Published Date: July 01, 2009
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Section 159 Procedures in place of fall protection equipment

This section recognizes that it is not always reasonably practicable for an employer to provide a “hard” fall protection system that uses guardrails, a harness-lanyard-anchor combination or another fall protection system described in this Part. The use of procedures in place of fall protection equipment is based on the employer determining that it is not reasonably practicable to provide a fall protection system for use by workers. The justification as to why it is not reasonably practicable should be noted.

If the use of a fall protection system is practicable, it must be used e.g. if anchor points are available or a fall protection system can be rigged without exposing workers to a greater hazard, then a fall protection system must be used. The option of using an administrative procedure is not intended to allow an employer or worker to avoid using a fall protection system or some type of elevated work platform just because doing so may be inconvenient or take more time than using an administrative procedure.

A procedure-based fall protection system can only be used in the following situations:

(1) installation or removal of fall protection equipment (first person up/last person down) – typical examples may involve installing a fall arrest anchor at the peak of a roof, installing a perimeter guardrail system on a flat roof, installing a portable fall arrest post at height, etc.;

(2) roof inspection – applies to both flat and sloped roofs. Roof inspection includes school staff checking for and retrieving items that have been thrown on a school roof. If it is not possible to remain at least two metres from the edge of the roof while retrieving the object or toy, then a procedure-based approach can be used as long as the conditions listed below are met;

(3) emergency repairs – this does not include normal maintenance and service tasks;

(4) at-height transfers between equipment and structures if allowed by the manufacturer’s specifications – examples include transferring to and from a structure from some type of elevating work platform, an electric utility lineman transferring from a helicopter to a high voltage transmission line, etc.; and

(5) situations in which a worker must work on top of a vehicle or load – section 155 applies in this case.

Workers engaged in these five types of activities at height are exposed to fall hazards for very short periods of time, if at all, since they may be able to accomplish their work without going near a danger zone i.e. within 2 metres of the edge in the case of roofs. Workers engaged in such work are not continually or routinely exposed to fall hazards. As a result, they tend to be very focused on their footing, alert and aware of the hazards associated with falling i.e. more aware of their position than, for example, a roofer who is moving backwards while operating a felt laying machine, or a plumber whose attention is on an overhead pipe and not on the floor edge.

If an employer wishes to use a procedure in place of fall protection equipment, all of the following conditions must be met:

(a) written hazard assessment – a written hazard assessment specific to the work site and work being performed must be completed before work at height begins. This reinforces the requirements of Part 2 for hazard assessment;

(b) written procedures – the procedures to be followed by workers while performing the work must be in writing and available to workers before the work begins. Workers must understand the activity that they are about to undertake. The procedures must be part of the fall protection plan required by section 140;

(c) limit number of workers exposed to fall hazard – the work must be carried out in such a way that minimizes the number of workers exposed to the fall hazard while work is performed;

(d) the work must be limited to light duty tasks of limited duration – the work must be a “light duty task” such as inspection, estimating, or simple emergency repairs e.g. membrane repair on a flat roof (the repair of insulation below the waterproofing membrane is not a light duty task), etc. The work done at each work area within the work site must be less than approximately 15 minutes in duration. While doing the task, the worker should not turn his or her back to the edge and should keep the edge in sight;

(e) worker competency – the worker performing the work must be competent to do so;

(f) use of procedures during inspection, investigation or assessment activities – if procedures are used for inspections, investigations or assessment activities, the activities must take place prior to the actual start of work or after work has been completed. If the activities take place while work is going on e.g. during construction of a roof or structure, the fall protection requirements of Part 9 apply to all workers exposed to a fall hazard. The use of procedures in these circumstances recognizes that before work begins, or after all work has been completed and workers have left the area, there may be a need for building inspectors, owners, etc. to inspect the area and/or the work. All fall protection equipment, such as perimeter guardrail systems or safety nets, may have been removed following completion of the work. The systems need not be reinstalled a second time for inspectors; and

(g) limit worker exposure to additional hazards – the use of a procedure must not expose a worker to additional hazards. Working at height has inherent risks. Exposing a worker to additional hazards and therefore greater potential harm is not an acceptable practice e.g. having a worker free climb a severely sloped metal clad roof to install an anchor at the peak, having a worker inspect a difficult-to-access equipment location that could be inspected from another location using other means i.e. elevating work platform or nearby structure using optical equipment.