By Baxter Byrd, Pure Safety Group
As the march of technology pushes fall protection products into the future, the most useful tool for the worker-at-height remains the one between their ears. Keeping that tool keen and sharp with a properly managed training program is the most effective way to ensure that what goes up, comes down safely.
2017 was an important year regarding worker-at-height training. OSHA released its long-awaited update to the 1910 Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems), which became effective on Jan. 17, 2017. If there was any doubt before this release as to the necessity of individual worker training, the updated standard removed that doubt. OSHA 1910.30(a)(1) states unequivocally:
Before any employee is exposed to a fall hazard, the employer must provide training for each employee who uses personal fall protection systems or who is required to be trained as specified elsewhere in this subpart. Employers must ensure employees are trained in the requirements of this paragraph on or before May 17, 2017.
This standard helps further codify the non-legally binding, but thorough ANSI/ASSE Z359.2-2017 Minimum Requirements for a Comprehensive Managed Fall Protection Program, and echoes the requirements found in OSHA 1926 Subpart M Safety and Health Regulations for Construction. In essence, training for the worker-at-height can no longer be considered a tangential concern.
It would be reductive to simplify training for the worker-at-height into a single, all-encompassing curriculum; there are simply too many strata of worker to require every worker to “know it all.” Rather, a better approach is to identify which training is most effective for a specific type of worker, and then add layers of more complex training as workers gain experience or take on greater responsibilities.
The power of why
Before jumping into the different levels of training you may need on a jobsite, it’s worth considering one of the most important benefits of training – the power of “why.” When addressing a fall hazard solution, it is one thing to know what equipment to use (practical knowledge), and another to know why to use it (theoretical knowledge). It is very possible a worker may have the practical knowledge to solve a problem, but not the theoretical reasoning (the “why”) behind it. Without a firm grasp of the theoretical reasoning behind why a specific solution is used, a worker may substitute what they feel is an appropriate alternative and end up in a life-risking situation.
Take leading edge-compatible self-retracting lifelines, for example. A worker may know there are certain SRLs that are suitable for falls in which the lifeline may contact the edge of a structure. But, unless they know why only specific SRLs can withstand that type of fall—how they work, the purpose of certain features or how a leading-edge fall differs from a regular fall—when it comes time to choose an SRL from the job box, their lack of knowledge may lead them to make the wrong choice. This is especially true when a jobsite contains products from different manufacturers, since not all designs are necessarily compatible. When a worker can properly evaluate a practical solution against their theoretical knowledge, they are much less likely to make mistakes in choosing a proper fall protection solution.
Different roles, different responsibilities
Jobsite responsibilities can vary greatly and, unlike in a strict hierarchical type of structure, a worker may have multiple responsibilities depending on the nature of the work being done. Still, there are general boundaries that can help identify what type of fall protection training might be most appropriate for a given jobsite role. The following list is not exhaustive, but includes examples of role-specific training common to many jobsites:
- Authorized Person: Entry-level introduction to fall protection topics. Authorized Persons represent the standard worker on a jobsite, and typically work under the supervision of a Competent Person.
- Competent Person: Competent Persons are assigned by the employer, and are capable of identifying fall hazards and selecting the appropriate fall protection equipment based on theoretical knowledge to mitigate those hazards. Competent Persons calculate fall clearance, develop rescue plans and perform regular equipment inspections to ensure proper functionality. Each jobsite must have at least one Competent Person.
- Authorized Rescuer: A prompt rescue of a fallen worker is a legal requirement. The Authorized Rescuer is capable of writing or reviewing a fall protection or rescue plan and performing a timely rescue in any given situation. Rescuers are knowledgeable in the selection, care, inspection and use of specialized rescue equipment.
- Confined Space Entry/Rescue: Not every worker is automatically permitted to enter a confined work space. Given the unique conditions found in confined space areas, workers need to be familiar with environmental conditions/noxious air ventilation, explosive potentials due to flammable vapor concentrations and below-foot rescue/retrievals. Confined space rescues are incredibly dangerous with potential rescuers themselves making up nearly 60 percent of fatalities.
Eliminate viral training
If we refer to the OSHA and ANSI regulations mentioned above, it’s worth noting that each employee is required to be trained. While it might be tempting to approach training via a viral method; i.e., training a few workers to pass on the information to others, it’s the wrong approach. Just as in a college class, we wouldn’t consider it effective for the professor to teach one student, and have that student pass the information to the next person and so on. Like the children’s “phone game,” the more ears knowledge passes through before it meets its intended recipient, the more opportunity there is for static, misinterpretation, incorrect translation and loss of integrity. Truly effective training is instructor-led and direct to the student, with ample opportunities to clarify information for the greatest learning outcomes.
Baxter Byrd is a technical writer with Pure Safety Group. His primary mission is translating dense regulatory standards to increase understanding and practical applicability.