Fall Protection

ESCO Group will provide and install all fall protection systems required for an employee, before that employee begins the work that necessitates the fall protection.

1. General Requirements

a) Scope: This written fall protection plan applies to all ESCO Group employees exposed to fall hazards 6 feet or more on ESCO locations or customer sites.  ESCO will follow customer requirements if they are more stringent.  For example, if customer requirements require fall protection at 4 feet.  The site specific fall protection plan will be developed by a qualified person designated by the ESCO Group.

b) Training: Each employee exposed to fall hazards will receive training on fall hazard recognition, selection and use of fall protection systems, and elements of this written plan.  Specific items included in the training will include:

i. The nature of falls in the work area

ii. Procedures for installing, removing, inspecting and maintaining fall protection systems.

iii. Procedures for proper use of fall protection systems, including fall arrest personal protective equipment.

iv. The role of employees in fall protection plans.

v. Employees will be retrained when at the following intervals:

1. Changes in work place hazards which may require additional training.

2. Changes in types of fall protection equipment.

3. When incident investigations or safety observations indicate the employee has not retained the necessary understanding or skill.

vi. All Training will be documented with a written record containing the employee’s name, dates of the training, and the signature of the person conducting the training.  The safety director will maintain all fall protection training and inspection records.

c) Guardrail Systems: Guardrail systems and their use shall comply with the following provisions, as listed in 29 CFR 1926.502(b):

i. Top edge height of top rails or equivalent guardrail system members shall be 42 inches plus or minus three inches above the walkway/working level.  When conditions warrant, the height of the top edge may exceed 45 inches providing the guardrail system meets all other criteria of this paragraph.

ii. Midrails, screens, mesh, intermediate vertical members or equivalent intermediate structural members shall be installed between the top edge of the guardrail system and the walkway/working surface when there is no wall or parapet wall at least 21 inches high.

1. Midrails, when used, shall be installed at a height midway between the top edge of the guardrail system and the walking/working level.

2. Screens and mesh, when used, shall extend from the top rail to the walking/working level and along the entire opening between top rail supports.

3. Intermediate members, when used between posts, shall be not more than 19 inches apart.

4. Other structural members shall be installed such that there are no openings in the guardrail system that are more than 19 inches wide.

iii. Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds applied within 2 inches of the top edge, in any outward or downward direction, at any point along the top edge.

iv. When the 200 pound test load specified in paragraph 3 is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches above the walking/working level.

v. Midrails, screens, mesh intermediate vertical members, solid panels and equivalent structural members shall be capable of withstanding, without failure, a force of at least 150 pounds applied in any downward or outward direction at any point along the midrail or other member.

vi. Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or lacerations and to prevent snagging of clothing.

vii. The ends of all top rails and midrails shall not overhang the terminal posts, except where such overhang does not constitute a projection hazard.

viii. Steel banding and plastic bandings shall not be used as top rails or midrails.

ix. Top rails and midrails shall be at least a quarter inch nominal diameter of thickness to prevent cuts and lacerations.  If wire rope is used for top rails, it shall be flagged at not more than 6 foot intervals with high visibility materials.

x. When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall be placed across the access opening between the guardrail sections when hoisting operations are not taking place.

xi. When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of the hole.

xii. When guardrail systems are used around holes used for the passage of materials, the hole shall have not more than two sides provided with removable guardrail sections to allow the passage of materials.  When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall be provided along all unprotected sides and edges.

xiii. When guardrail systems are used around holes, which are used as points of access, they shall be provided with a gate or be so offset that a person cannot walk directly into the hole.

xiv. Guardrail systems used on ramps or runways shall be erected along each unprotected side or edge.

d) Safety Net Systems: Safety net systems and their use shall comply with the following provisions, as listed in 29 CFR 1926.502(c):

i. Safety nets shall be installed as close as practical under the walking/working surface on which employees are working, but in no case more than 30 feet below such level.  When nets are used on bridges, the potential fall areas from the walking/working surface to the net shall be unobstructed.

ii. Safety nets shall extend outward from the outermost projection of the work surface as follows:

Vertical Distance Minimum Required
From Working Level Horizontal Distance
To Horizontal Plane         of Outer Edge of Net from The
Of Net:         Edge of Working Surface:

Up to 5 feet         8 feet
From 5 to 10 feet         10 feet
More than 10 feet         13 feet

iii. Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface or structures below when subjected to an impact force equal to the drop test described next:

1. Safety nets and safety net installation shall be drop tested at the jobsite after initial installation and before being used as a fall protection system, whenever relocated, after a major repair, and at a 6-month interval if left in one place.  The drop test shall consist of a 400 pound bag of sand 30 to 32 inches in diameter when employees are exposed to fall hazards, but not less than 42 inches above the level.

2. When the employer can demonstrate that it is unreasonable to perform the drop test required above, the employer shall certify that the net and net installation is in compliance with rules regarding a certification record for the net.  The certification record must include an identification of the net and net installation for which the certification record is being prepared, the date that it was determined that the identified net and net installation were in compliance and the signature of the person making the determination and certification.  The most recent certification record for each net and net installation shall be available at the jobsite for inspection.

iv. Defective nets shall not be used.  Safety nets shall be inspected at least once a week for wear, damage, and other deterioration.  Defective components shall be removed from service.  Safety nets shall also be inspected after any occurrence, which could affect the integrity of the safety net system.

v. Materials, scrap pieces, equipment and tools which have fallen into the safety net shall be removed a soon as possible from the net and at least before the next work shift.

vi. The maximum size for each safety net mesh opening shall not exceed 36 square inches nor be longer than 6 inches on any side and the opening measured center to center of mesh ropes or webbing, shall not be longer than 6 inches.  All mesh crossings shall be secured to prevent enlargement of the mesh opening.

vii. Each safety net shall have a border rope for webbing with a minimum breaking strength of 5,000 pounds.

viii. Connections between safety net panels shall be as strong as integral net components and shall be spaced not more than 6 inches apart.

e) Personal Fall Arrest Systems: Personal fall arrest systems shall and their use shall comply with the provision set forth.  BODY BELTS ARE NOT ACCEPTABLE AS PART OF A PERSONAL FALL ARREST SYSTEM. Only a full body harness shall be used for personal fall arrest systems.  Personal fall arrest systems and their use shall comply with the following provisions, as listed in 29 CFR 1926.502(d):

i. Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials.

ii. Connectors shall have a corrosion resistant finish, and all surfaces and edges shall be smooth to prevent damage to interfacing parts of the system.

iii. D-rings and snap hooks shall have a minimum tensile strength of 5,000 pounds.  D-rings and snap hooks shall be proof tested to a minimum tensile load of 3,600 pounds without cracking, breaking or taking permanent deformation.

iv. Snap hooks shall be sized to be compatible with the member to which they are connected.  Only locking snap hooks shall be used.

v. On suspended scaffolds or similar work platforms with horizontal lifelines, which may become vertical lifelines, the devices used to connect to horizontal lifelines shall be capable of locking in both directions on the lifeline.

vi. Horizontal lifelines shall be designed installed and used under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two.

vii. Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds.

viii. During the construction of elevator shafts, two employees may be attached to the same lifeline in the hoistway, provided both employees are working atop a false car that is equipped with guardrails, the strength of the lifeline is 10,000 pounds and all other criteria specified in the paragraph have been met.

ix. Lifelines shall be protected against being cut or abraded.

x. Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet or less shall be capable of sustaining a minimum tensile load of 3,000 pounds applied to the device with the lifeline or lanyard in the full extended position. Utilize an anchor point directly above the person to prevent a swing fall situation.

xi. Ropes and straps used in lanyards, lifelines and strength components of body harnesses shall be made from synthetic fibers.

xii. Anchorage’s used for attachments of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds per employee attached, or shall be designed, installed and used as follows:

1. As part of a complete personal fall arrest system which maintains a safety factor of at least two.

2. Under the supervision of a qualified person.

3. If an anchor point has been used for material handling, it cannot be used for a fall protection anchor point. 

xiii. Personal fall arrest systems, when stopping a fall shall:

1. Limit maximum arresting force on an employee to 1,800 pounds when used with a body harness.

2. Be rigged such that an employee, can neither freefall more than 6 feet nor contact any lower level.

3. Bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet.

4. Have sufficient strength to withstand twice the potential impact energy of an employee free falling from a distance of 6 feet or the free fall distance permitted by the system, whichever is less.

5. NOTE: If the personal fall arrest system meets this criteria and protocol, and if an employee having a combined personal and tool weight of less than 310 pounds and is using the system, the system will be considered to be in compliance.  If an employee having a combined tool and body weight of 310 pounds or more and uses the system, then the employer must appropriately modify the criteria and protocols to provide proper protection for such heavier weights.

xiv. The attachment point of the body harness shall be located in center of the wearer’s back near shoulder level or above wearer’s head. When hooking the snap hook of the lanyard to the harness d-ring a visual confirmation must be done to assure the proper connection between the lanyard and harness.

xv. Harnesses and components shall be used only for employee protection and not to hoist materials.

xvi. Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse.

xvii. The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves. The Safety Department shall be notified prior to starting work if a fall rescue cannot be accomplished by using the onsite aerial lifts/ladders. This will allow the Safety Department to be involved and get a plan in place before the work starts.

xviii. Personal fall arrest systems shall be inspected prior to each use using our lanyard harness inspection sheets.

xix. Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists.

f) Covers: Covers for holes in floors, roofs, and other walking/working surfaces shall meet the following requirements:

i. Covers located in roadways and vehicular aisles shall be capable of supporting without failure at least twice the maximum axle load of the largest vehicle expected to cross the cover.

ii. All other covers shall be capable of supporting, without failure, at least twice the weight of employee, equipment and materials that may be imposed on the cover at one time.

iii. All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment or employees.

iv. All covers shall be color-coded or they shall be marked with the word “HOLE” or “COVER” to provide warning of the hazard.

1. NOTE: This provision does not apply to cast iron manhole covers or steel grates used on street or roadways. 

g) Rescue Plan: When utilizing fall protection equipment on the job site, employees shall make other employees aware of their location so that if a fall incident occurs, there would be someone to summons help. The notified employee needs to be aware that full protection equipment is in use and must check on the individual periodically. 

i. The ESCO Group will make available safety relief straps (steps) for all company harnesses. 

ii. To rescue an individual from a fall incident, we must utilize the onsite aerial lifts or ladders. 

iii. The Safety Department shall be notified prior to starting work if a fall rescue cannot be accomplished by using the onsite aerial lifts/ladders. This will allow the Safety Department to be involved and get a plan in place before the work starts. 

iv. All injuries or near misses resulting from a fall will be investigated to determine root cause.