OHS Code Explanation Guide

Published Date: July 01, 2009
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Part 9 Fall Protection

Section 140 Fall protection plan

A fall protection plan is required if work is performed at a work site at which a fall of 3 metres or more may occur and guardrails do not protect workers. Section 8 of the OHS Regulation requires that the plan be in writing and available to workers. The plan must be available at the work site before work with a risk of falling begins. Figure 9.2 shows a sample fall protection plan.

As listed in subsection 140(2), the fall protection plan must specify the following information:

(a) the fall hazards at the work site;
(b) the fall protection system to be used at the work site;
(c) the anchors to be used during the work;
(d) that clearance distances below the work area, if applicable, have been confirmed as sufficient to prevent a worker from striking the ground or an object or level below the work area;
(e) the procedures used to assemble, maintain, inspect, use and disassemble the fall protection system, where applicable; and
(f) the rescue procedures to be used if a worker falls and is suspended by a personal fall arrest system or safety net and needs to be rescued.

A fall protection plan is required if a travel restraint system is being used. Rescue procedures are not necessary in this case since a worker will not fall and be left suspended in the air.

A unique fall protection plan need not be created for each work site. If an employer faces the same fall hazards at multiple work sites, and the fall protection equipment and rescue procedures are identical at each work site, then a single plan applicable to all the work sites is acceptable. Alternatively, an employer can create a single fall protection plan that covers all of the fall hazards likely to be encountered during normal operations. Only in the event of a unique work situation arising would a new or amended fall protection plan be required.

Workers affected by the fall protection plan must be trained in all its elements and the plan must be made available to them.

Where a fall protection plan is not necessary

A fall protection plan is not necessary for

(1) permanent work areas equipped with guardrails, and
(2) situations involving the use of a boom-supported elevating work platform or the use of a fork-mounted elevating work platform intended to support a worker. These situations leave no choice as to the means of fall protection, and the rescue of a worker on the platform is generally straightforward – the platform can simply be lowered.

Figure 9.2 Sample fall protection plan

Fall Protection Plan

Workers sign the second page of this form to acknowledge that they have
reviewed and understand this fall protection plan.
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Fall Protection Plan

Workers must be trained in the safe use of fall protection equipment and the procedures they must follow to ensure their personal safety while using this equipment. This training must include the procedures to assemble, maintain, inspect, use and disassemble the fall protection system or systems in use (refer to section 15 of the OHS Regulation). Workers expected to rescue a worker who has fallen and is suspended by a fall protection system must be trained in rescue procedures. These procedures should be practiced at regular intervals.

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Rescue after a fall

The OHS Code requires written rescue procedures. After an arrested fall, the fallen worker remains suspended in mid-air from his or her full body harness, awaiting rescue. In most cases, the worker is not injured and can alter body position within the harness to be more comfortable.

Unfortunately, a worker suspended in a near upright position with the legs dangling in a harness of any type is subject to what has come to be known as “suspension trauma”. This is one of the reasons that the fall protection plan must include rescue procedures.

Suspension trauma death is caused by orthostatic incompetence. A soldier standing almost motionless at attention for a long period of time and then fainting is an example of the problem. What happens with orthostatic incompetence is that the circulation of blood is reduced because the legs are immobile and the worker is in an upright position.

Gravity pulls the blood into the lower legs, which have a very large storage capacity. Enough blood eventually pools in the legs that return blood flow to the right side of the heart is reduced. This causes blood supply problems for both the heart and the brain. Normally the person faints at this point and falls to the ground. Now that the person is horizontal, blood from the legs flows back to the heart and on to the rest of the body.

While suspended in a harness however, the worker cannot fall into a horizontal position. The worker’s problem is that he or she is being held vertical while motionless. Fall victims can slow the onset of suspension trauma by pushing down forcefully with the legs, by positioning their body in a horizontal or slightly leg-high position, or by standing up. However, the design of the harness, the attachment points used, and the presence of fall injuries may prevent these actions.

The suspended worker faces several problems

(1) the worker is suspended in a near upright posture with legs dangling;
(2) the safety harness straps exert pressure on leg veins, compressing them and reducing blood flow back to the heart; and
(3) the harness keeps the worker in a near upright position, regardless of consciousness.

Rescue must happen quickly to minimize the dangers of suspension trauma. According to information summarized in the July 2008 issue of the Journal of Occupational and Environmental Medicine, suspension trauma begins within 3.5 to 10 minutes in most subjects, with a few very fit subjects developing symptoms after 30 minutes. This time increases significantly if the suspended person can move their legs against resistance during suspension.

Symptoms have been described as starting with a feeling of general physical discomfort, then intense sweating, nausea, dizziness, and hot flashes. Symptoms progress to difficulty breathing, increasing heart rate, and progressively worsening heart function. Eventually the person loses consciousness. A person who is motionless and suspended in a harness is considered to be a medical emergency.

If a worker is suspended long enough to lose consciousness, rescue personnel must be careful in handling such a person or the rescued worker ay die anyway. This post-rescue death is apparently caused by the heart’s inability to tolerate the abrupt increase in blood flow to the right side of the heart after removal from the harness. Current recommended procedures are to take from 30 to 40 minutes to move the victim from kneeling to a sitting to a laying down position. A physician should examine the rescued victim. Among other things, the reduction in blood flow while suspended can affect the kidneys and lead to permanent damage. For more information about suspension trauma, readers are referred to the sources listed below.

A motionless, suspended victim suggests serious injury and a rescue must be performed quickly. A non-breathing, motionless victim must be ventilated within four minutes of when they stop breathing in order to prevent irreversible brain damage.

For more information

Harness suspension: review and evaluation of existing information
A very comprehensive review of the topic, prepared for the Health and Safety Executive, United Kingdom.
Will your safety harness kill you?

Schwerha JJ. Workers at Height are Required to Use Fall Prevention Systems. What are the Health Risks From Being Suspended in a Harness? Journal of Occupational and Environmental Medicine. Vol. 50(7), July 2008.

Commentary on the use of 911 for rescue

In the case of rescues involving workers in confined spaces and workers suspended in the air after a fall, calling 911 alone and awaiting the arrival of rescue services personnel is considered to be an insufficient emergency response. The employer must have some basic level of on-site rescue capability — see section 55 for confined spaces — in the event that rescue services personnel are delayed or unable to attend the scene.

In some situations, rescue services personnel may not have the equipment or skills to perform a rescue e.g. a worker in a confined space deep below ground level in a horizontal tunnelling operation or a worker suspended 100 metres above ground level following the failure of a swingstage scaffold. In such cases the employer’s on-site rescue capability must be such that the work site is virtually self-sufficient in returning a rescued worker to safe ground.

While calling 911 may be part of a rescue response, Workplace Health and Safety expects an employer to have some means of basic rescue capability at the work site. Basic means of rescue may include

(a) having access to a manlift or scissor lift at the work site that is capable of reaching a suspended worker. Someone must be able to competently operate the equipment;

(b) having ladders on site that are capable of reaching a suspended worker;

(c) equipping workers with leg loop extensions for their full body harnesses i.e. suspension relief straps. These attach to the full body harness, providing foot loops into which a suspended worker can place his or her feet and then raise the legs. Doing so allows blood pooling in the legs to circulate. Using the foot loops may help the worker to remain comfortable until he or she returns to safe ground;

(d) from above the fallen worker’s suspended position, having a worker lower a loop of rope into which the worker can place his or her feet and then stand up. As in (c), the goal is to make the worker more comfortable by relieving the pressure of the harness straps on the legs and offering the legs something to push against to pump pooled blood back into circulation. Using the loop may help the worker to remain comfortable until he or she returns to safe ground. It may also allow the worker to connect to a descent system followed by disconnection from the fall arrest system;

(e) using Type 3 self retracting devices that include an integral hand winch that allows the suspended worker to be raised upwards or lowered to safe ground. Use of this device does not require the suspended worker to be conscious; and

(f) equipping workers in certain situations with self rescue devices such as specialized descenders that allow the suspended worker to remove themselves from their lanyard and descend to safe ground using one of these devices.

If a work platform or personnel basket is suspended from a crane or hoist, a fall protection plan must be in place for the rescue of the occupant(s) in the event that the crane or hoist is unable to lower the work platform or personnel basket.