Draft outline on developing a fall protection plan
During the month of September FEM has an initiative called Safetember which focuses on reducing injuries and fatalities in the construction industry. This year’s theme is “Working at Heights” and in support of this initiative, the Association dedicates this month’s article to what should be included in a fall protection plan.
FEM statistics show that for the past four years, 15% of all fatalities (average of 11 per year) was caused by falls from different heights.
So let us look at what a fall protection plan is in terms of the Construction Regulations:
Construction Regulation defines fall protection as follows:
"fall protection plan" means a documented plan, which includes and provides for -
(a) all risks relating to working from a fall risk position, considering the nature of work undertaken;
(b) the procedures and methods to be applied in order to eliminate the risk of falling; and
(c) a rescue plan and procedures;
Construction Regulation 10 requires a fall protection plan to be developed to manage fall risk on a project. What’s a fall risk in terms of the Construction Regulations? "fall risk" means any potential exposure to fall either from, off or into;
For practical purposes, you could break down your fall protection planning into ten sections, with each section responding to a component towards compliance with Construction Regulation 10.
These sections relate to your Fall Protection Policy; Work Site and Job Conditions; Fall Risk Assessment; Legal Appointments; Training Management; Health Management; Equipment Management; Operating Procedures; Emergency Procedures; Review and Amendments.
Fall Protection Policy
Your policy should include a statement on how the employer will meet statutory requirements, such as the OHS Act, national or international standards (SANS, ISO, etc), industry standards (professional body, such as the Institute for Work at Height), and corporate standards.
Working at Heights Site Information
Gather and collate relevant information on the site such as; who, what, when, where, how. Part of the information gathering process includes:
o Notification of Construction Work in terms of CR4.1 (b), submitted to DOL seven days prior to commencement of construction work; ( Only if you are a direct PC)
o Contact Information of relevant management staff, contractors, and emergency services;
o Worksite location/s, address/es, GPS coordinates, road and site access points;
o Method statement, with a description of the site, project phases, jobs, access methods and equipment requirements. What fall arrest or rope access equipment will be used, how you would gain access, scaffolding positions and methods, equipment applications.
Fall Risk Assessment
A detailed baseline risk assessment must be performed by a competent person (CR9.1 and CR10.2 a), including;
v Identify hazards and risks (including training and behaviour) to which your employees may be exposed
v Analyze and evaluate the risks and hazards
v Document your plan and work procedures to remove, reduce and manage the risks and hazards.
The risk assessment must be communicated to all employees by the competent risk assessor or fall protection planner. Risk assessments must be monitored and reviewed in response to significant changes in plan, equipment, or staff.
Managerial Legal Appointments
Appointments required by the OHS Act, relevant to work at height, including:
Ø Fall Protection Planner CR 10.1 (a), registered with IWH
Ø Risk Assessor CR9.1
Ø Rescuer CR10.2 (e)
Ø Equipment Controller CR10.2 (d)
Ø Rope Access Technician CR18.7
Ø Fall Arrest Technician CR10.2 and 10.4 (b)
Ø Rope Access Supervisor CR18, 1.
Refer to The Institute for Work at Height (IWH) registration requirements for each designation applicable. Appointees must be competent in terms of the definition of a competent person in the Construction Regulations.
Training Management
The applicable training must be identified per designation and appointment letters must state the required training. Records of training must be kept and identified on a training matrix.
Health Management
Relevant employees must have a valid COF (certificate of fitness) or medical fitness certificate. A medical fitness register must be kept with details and expiry dates of the COF.
Work at Height Equipment Management
According to CR10.2 (d) and 10.4 (c)(i), there must be a procedure for inspection, testing and maintenance of all each kind of fall protection equipment. Refer to SANS 50365: 2008 /EN 365: 2004;
Equipment Inventory for different types of equipment, with unique numbering, age, quantity and status. Inventory records must be kept at the equipment storage.
Booking-in and booking-out documents by the equipment controller, with copies at the stores as well as in the fall protection plan file.
Inspection records for intervals not exceeding 3 months of all equipment on the inventory list, kept at the stores.
Pre-use inspection records by users, with records on file.
Defective equipment reported to the appointed person (CR8,7), who reports to the Equipment Controller. Replace defective equipment and amend the inventory list.
Work at Height Operating Procedures
Refer to training manuals, equipment instructions, manufacturer’s recommendations, industry best practices, company procedures, client specifications, as well as CR10.4 and CR10.5, to draft this part of your operating procedure.
Height Emergency Procedures
A site-specific rescue plan should include:
· Standard or specific fall arrest rescue procedures, and responsible people
· Standard or specific rope access rescue procedures, and responsible people
· First aid procedures
· Emergency services contact details and the kind of information they require
· Incident reporting procedures and document formats (Annexure 1 and WCL2)
Fall Protection Review
Include a review process to follow if there is any:
ü Change in worksite
ü Change in employees or contractors
ü Change in scope of work
ü Incidents
ü Change in legislation or periodic review.
ü A review register must be kept and changes to the plan must be recorded.
Compile a site-specific fall protection plan considering:
The risk assessment
Site conditions and access methods (scaffolding, rope access, MEWP, etc)
Required fall arrest equipment;
• Required training per Unit Standard and registered by IWH;
• Emergency procedures based on equipment used, access methods and the level of training your employees to have.
Your written fall protection plan should be reviewed before work begins on any job site. It is recommended that you have a sheet for employees to sign at the job site stating that they have been trained and understand the fall protection plan. Having weekly safety meetings where fall protection equipment and safety procedures are reviewed can also help ensure that your employees stay as safe as possible.
Providing this information to all helps carry out our mission of educating the community to protect the workforce and save lives. We hope that you can utilize this when drafting up a fall protection plan for your company or organization to keep your workers safe.
Neil Enslin | Occupation Health and Safety Manager
Sources:
· MBSA Construction Health and Safety Manaul
· Construction Regulations 2014
