Part 1: Employers: The Minimum Requirements for a Managed Fall Protection Program

Employers have a lot of duties and responsibilities when it comes to at-height workers. Part one of this four-part blog series covers the expectations for employers to keep their workers safer at height—following the national standard that determines the minimum requirements for a comprehensive fall protection program—ANSI Z359.2-2007.

POLICY STATEMENTS:

Employers have a lot of duties and responsibilities when it comes to at-height workers. To begin, it is the employer’s responsibility to create and implement policy statements that provide goals and guidance for a managed fall protection program. These policy statements should emphasize the employer’s commitment to provide a safe workplace for all employees exposed to fall hazards.

ANSI Z359.2 provides a sample policy statement for employers’ general use, but it’s very important to develop your own policy statement to meet the specific needs of your workers, application, and facility. Never-the-less, the following policy statement can be used as an example or even a starting point to help managers develop and implement their own.

The (company name) safety policy is to take every reasonable precaution to protect the health and safety of employees. Implicit in the safety policy is the requirement that employees shall use effective fall protection systems when working in any situation that presents a foreseeable exposure to a fall hazard.

DUTIES AND RESPONSIBILITIES:

Once employers have developed and implemented a sufficient policy statement, they can begin to meet all the duties and responsibilities outlined by ANSI Z359.2. According to the American National Standard, there are a total of eight mandatory responsibilities necessary to meet the minimum requirements:

1. Employers must provide whatever resources are necessary to support their fall protection program in a timely manner.
2. Employers must appoint a program administrator with the required knowledge, experience, training, and authority to lead, manage, and evaluate the employer’s fall protection program.
3. Employers must identify and document fall hazards and eliminate or control all existing and new fall hazards in their employees’ workplace.
4. Employers must write and maintain a comprehensive set of written fall protection and rescue procedures for every location where a fall protection system is used to control a hazard. Fall protection and rescue procedures should be outlined individually, but employers can cover more than one location or hazard when they are sufficiently similar.
5. Employers must inform each authorized person about any potential fall hazard before he or she is exposed to it. This not only applies to job-sites owned and operated by the employer, but it also applies to any location where an authorized person could be exposed to a fall hazard.
6. Employers must provide authorized persons with fall protection at locations owned or operated by the employer. For outside locations, the employer is ASLO responsible for ensuring authorized persons working at those locations are provided with continuous fall protection. There are several ways to accomplish this: employers can train employees to recognize fall hazards in any location and direct them to avoid exposing themselves to those hazards without fall protection; or they can reach an agreement with other employers to ensure visiting employees (like service or delivery personnel) will be provided with the necessary fall protection to do their job safely and effectively.
7. Employers must provide authorized persons with the knowledge and training necessary to operate all active fall protection systems in their workspace.
8. Employers must provide competent persons to supervise any authorized persons who are exposed to fall hazards.