Approaching Controls Holistically
Acrophobia ranks third on the list of things people fear the most, so why is it often so hard to get people to comply with the regulation that they must tie off while wearing an approved fall arrest harness? Well for starters, no such regulation exists. Now, before you get all self-righteous and belligerent, let me explain.

While it is true that there are in fact, many regulations that require employers to protect workers from falls from height, none (at least that I can find or know of) specifically require that a harness be worn. It makes no sense to me that safety professionals who are well-versed in the hierarchy of controls ignore them when they are looking at fall protection. The typical first response is to insist on Personal Protective Equipment – the lowest control in the hierarchy of controls and by far the least effective.




Fascination with PPE


So many safety professionals tend to throw the hierarchy of controls out the window when it comes to working at height. You don’t believe me? Do a Google search on “Working at Height protection” and you will see page (and Advert) after page extolling the virtues of the fall arrest harnesses. That’s swell, but Personal Protective Equipment (PPE) is at the bottom of the hierarchy of controls. So, why this fascination with PPE? when the hierarchy of controls tells us plainly and succinctly that this form of protection isn’t all that effective chiefly because it depends on the, often reluctant, cooperation of the worker.

There are plenty of reasons why workers resist wearing fall arrest harnesses, but my favorite one was the cases (no that is not a typo this has happened multiple times over the years) where the safety department required workers who worked at height (which they defined as anything higher than two metres) and yet the harnesses they gave them had lanyards that were just a touch over three metres. One does not have to be a genius to know that if one falls two metres and the lanyard is three metres you are going to end up on the floor in a bloody heap. People, by and large, will follow the rules provided that the rules make sense, and many people will ignore rules that don’t make sense.

Another factor that causes resistance to harnesses is fit. One size does NOT fit all when it comes to fall arrest harnesses. Very large or obsese workers may find it difficult to find a harness that fits comfortably and because of this discomfort the workers are highly likely to wear the harness inappropriately. Additionally, all harnesses have a weight limit and that limit can be compromised after multiple uses or because of inappropriate storage of a harness. Very small workers may find it difficult to find a harness that will prevent them from slipping out of it during a fall. There are harnesses specifically designed for men and women of slight frame or build.

“it’s important to have the right harness for the employee and the right harness for the application; if you do not you are putting your workers at risk”

In short, it’s important to have the right harness for the employee and the right harness for the application; if you do not you are putting your workers at risk. Too often harnesses are issued without these considerations in mind, what’s worse is that many companies have a small number of harnesses that are issued before a job.

Without proper training in how to adjust the harness workers may be put at substantial risk. The following is the correct procedure for adjusting a harness for proper fit:

1. Shake the harness, while holding it by the dorsal ring (d-ring) – ensure the harness itself is right side up, and that the straps hang straight.
2. Put your arms through the shoulder loops and leg straps, making sure both shoulder loops are vertical and spread evenly across the chest.
3. Attach the waist belt by inserting the male connector into the female connector. Do the same for each of the shoulder straps.
4. All straps should be snug and pulled tight. Adjust the straps until the harness fits comfortably on the body. Make sure both leg straps have been secured properly.
5. Once you’re wearing the harness and all buckles have been attached, stand up and try moving in any direction. The harness should feel centered and snug without limiting your range of motion.
6. If there are any loose straps or buckles, use keepers or tie-down straps to keep them secure and out of the way, otherwise these straps may get caught in moving parts or machinery.

You should never walk around with your buckles or straps undone. There’s always a chance you could forget to reattach your buckles or straps, leaving you vulnerable in the air.

Beyond the battle to get people to wear PPE like safety glasses or hard hats, when it comes to fall arrest systems some of the objections you will hear from workers are valid, so whenever possible use the hierarchy of controls to guide your thinking about protecting workers from falling from heights.

Elimination


I work in the movie business and have for about ten years – first in production safety, and most recently as a COVID Compliance Supervisor – and have encountered situations too numerous to mention where tying off just wasn’t an option. Unfortunately, too many people see fall arrest harnesses as the only option and where that isn’t possible they default to no protection whatsoever.

The best way to eliminate a fall from height hazard is to not work at height. In film production many otherwise dangerous scenes are shot in front of a green screen – literally a “digital green” backdrop that allows filmmakers to drop in a photo realistic background. So while the actors are actually standing on a soundstage with a few props, when the film is finished the actors appear to be dangling off a cliff or jumping across rooftops.

“whether you think you can or you think you can’t, you’re right”

Some of you may rightfully thinking, that’s great, but I don’t work in the movies, I work in construction, or manufacturing, or slaughterhouses, and I can’t “make pretend” that I am working at heights. I have to actually DO the work at height. If my years of experience have taught me anything it’s that if you only see one solution you will believe there is only one solution. As Henry Ford said, “whether you think you can or you think you can’t, you’re right.” This quote is completely applicable to fall protection. If you think there isn’t a better way, you’re never going to find one.

A common practice in the construction business is to build substructures on the ground and then hoist them onto the point of the structure where it will eventually be installed. This eliminates the risk of a fall from height while adding minimal risk (assuming good crane safety discipline is observed.)

Substitution


Sometimes whether we like it or not, we are forced to work at heights, but that doesn’t mean we have to bury our heads in the sand.

Once I was watching the rehearsal of a scene that had people running at a height of about four metres. I was concerned because obviously you can’t have actors in safety harnesses, so I set out to use the hierarchy of controls. I looked at the situation and came up with an idea that I suggested to the Assistant Director. What, I asked, would it do to the artistic vision if we were to shoot the scene from a different angle? He said it didn’t make a difference and asked me why I wanted to know. I explained that by moving the angle of the shot if an actor were to walk off the platform he or she would only fall about half a metre. Now I know that a fall from that distance may well have caused an injury, but it was far less risky than a four metre fall that was almost certain to be fatal. So while I was unable to eliminate the hazard entirely I was able to substitute one condition for another to mitigate the severity of the injury. The scene was shot with minimal disruption and without incident.

Engineering controls


Another control that can be very effective in protecting workers from a fall from height is engineering controls. These can range from netting designed to catch a falling worker, to guard rails to arrest belts (an anchored tether that extends short of the fall zone.) These engineering controls are surprisingly inexpensive and easy to install.

I was once on a construction site when I saw a crane hoisting a window to be installed onto the top floor of a third story building. I was horrified to see the workers reaching out to grab the suspended window and leaning precariously out of the building. A couple of the five or so struggling to get the window into place were literally kneeling on the opening and leaning out.

I walked over to the foreman and before I could speak he said “I know, I know, they need to be tied off.” I explained to him that the building had no appropriate tie offs and if they were to drive anchors into the ageing concrete ceiling there was a good chance the anchor would fail, or worse yet were the worker to fall that a large chunk of concrete would come loose and land on him.

He asked what I suggested and I asked him why they didn’t use a manlift? He cursed and I thought he was mad at me. I asked if I said something wrong, and he just scowled at me and pointed to five unused manlifts and grumbled about the exorbitant fee he was paying to have them sitting there. He stopped work and had one worker in the man lift working to put the window in from the outside while another worked on the inside to secure it. Not only did the job become exponentially safer, it lowered the risk of damaging the window AND now the job required only two workers instead of five. There was an added benefit: the foreman and the crew saw that I was there to enable safe production – I wasn’t a cop, or someone to be feared or hated, but someone who was genuinely looking for safer ways to do the job.

“PPE is completely useless without other controls to support it”

Personal Protective Equipment


Knowing that a good share of those reading this either sell or buy personal equipment, what I am about to say is likely to go over like a fart in church. But I have to risk it. PPE is completely useless without other controls to support it. I have seen road patching crews bedecked in high-viz apparel, and wearing gloves, hard hats, steeltoed boots literally stepping into rush hour traffic from a blind spot. Even knowing of this possibility I have almost hit several workers – not with my car mind you, I was angry enough to put out a hit on them for their wanton disregard for their safety and the safety of drivers, but I don’t know that many contract killers and the ones I do know charge too much.

The worst part about this situation was that they were following the rules given to them by their employers (although what they were doing is, in fact, against the law). All the PPE in the world won’t save people who put themselves in the line of fire because their stupidviser told them to do so.

Approaching controls holistically


Contrary to what many people – both in safety and in Operations – seem to think, there is no hard and fast rule for applying a particular control. Each job and each circumstance needs to be carefully assessed before deciding that a particular control is acceptable and appropriate. The key is to approach the situation sensibly – start at the top of the hierarchy of controls and work from there. But really take a hard and serious look at implementing the controls and work hard to make it happen. Be creative and remember, as Henry Ford said, “whether you think you can or you think you can’t, you’re right.


SOURCE:

https://www.hsimagazine.com/article/approaching-controls-holistically/