Frequently Asked Questions
Question 1: Is e-learning or computer based fall protection training enough to satisfy the minimum OSHA requirement?
You will find that when it comes to something as complex as fall protection, the answer is not always a simple YES or NO.
OSHA requires employees to be trained by a Competent Person to recognize the hazards of falling and learn procedures that mitigate fall risks.
The employee must not only display adequate knowledge, but also complete hands-on training exercises on how to properly select, inspect, assemble and use fall protection equipment, furthermore, the employee must be able to select the correct anchor for the anchor point.
The employee must attend physical demonstrations that simulate on- site conditions.
Like any training program, employers should understand requirements of the work being conducted and plan their training accordingly. The ANSI/ASSE Z359 Fall Protection Code — specifically, ANSI/ASSE Z359.2-2007 (Minimum Requirements for a Comprehensive Managed Fall Protection Program) — provides employers with more direction about how to set learning objectives for fall protection training programs. Once an assessment of training needs is conducted, the manner in which the training is delivered can be addressed.
Minimum requirements for fall protection training are outlined in the following standards and regulations:
OSHA 1926.503(a)(2) OSHA 1926.503(c)(3)
ANSI Z359.2 (3.3.1.5) ANSI Z359.2 (3.3.6.2) EM385.
The term “Competent Person” is used in many OSHA standards and documents. An OSHA “Competent Person” is defined as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them” [29 CFR 1926.32(f)]. By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person.
Question 2: How often is refresher training required?
A. Federal OSHA requirements are based on knowledge and not time. OSHA outlines specific circumstances when retraining is required, including changes on the jobsite or in the types of fall protection systems or equipment.
B. ANSI, on the other hand, requires refresher training every two years in fall protection classes and every year for personnel assigned to perform rescues after a fall.
Do you have a rescue plan?
If you have any reason to believe that a trained employee does not have the understanding and skill required, it’s your responsibility to ensure the employee is adequately retrained.
Question 3: Does Part 1926 Subpart M require that personal fall arrest systems be inspected by a competent person?
The inspection of personal fall arrest systems required in §1926.502(d) (21) does not have to be performed by a “competent person.”¹ However, §1926.503(a)(2) states:
The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas:
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(ii) The correct procedures for . . . inspecting the fall protection systems to be used.
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Therefore, under §§1926.502(d)(21) and 1926.503(a)(2) (ii), the equipment must be inspected prior to each use by an employee who has been trained by a competent person to do the inspection.
Also, under §1926.502(d)(19), a competent person must inspect personal fall arrest equipment to determine that personal fall arrest systems and components subjected to impact loading are undamaged and suitable for reuse²:
Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse.
It is industry standard practice to remove from use and destroy any component of a PFAS involved in a fall.
Always refer to the manufacturers Instruction/Specification Manual.
Question 4: When can I use a Fall Protection Plan
Answer:
1926.502(k) Fall protection plan
This option is available only to employees engaged in leading edge work, precast concrete erection work, or residential construction work (See 1926.501(b)(2), (b)(12), and (b)(13)) who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. The fall protection plan must conform to the following provisions.
1926.502(k)(1)
The fall protection plan shall be prepared by a qualified person and developed specifically for the site where the leading edge work, precast concrete work, or residential construction work is being performed and the plan must be maintained up to date.
OSHA 29 CFR 1926.32(m) defines a qualified person as an individual “who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.”
1926.502(k)(2)
Any changes to the fall protection plan shall be approved by a qualified person.
1926.502(k)(3)
A copy of the fall protection plan with all approved changes shall be maintained at the job site.
1926.502(k)(4)
The implementation of the fall protection plan shall be under the supervision of a competent person.
1926.502(k)(5)
The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.
1926.502(k)(6)
The fall protection plan shall include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. For example, the employer shall discuss the extent to which scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling.
1926.502(k)(7)
The fall protection plan shall identify each location where conventional fall protection methods cannot be used. These locations shall then be classified as controlled access zones and the employer must comply with the criteria in paragraph (g) of this section.
1926.502(k)(8)
Where no other alternative measure has been implemented, the employer shall implement a safety monitoring system in conformance with 1926.502(h).
1926.502(k)(9)
The fall protection plan must include a statement which provides the name or other method of identification for each employee who is designated to work in controlled access zones. No other employees may enter controlled access zones.
1926.502(k)(10)
In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents.
[44 FR 8577, Feb. 9, 1979; 44 FR 20940, Apr. 6, 1979, as amended at 45 FR 75626, Nov. 14, 1980; 55 FR 47687, Nov. 14, 1990; 59 FR 40733, Aug. 9, 1994; 60 FR 5131, Jan. 26, 1995]
1926.501 Duty to have fall protection.
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(b) (1) * * *
(2) Leading edges. (i) Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of §1926.502.
Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with §1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems
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(12) Precast concrete erection. Each employee engaged in the erection of precast concrete members (including, but not limited to the erection of wall panels, columns, beams, and floor and roof “tees”) and related operations such as grouting of precast concrete members, who is 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems, unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of §1926.502.
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(13) Residential construction. Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of §1926.502.
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As stated in the three provisions above, §1926.502(k) sets out specific requirements for fall protection plans; however, §1926.502(k) does not require pre-planning meetings.⁴