and

lanyards which automatically limit free fall distance to 2 feet (0.61 m) or less

– shall be capable of sustaining a minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard in the fully extended position.

Connection

Fall Arresting Devices

• 1926.502(d)(13)– Self-retracting lifelines and

lanyards which do not limitfree fall distance to 2 feet (0.61 m) or less, ripstitchlanyards, and tearing and deforming lanyards

– shall be capable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position.

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FALL PROTECTION PLANNINGFall Protection – Competent Person Training

07 - Planning

01:55

Calculating Your Fall Distance

• Bottoming Out:

– When a worker hits a lower level, or the ground, before the fall is fully arrested.

– Occurs when required fall clearance is greater than the distance from the work surface to the next level.

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• Situation

– I am 6 feet tall

– Using a 6 foot lanyard

– Anchored at my shoulder height

• How much fall clearance do I need?


• General Rule:

– 6 feet free fall

– 3.5 feet deceleration

– 1 foot D-ring slide

– 2 foot safety factor

• 12.5 feet clearance required


• What if I don’t have 12.5 feet of clearance?

– Raise the anchor point

– Use a shorter lanyard

– Use a Self-Retracting Lifeline [SRL]

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• Using an SRL:



– 2 feet safety factor

• 6.5 feet clearance required.

– Versus 12.5 feet


• Using an Rope Grab:

– 6 feet free fall

– 2 feet for rope grab


– 1.5 feet rope stretch


– 2 feet safety factor

• 16 feet clearance required

Fall Protection Considerations

Fall Obstruction

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Fall Protection Considerations

Swing Obstruction

DETAILED EQUIPMENT INSPECTIONFall Protection – Competent Person Training

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Inspection Frequency

• How often should fall protection equipment be inspected?– Fall protection equipment

should be inspected by the user before each use, and should also be inspected at least once a year by a Competent Person who is designated by the employer to oversee the fall protection program. Note the Competent Person can inspect the equipment more frequently if the use is severe.

• Is the ANSI required "once a year" full inspection of equipment by a competent person OK under all circumstances?– Fall arrest equipment must be

inspected by the user before each use. The competent person must perform a full inspection of the equipment at least once a year or sooner if the competent person feels the equipment is being used in an aggressive environment and requires more frequent inspection.

Equipment Inspections

03:36

Detailed Equipment Inspection

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06 – Anchor Hardware Inspection

02:34

03 – Full Body Harness Inspection

02:53

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05 – Carabiner Inspection

01:41

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04 – Lanyard Inspection

02:11

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07 – Retracting Lifeline Inspection

06:02

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Fall Protection Test - Funny

00:19

Inspection

• DO NOT connect two (or more) snap-hooks directly to one ‘D’-ring.

– Use an extension device

Inspection

• DO NOT connect two snap-hooks to each other.

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Inspection

• DO NOT connect a snap-hook back on its integral lanyard.

SELECTION AND USE OF NON-CERTIFIED ANCHORAGES


Selection and Use of Non-Certified Anchorages

• Anchor Systems– Z359.2 establishes

strength criteria for various fall protection anchors, simplifying in one standard the design requirements for fall arrest, horizontal lifelines, work positioning, travel restraint and rescue systems.

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• a certified anchorage is one where there is documentation that the system meets the requirements of the standard and where the anchorage is identified and the system designed by a qualified person.

• A non-certified anchorage is one that a competent person can judge to be capable of supporting the predetermined anchorage forces and that incorporates an energy-absorbing device.


• Fall Arrest– Noncertified anchor: 5,000

lbf. static strength.– Certified anchor: designed,

selected and installed by qualified person; static strength two times maximum arresting force.

• Work Positioning– Noncertified anchor: 3,000

lbf. static strength.– Certified anchor: static

strength two times foreseeable force.

• Restraint & Travel Restriction– Noncertified anchor: 1,000


strength two times foreseeable force.

• Rescue Systems– Noncertified anchor: 3,000


strength five times the applied load.

Static Load Requirements

Non-Certified Certified

Fall Arrest Systems 5,000 lbs. (22.2 kN) 2 X maximum arresting force

Work Positioning Systems 3,000 lbs. (13.3 kN) 2 X foreseeable force

Restraint & Travel Systems 1,000 lbs. (4.5 kN) 2 X foreseeable force

Rescue Systems 3,000 lbs. (13.3 kN) 5 X applied load

Horizontal Lifelines Must sustain at least two times the maximum tension developed in the lifeline during fall arrest in the direction applied by lifeline forces

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Click to edit Master title style

Breaktime

• You have 10 minutes to go to the bathroom, get a cup of coffee, grab a snack, rotate your tires, check your e-mails, and call home.

• BEGIN!

FALL PROTECTION RESCUE PROCEDURES


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Deer Stand Accident

01:31

Prolonged, Upright Suspension

• In 29 CFR 1926.502, OSHA requires employers

to "provide for prompt rescue of employees in

the event of a fall,"

• Research indicates that "suspension in a fall

arrest device can result in unconsciousness,

followed by death, in less than 30 minutes."


• The risk of "orthostatic intolerance" and

"suspension trauma," which refer to some of

the potential health hazards – death being the

chief one – experienced by workers who are

suspended upright by fall arrest equipment

after a fall.

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• Injuries suffered during the fall, or the shockresulting from the experience of the fall, "can increase the onset and severity" of venous pooling and orthostatic intolerance.


• Other physical and environmental factors such as:

• Fatigue,

• Dehydration,

• Hypothermia,

• Cardiovascular disease,

• Respiratory disease and

• Blood loss

Suspension Trauma

Prolonged, Upright

Suspension

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• "Unless the worker is rescued promptly using

established safe procedures, venous pooling

and orthostatic intolerance could result in

serious or fatal injury, as the brain, kidneys

and other organs are deprived of oxygen,"


Retrieval

• 1926.502(d)(20), when personal fall arrest systems are used, the employer must assure that employees can be promptly rescued or can rescue themselves should a fall occur.

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Retrieval

• In some situations, equipment which allows employees to rescue themselves after the fall has been arrested may be desirable, such as devices which have descent capability.

Retrieval

Rescue Positioning Device [RPD]

• System to transfer victim from fall arrest equipment to hauling / lowering system.

• May require secondary anchorage if fall has damaged primary anchorage.

05:18

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Retrieval

• The availability of rescue personnel, ladders or other rescue equipment should be evaluated.

Victim Pickoff

02:30

Pole Top Drop

00:20

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Retrieval

• OK for raising and lowering tools and materials.

• NOT for PFAS or personnel retrieval

Equipment Inspection Exercise

• Harness selection

• Inspection of anchor, lanyard, harness, and hardware.

• Donning and fitting the harness

• Climbing exercise

• Harness suspension exercise

COURSE SUMMARYFall Protection – Competent Person Training

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Course Summary

• Fall hazard elimination and controls

– Controlled Access Zones

– Passive Fall Protection (e.g. handrails, guardrails, etc.)

– Fall Restraint systems

– Fall Arrest systems (e.g. personal fall arrest systems [PFAS], and nets)

Course Summary

• Detailed equipment inspection

• Selection and use of non-certified anchorages

• Fall protection rescue procedures

Course Summary

• Competent person responsibilities

– Fall hazard surveys and procedures

– Fall protection system assessments

– Fall protection component inspections

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Summary

01:10

QUESTIONS

QUIZ

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Documents

PowerPoint Presentation Conference/PC02 John Lindstrom F… · 01 - Introduction 01:01 ... 1910.23(c)(2) states that "every runway shall be guarded by a standard railing on all open