Working at Heights

(Fall Protection Standard)

Code #: Author: Tony Ogunsanya Approvers: Miguel Arenas Rev. No. [0]
HSE-S-02
Reviewers: Arturo Tepale Rev. Date
Tecotl

Content
1. Scope and Applicability ...................................................................................................................................... 2
2. Purpose ................................................................................................................................................................ 2
3. Roles and Responsibilities .................................................................................................................................. 2
4. Definitions and acronyms................................................................................................................................... 6
5. Standard and Guidance ........................................................................................................................................... 7
5.1 Fall Protection Program Requirements .................................................................................................... 7
6. Key performance indicators (KPIs) .................................................................................................................... 13
7 Training & Evaluations ..................................................................................................................................... 14
7.1 General Training Requirements ............................................................................................................. 14
7.2 Specific Training Requirements ............................................................................................................. 15
8 Continuous Improvement ..................................................................................................................................... 18
8.1 Program Evaluation and Improvement ........................................................................................................ 18
9 References ........................................................................................................................................................ 18
10 Revision history ................................................................................................................................................ 18

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 1. Scope and Applicability
This standard defines the safety requirements relating to work conducted at heights at Orbia
Polymer Solutions sites. This standard applies to all employees and contractors at Orbia
Polymer Solutions sites. Where a specific requirement of this standard differs from the
requirements of applicable local or national standard, the most restrictive requirement governs.

2. Purpose
OSHA estimates that each year, approximately 200,000 serious injuries occur in the US from
falls in the workplace, including hundreds of fatalities.

The purpose of this standard is to establish minimum requirements of a fall protection program
that enables the management of Orbia Polymer Solutions to identify, evaluate and control fall
hazards in the workplace while reducing the likelihood of significant injuries from workplace
falls. This standard applies to all sites and in work situations under the control of Orbia Polymer
Solutions.

3. Roles and Responsibilities

3.1 Site Manager is responsible for the development, implementation, and management of the
fall protection program within their site, and shall:

3.1.1 Provide adequate and timely resources to support the program.

3.1.2 Appoint a Program Administrator to direct, manage, implement, and evaluate the
program.
3.1.3 Protect authorized persons from fall hazards and ensure continuous fall protection while
working at heights in an area under their control.

3.2 Fall Protection Program Administrator shall possess the knowledge, training, and
experience to direct, manage, implement, and evaluate the fall protection program. In
addition, the program administrator shall:

3.2.1 Ensure the fall protection program satisfies all local regulations and standards, and that
appropriate equipment are available for the type of work at heights occurring under their
purview.
3.2.2 Establish and assign program responsibilities outlined in this standard to individuals.
3.2.3 Recognize limitations of authorized people to work at heights and take actions to ensure
that an authorized person’s limitations are not exceeded.
Note: The limitations of authorized persons to work at heights should be considered on a
case-by-case basis according to the training needs assessment in Section 7.1.1

3.2.4 Ensure that procedures are developed for every location where an active fall protection
system is used.

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 Note: Procedures should cover every fall hazard to which authorized persons may be
exposed, but similar hazards requiring identical control measures may be grouped together.

3.2.5 Ensure a procedure to identify new fall hazards is established and implemented.
3.2.6 Ensure that rescue plans conducted by employees or with assistance from contractors
are coordinated to ensure successful rescue event.
3.2.7 Ensure and verify training for all personnel involved in the fall protection program.
3.2.8 Determine the frequency of periodic inspections according to the environment where
equipment is being used, frequency of use, and manufacturer instructions. The frequency
of periodic inspections of fall protection shall be at least once annually.
3.2.9 Advise and provide guidance to architects, engineers, planners, and designers during the
planning phases of projects to address fall hazards that could be encountered by
employees when the project is completed in accordance with the fall protection
hierarchy.
3.2.10 Ensure investigation of the fall protection program related incidents.

Note: Investigations of incidents may include reviewing incident reports, implementing

corrective measures to eliminate causal factors, and preparing necessary report.

3.3 Qualified Person shall, through education, and professional experience have the
knowledge and understanding of applicable fall protection regulations, standards,
equipment and systems, physical sciences, engineering principles, and mandatory
requirements for equipment and systems used at the site. In addition, the Qualified Person
shall:
3.3.1 Supervise the design, selection, installation, use and inspection of certified anchorages,
permanent systems, and horizontal lifelines.

Note: While anchorages and horizontal lifelines are installed and used under the control and
supervision of the qualified person. The qualified person does not need to be physically present
whenever the systems are used or inspected. However, the qualified person is required to ensure
that the systems are installed and used correctly. This may involve field verification of
installation and use.

3.3.2 When supervising the design, installation, or selection of an active fall protection
system, the qualified person shall ensure the requirement of this standard are met.

3.4 Competent Person is responsible for the immediate supervision, implementation, and
monitoring of the fall protection program.

Note: The competent person is usually a supervisor or a shift lead in a position of authority and
with experience in fall protection as it relates to the work that the authorized persons perform.

3.4.1 The competent person shall conduct a fall hazard survey to identify all potential fall
hazards before authorized persons are exposed to those hazards. In addition, the
competent person shall:

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 3.4.2 Prepare, update, review, and approve procedures as directed by the program
administrator. Review procedures as workplace activities change to determine if
additional practices, procedures, or training should be implemented before work at
heights continues.
3.4.3 Specify in procedures the selected systems, including anchorage locations, connecting
means, body supports, and equipment that authorized persons are required to use when
they are exposed to fall hazards.
3.4.4 Supervise the selection, installation, use, and inspection of anchorages in consultation
with the program administrator and qualified person.

Note: Some local jurisdictions require that the installation of anchorages to structures shall
be supervised by individuals who are licensed as professional engineers in that jurisdiction.

3.4.5 Verify that fall protection systems have been installed and inspected according to
program requirements.
3.4.6 Verify that clearance is adequate before work begins.
3.4.7 Identify, evaluate, and impose limits on the workplace activities to control fall hazards.
These limitations shall be communicated to all authorized persons.
3.4.8 Verify authorized person training is complete and applicable procedures are in use prior
to the commencement of work at heights.

Note: This section is not intended to require an authorized person to review procedures
every time before work begins. The frequency of the review should depend on how often the
work is performed, its complexity, the work environment, the skills of the worker, and other
variables. The review should be frequent enough to keep the authorized person adequately
informed about the procedures.

3.4.9 Assist the program administrator in establishing limitations of authorized people and
take action to ensure that work does not exceed those limitations.
3.4.10 Ensure that a prompt rescue of authorized persons can be performed.
3.4.11 Have the authority to stop work immediately and take prompt corrective measures to
mitigate fall hazards.
3.4.12 Inspect fall protection equipment or ensure before-use inspections occur in accordance
with manufacturers’ instructions.
3.4.13 Remove from service all equipment, systems, and components that do not pass
inspection, are damaged, or impacted.

3.5 Authorized Person shall follow the site’s policy and procedures and the instructions on the
specific systems and equipment in use. In addition, the authorized person shall:

3.5.1 Notify the competent person of unsafe work practices or hazardous conditions or actions
that may cause injury to either themselves or others before commencing work at
heights.

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 3.5.2 Use, inspect, store, and care for equipment and systems in accordance with program
procedures.
3.5.3 Remove from service and notify the competent person of any equipment that does not
pass a before-use inspection.

3.6 Competent Rescuer shall develop rescue procedures before the authorized persons start
work activities at heights. In addition, the competent rescuer shall:

3.6.1 Verify that all authorized rescuers have been trained and are proficient at performing
rescue.
3.6.2 Identify hazards associated with rescue from heights and the required procedures
necessary to mitigate the hazards within the area of the rescue.
3.6.3 Identify the resources needed to conduct a safe and effective rescue from heights and
verify that those resources are available.
3.6.4 Inspect rescue equipment before it is put into service.
3.6.5 Verify that equipment is stored or staged appropriately and protected from workplace
conditions that may damage the equipment.
3.6.6 Evaluate rescue procedures at least annually through rescue drills.

Note: Competent rescue responsibilities may be fulfilled by employees, emergency services, in-
house professionals, or contract services.

3.7 Authorized Rescuers shall perform or assist in rescues of personnel suspended, or

attached to, fall protection systems in accordance with site procedures. In addition,
authorized rescuers shall:

3.7.1 Review rescue procedures before rescue begins.

Note: It is recommended that authorized rescuers participate in the development of rescue

procedure(s).

3.7.2 Inspect rescue equipment prior to activities that may require rescue, verify that all
equipment is in working condition, and securely store equipment until needed.

3.8 Trainers are responsible for training in accordance with the requirements of this standard.
In addition, trainers shall:

3.8.1 Be familiar with the fall hazards, regulations, standards, and equipment used at the site
they are instructing.
3.8.2 Conduct training needs assessment to determine training content using the resources of
the fall protection program (e.g., fall hazard assessment, manufacturer’s instructions,
procedures, and rescue plans).

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 3.8.3 Evaluate the knowledge, skills, and abilities of trainees according to the
requirements of this standard.

4. Definitions and acronyms

4.1 Active Fall Protection System. A fall protection system that requires authorized persons to
wear or use fall protection equipment.
4.2 Authorized Person. A person assigned by Orbia site management to work at heights where
there is a potential for a fall hazard.
4.3 Authorized Rescuer. A person assigned by Orbia site management to perform rescue from
fall.
4.4 Certified Anchorage. An anchorage that a qualified person certifies to be capable of
supporting the design load encountered during use.
4.5 Clearance Requirement. The distance below an authorized person that ensures the
authorized person is clear of any objects that would cause injury in the event of a fall.
4.6 Competent Person. An individual who through training and experience can identify,
evaluate, and address any potential fall hazard, and is designated and authorized by Orbia
site management to take prompt corrective action with regards to such hazards.
4.7 Competent Rescuer. An individual designated by site management who by training,
knowledge and experience can implement, supervise, and monitor fall rescue plans.
4.8 Continuous Fall Protection. One or more fall protection systems that provide fall protection
without interruption.
4.9 Fall Arrest. The action or event of stopping a free fall or the instant where the downward
free fall is stopped.
4.10 Fall Arrest System. An active fall protection system where a collection of equipment is
configured to stop a free fall.

Note: A fall arrest system is typically comprised of components such as harnesses, lanyards,
deceleration devices, horizontal lifelines, vertical lifelines, anchorages, and anchorage
connectors. Configured and used properly, they will arrest a free fall in accordance with the
requirements of this standard.

4.11 Fall Hazard. Any condition in the workplace that exposes a person to a potential fall of four
feet or more.
4.12 Fall Hazard Survey. A process that collects information regarding existing or potential fall
hazards.
4.13 Fall Protection. Any equipment, device or system that prevents an accidental fall from
elevation or reduces the effect of such a fall.
4.14 Fall Protection Procedure. A series of logical steps that describes the specific practices,
equipment, and methods to be used for the protection of authorized persons from falling
when exposed to fall hazards.
4.15 Hazard Elimination. Methods to prevent exposure to fall hazards.
4.16 Inspection. An examination to assess the function and condition of equipment or systems.

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 4.17 Inspection, before use. An inspection of equipment conducted prior to use by the
authorized user to assess equipment function and condition.
4.18 Periodic Inspection. An inspection conducted by a competent person (other than the user)
at least once a year to determine the function and condition of an equipment.
4.19 Non-Certified Anchorage. An anchorage selected that is estimated to be capable of
supporting the loads encountered during use.
4.20 Passive Fall Protection System. Fall protection that does not require the wearing or use of
personal fall protection equipment, such as, fixed work platforms with guardrails.
4.21 Performance Assessment. A form of evaluation that requires trainees to demonstrate
understanding of the subject matter by performing a task rather than answering questions.
4.22 Qualified Person. A person who has extensive training, knowledge, and experience in the
fall protection and rescue area who can design, analyze, evaluate, and specify fall
protection and rescue systems to the extent required by this standard.
4.23 Rescue. The process of removing a person from danger, harm, or confinement to a safe
location.
4.24 Swing Fall. A pendulum-like motion that occurs during and/or after a vertical fall from a
position that is located horizontally away from a fixed anchorage.
4.25 Travel Restraint System. An active fall protection system that limits travel in such a
manner as to prevent the user from a fall hazard.

5. Standard and Guidance

5.1 Fall Protection Program Requirements
5.1.1 A site fall protection program conforms to this standard if it includes all requirements of this
section. Where a specific requirement of this standard differs from the requirements of
applicable local or national standard, the most restrictive requirement governs.
5.1.2 A policy statement that provides general goals and emphasizes the site’s commitment to
providing a safe working environment for all employees and contractors working at heights
and exposed to fall hazards.
5.1.3 Establish requirements and assign responsibilities for the identification, evaluation, control
of, and rescue from existing or foreseeable fall hazards at the site.
5.1.4 Establish the responsibilities of all personnel involved in the development, management,
implementation, monitoring, maintenance, and evaluation of the site’s fall protection
program in accordance with Section 3.
5.1.5 Establish requirements for training and evaluation of personnel in accordance with section
7.
5.1.6 Ensure that fall hazards are assessed and documented in accordance with section 5.2.
5.1.7 Ensure the application of the fall hazard hierarchy of controls in accordance with section 5.3.
5.1.8 Ensure fall protection and rescue procedures are established in accordance with section 5.5.
5.1.9 Ensure the implementation and management of requirements in accordance with section
5.6.
5.1.10 Establish requirements for investigation and reporting of all fall-related incidents in
accordance with section 5.7.

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5.1.11 Provide periodic fall protection program evaluation in accordance with section 8.
5.1.12 If a site management determines that any of the requirement in this section is not feasible,
the site shall develop an alternative requirement that provides an equivalent or higher level
of protection. The site program administrator shall develop and maintain documentation
that explains why the standard requirement is not feasible and demonstrates the
equivalency or superiority of the alternative requirement.

5.2 Fall Hazard Survey

5.2.1 A fall hazard survey (referred to as “survey” henceforth in this standard) shall be
conducted to identify each fall hazard to which an authorized person may be exposed.
Information collected shall be reported to the program administrator.

Note: The survey provides information regarding fall hazard type, basic configuration of the
hazard, exposure, frequency, height, solution(s) and rescue. The survey should generate a
list of the fall hazards from highest to lowest priority. This will allow for priority of focus on
associated risk from highest to lowest risk.

5.2.2 The survey shall be conducted by a competent person or qualified person who is familiar
with, and has access to, information about local work processes, regulation, environmental
factors, policy, and industry practices.
5.2.3 The survey shall identify paths of travel and fall hazards along such paths. Locations and
distances to obstructions in potential fall paths, including swing falls.
5.2.4 The survey shall identify environmental factors that may affect the installation, use,
inspection, maintenance, storage, and dismantling of any fall protection system. The survey
shall as a minimum identify the presence of:

 Hot objects, sparks, flames, and heat-producing operations.

 Hazardous chemicals that could potentially affect the authorized person or the fall
protection system and components.
 Electrical hazards.
 Environmental contaminants of any form.
 Sharp objects and abrasive surfaces.
 Moving equipment and materials.
 Unstable, uneven, and slippery walking/working surfaces, unguarded openings.
 Climatic and weather factors.
 Other materials or circumstances which could adversely affect the fall protection
system.
 Foreseeable changes in any of these conditions taken singularly or collectively.
5.2.5 The fall hazard survey shall collect information regarding fall hazards to include, where
applicable and available:

 Reason for the exposure.

 Severity of the fall.

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  Occurrence, frequency, and duration of the task.
 Obstructions in the fall path.
 Existing fall protection systems or equipment.
 Access and egress from the fall hazard area
 Environmental conditions.
 Other workers and contractors in the immediate area
 Proximity to the fall hazard.
 History of accidents and incidents related to the task or structure.
 Range of mobility in each fall hazard zone
 Potential anchorage location
 Available clearance
 Potential evacuation, escape, or rescue paths as applicable.
 Number of personnel exposed to fall hazards.

5.2.6 Surveys reports shall be updated whenever there is a change to the task. Process,
structure, equipment, or regulation that would render past surveys obsolete. The report
shall contain a revision identifier to ensure the most current version is discernable.

5.3 Eliminating and Controlling Fall Hazards

The site management shall use the fall hazard hierarchy of controls when addressing fall hazards
and designing fall protection solutions for existing and new facilities. In order of preference, the fall
hazard controls are:
a. Eliminating or preventing exposure
b. Passive fall protection
c. Active fall protection (travel restraint and fall arrest)
5.3.1 Elimination or Prevention
Eliminating exposure or preventing fall hazards shall be considered before other fall
protection methods. The program administrator shall not use fall protection methods when
eliminating or preventing the fall hazard is feasible.
5.3.2 Passive fall protection methods shall be used when elimination or prevention method is
not feasible.
5.3.3 Active Fall Protection Systems shall be used when elimination or prevention of the hazard
or passive fall protection methods is not feasible.
[Link] Active fall protection system shall:

 provide continuous protection,

 maximize anchorage height,
 minimize free fall distance,
 minimize swing falls,
 minimize arresting forces,
 minimize clearance requirements.

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5.3.4 Travel Restraint systems shall be used when passive fall protection methods are not
feasible. Travel restraint systems shall:

 Prevent any fall through the entire range of movement.

 Be limited in use on surfaces of up to a maximum slope of 4:12 (18.4 degrees).
 Not allow an authorized person to be suspended.

5.4 Fall Arrest

The program administrator shall only use fall arrest systems when all other methods of fall
protection are not feasible. Fall arrest systems shall:
 Provide continuous protection through the entire range of movement.
 Minimize free fall distances by increasing anchorage elevation and/or limiting the length
of connecting equipment.
 Be used in conjunction with positioning systems when feasible, to reduce the potential
of a fall event.
 Minimize arresting forces as much as possible, not to exceed 1800 lbs. (8KN) per
authorized person.
 Minimize clearance requirements, limiting contact with surrounding structures and any
lower level.
 Provide a means for a suspended employee to reduce the effects od suspension trauma.

5.5 Minimum Requirements for Procedures

5.5.1 Procedures are required whenever authorized persons are exposed to any fall hazard while
using active fall protection systems. The procedures shall be documented and site specific.
5.5.2 Procedures shall specify the equipment and systems for each fall hazard and shall describe
installation, inspection, use, and disassembly.
5.5.3 Fall protection procedures shall be prepared and maintained by the site’s qualified person,
competent person, competent rescuer, and/or program administrator.
5.5.4 Procedures shall be prepared specific to the site and task where they will be used except
where the same procedure can be effectively applied to similar tasks.
5.5.5 Procedures shall provide for continuous fall protection and reference training requirement of
authorized persons permitted to use the system according to section 7.
5.5.6 Procedures shall include:

 Equipment used in the fall protection system.

 Inspection of equipment
 Responsible party for the maintenance of equipment or systems as applicable
 Storage location of equipment
 Identification of anchorages
 Clearance requirements
 A description for the first person installing, or the last person removing the system

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  Use and egress from the system.
 Maximum arrest forces and limitations on use of the system, including the weight range
of users and the maximum number of permitted locations of authorized persons who
may attach to or use the system.
 A rescue plan, including applicable steps and personnel responsibilities.
 Instructions and/or contact information to report incidents and near misses.

5.6 Program Implementation and Management

5.6.1 Fall protection systems and components that do not conform to the requirements of this
standard shall be used only under the directions of a qualified person.

5.6.2 Anchorages - When feasible all anchorages shall be certified by a qualified person
regarding strength, location, and compatibility with associated equipment.
[Link] If the fall protection program administrator deems the use of certified anchorages infeasible,
the program administrator shall consult with authorized, competent, and qualified people to
conduct assessments of non-certified anchorages for use and reference the anchorages in
training and procedures.
[Link] Anchorage Strengths - Anchorages shall have a minimum breaking strength applied in the
directions permitted by the applicable system no less than:
 5000 pounds (22.3kN) for fall arrest systems
 3000 pounds (13.4kN) for positioning systems
 1000 pounds (4.5kN) for travel restraint systems

Note: A qualified person may design and/or certify anchorages that have a safety factor of 2.0
against failure. Qualified persons should also verify that the design loads meet local
requirements. The impact of fall forces on beams, columns, and their supports, other than
anchorages are not addressed by this standard. Under the International Building Code, which
many jurisdictions have adopted as a regulation, a professional engineer is typically required to
evaluate and analyze the structural integrity of beams and columns impacted by fall forces.
Caution should be exercised when selecting and using anchorages for older buildings and
structures so that other structural members will have sufficient capacity to sustain fall arrest
forces without any failure.

[Link] If a travel restraint, positioning, or rescue anchorage may be used as an anchorage for fall
arrest, it shall be designed as a fall arrest anchorage.
[Link] Anchorages for permanent horizontal lifeline systems shall be designed according to
ANSI/ASSP Z359.6, Specifications and Design Requirements for Active Fall Protection
Systems.
[Link] Anchorages for temporary, commercially manufactured, horizontal lifelines shall be used
according to manufacturers’ instructions, be designed by a qualified person, and have a
minimum breaking strength of two times the maximum tension developed in the lifeline
during fall arrest in the direction applied by the lifeline forces.

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[Link] Anchorage for rescue systems shall have minimum breaking strength applied in the
directions permitted by the system of at least 3000 pounds (134kN), specified by a qualified
person and designed according to ANSI/ASSP Z359.6, Specifications and Design
Requirements for Active Fall Protection Systems.

Note: Anchorage may have to sustain a two-person load and could sustain additional dynamic
(impact) loading. Anchorages for rescue should consider all potential dynamic and static load
factors.

[Link] Inspection of Anchorages. Anchorages shall be inspected before each use and periodically
in accordance with site’s procedures. Periodic inspections shall be documented.
[Link] If inspection reveals damage or defect, anchorages shall be repaired or replaced and
recertified by a qualified person before returning into service.

[Link] Selection of Anchorage. Fall arrest anchorages shall be selected that minimize free fall,
swing fall, total fall distances, and prevent contact with an obstruction, lower level, or
object.
[Link].1 Anchorage connectors shall not reduce the anchorage strength below the applicable
level set forth in this section or below the allowable level set by applicable building
codes.
Note: The strength of an anchorage system depends on its components and the adequacy of
the connector(s) attachment to the anchorage. A professional engineer may need to be
consulted to determine the impact of the fall forces on the building structure, based on
applicable building code requirements.
[Link].2 The maximum angle or offset distances shall be in accordance with manufacturer’s
recommendations for swing falls.

5.6.3 Inspection, Maintenance Storage and Care of Equipment shall, at a minimum, be in

accordance with site’s policy and manufacturer's instructions.
[Link] Manufacturer’s instructions and recommendations on the use, inspection, maintenance,
storage, and care of equipment shall be accessible for review by authorized persons who
use, inspect, maintain, or store such equipment.
[Link] Inspections of equipment shall be conducted before use or before shift by the authorized
person to ensure that the equipment is in working order and functional. Any damaged,
impacted, or non-functioning equipment shall be immediately removed from service.
[Link] Periodic inspections shall be conducted by a competent person or a competent rescuer at
least once per year. Periodic inspections shall be documented, and the inspection record
retained for the service life of the equipment.

5.6.4 Removing Equipment from Service. Equipment shall be taken out of service when any
inspection reveals the equipment is damaged or excessively worn, ceases to function, the
inspection interval has been exceeded, or it has been impacted by arresting a fall.
[Link] Equipment taken out of service through the equipment inspection process may be returned
to service if deemed suitable for use by a competent person.

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[Link] Equipment deemed unacceptable for use shall be discarded, returned to the manufacturer,
or kept in a controlled area to prevent reuse.

5.6.5 Maintenance of Equipment. The competent person or competent rescuer shall verify that
equipment is maintained according to the site’s policy.

5.6.6 Storage of Equipment. Equipment storage shall be in accordance with the manufacturer's
instructions.
[Link] Equipment shall be stored in a manner that protects it from exposure to conditions that
could damage it.
[Link] Access to stored equipment shall be limited to those trained in the use of the equipment.

5.7 Incident Investigations

5.7.1 All fall-related incidents shall be reported to the program administrator and the site’s HSE
manager. All incidents shall be investigated promptly. Incident investigation shall consider
all factors that contributed to the event including a review of policies, procedures, training,
fall hazard survey, fall protection procedures, equipment and related systems, and general
communication.

Note: Incidents usually have multiple causal factors. Investigators should consider all causal
factors, direct and indirect, and specifically examine factors that may contribute to unsafe
operations. Examples include tools, equipment, defects in facility design, construction, planning,
environmental factors, and ergonomics. Human factors such as lack of knowledge, skill,
management, communication, procedures, and enforcement of procedures should also be
considered. Personnel trained to conduct investigations and personnel involved in the incident
should be part of the investigation.

5.7.2 Any activity affecting the equipment or work involved in the incident shall cease, and the
work area and equipment secured until the investigators permit activities to resume.
5.7.3 Investigation reports shall be shared across Orbia Polymer Solution sites and retained for at
least five years.

6. Key performance indicators (KPIs)

The following are recommended KPIs. Additional KPIs may be used at the site as needed.

6.1 Operational Discipline – Percent Work at Heights without an emergency or entrant’s

rescue.
6.2 Training - Percent applicable personnel (e.g., Program Administrator, Competent Person,
etc., with up-to-date training in the duties they perform in the Fall Protection program.
(Section 3 & Section 7)
6.3 Recordkeeping – Record of periodic inspection of fall arrest equipment conducted by
competent person/rescuer. (Section [Link])

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7 Training & Evaluations
7.1 General Training Requirements

7.1.1 Training Needs Assessment. Training content shall be determined by a training

needs assessment. The assessment shall be documented and developed according to the
scope of work at the site. It shall include the fall protection methods used, equipment
performance requirements of authorized personnel, and the rescue systems needed, as
determined by the site program administrator.

Note: A training needs assessment is developed to determine the content and depth of training
required. Site management has the responsibility to determine the duration and delivery method
of fall protection training according to specific needs. The training needs assessment will ensure
that the authorized person’s limitations are not exceeded for the tasks to be performed.

7.1.2 Documentation. Training and retraining shall be documented to include the following
information:
 training objectives, content, delivery materials, performance requirements, and
performance assessments
 date, time, location and duration of training or evaluations
 name, title, or description of training
 trainer’s or evaluator's name
 trainees’ names
 training or evaluating organization’s name, and qualifications of trainer(s) (if training
services are provided by an external organization) Commented [A1]: I suggest including the instructor's
 successful completion of performance requirements of trainees based on certificate or qualifications
observation of physical demonstrations of skill or exercises.

7.1.3 Retraining shall be provided as necessary in any of the following situations:

 Changes in the program render previous training obsolete.
 Changes in equipment renders previous training obsolete.
 Changes in the workplace that render previous training obsolete.
 Inadequacies in trainee’s performance indicates lack of knowledge or skills.
 Changes in applicable regulations render previous training obsolete.

Note: Retraining is a responsibility of the site management, which may be triggered by

any of the events listed in this section. The frequency and duration of training required to
remain proficient varies with the number and types of fall protection systems used.

[Link] If none of the conditions listed in 7.1.3 is applicable, the minimum frequency for
retraining shall be conducted as follows:

 authorized person: every two years

 competent person: every two years

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  authorized rescuer: every two years with annual drills
 competent rescuer: every two years with annual drills

[Link] The program administrator may conduct performance assessments on an annual

basis as an alternative to the requirements of [Link]
[Link] A training plan for retraining shall be developed for qualified persons, trainers,
and program administrator to update their education.
[Link] Trainers shall be identified by the program administrator to meet the
requirements established in section 3.8.

7.2 Specific Training Requirements

7.2.1 Training shall be conducted before exposure to a fall hazard occurs for all
personnel.
7.2.2 Training with fall protection and rescue equipment must include:

 Examples of all applicable equipment and systems used with the program.
 Experiential exercises where attendees can inspect, assemble, use, and
disassemble the equipment.

7.2.3 Training for all personnel shall include the following:

 Fall hazard recognition and identification.

 Awareness of the hierarchy of fall protection according to section 7.
 Awareness of fall protection and rescue regulations and standards.
 Their responsibilities under the program.
 Inspection requirements of the program.
 The use of fall protection and rescue procedures within the program.

7.2.4 All personnel shall be trained on the before use inspection, assembly, use,
disassembly, and storage of the following that are applicable to the program,
identified by the needs assessment, and in accordance with equipment
manufacturers’ instructions:

 Certified and non-certified anchorages identified for use.

 Anchorages connectors
 Connectors
 Energy absorbers
 Energy absorbing lanyards
 Full body harness
 Self-retracting devices
 Single anchor lifelines and fall arresters
 Climbing ladder fall arrest systems

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  Horizontal lifelines
 Descent control systems with an independent fall control system
 Winches/hoists and synthetic rope haul systems with an independent fall
protection system
 Passive fall protection systems (e.g., guardrails, covers, barriers, nets)
 Engineered and/or custom fall protection systems and equipment
 Using equipment in travel restraint applications
 Using equipment in fall arrest applications
 Using equipment in positioning applications with an independent fall protection
system
 Maintaining continuous fall protection when using fall protection system
 Estimating and minimizing free fall distances
 Estimating and minimizing swing falls
 Recognize when clearance of a fall arrest system is insufficient.

Note: It is common for people to have more than one designation within a site’s fall
protection program. For example, site management might require competent rescuers to
also be trained as competent person. This determination is made by site management
depending on their needs.

7.2.5 Authorized Person training shall be conducted according to sections 7.2.2

through 7.2.4

7.2.6 In addition to 7.2.2 through 7.2.4, Competent Person training shall include:

 Surveying fall hazards

 Periodic inspection of equipment components and systems
 Developing fall protection procedures
 Selecting and using certified and non-certified anchorages with a focus on
strength and location
 Assessing system component compatibility
 Estimating clearance requirements using maximum deceleration distances of fall
arrest systems
 Principles of fall protection system assembly, focusing on the reduction and
control of connections, free fall distances, arresting forces, swing fall and ease of
rescue

7.2.7 In addition to 7.2.2 through 7.2.4, Program Administrator training shall include:

 Developing and maintaining a fall protection program

 Surveying fall hazards
 The selection and appointment of personnel
 Developing fall protection procedures

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  Development of equipment lists
 Development of engineered systems standards
 Development, implementation, and monitoring of training programs
 Accident/incident investigations
 Evaluating fall protection program effectiveness

7.2.8 In addition to sections 7.2.2 through 7.2.4. Qualified Person training shall
include:

 Surveying fall hazards

 Developing fall protection procedures
 Selecting appropriate equipment and systems in consideration of available
clearance
 Calculating specific clearance requirements for fall arrest systems
 Methods for minimizing clearance requirements
 Designing, selecting, analyzing, and certifying anchorages
 Assessing system component compatibility
 Determining when fall protection systems are infeasible
 Designing new, evaluating existing, and certifying horizontal lifelines
 Determining acceptable swing fall distances
 Determining acceptable impact forces

Note: Qualified persons must be trained according to the tasks expected of them.

7.2.9 In addition to sections 7.2.2 through 7.2.4, Authorized Rescuer training shall
include:

 Rescue system(s) assembly and use

 Before-use inspection of the rescue system(s)
 Principles of rescue system assembly, focusing on the reduction and control of
connections, free fall distances, arresting forces, and ease of rescue

7.2.10 In addition to sections 5.2.2 through 5.2.4 and 5.2.9 Competent Rescuer training
shall include:
 Applicable fall protection and rescue regulations and standards
 Developing rescue plans
 Developing rescue procedures
 Periodic inspection of rescue equipment components and systems

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8 Continuous Improvement
8.1 Program Evaluation and Improvement
The Program Administrator shall ensure that the program is evaluated at periodic intervals
not to exceed two years and include a review of:
 The program policies and procedures
 Personnel responsibilities
 Personnel training
 Survey reports
 A review of fall control measures to determine if existing fall hazards can be
eliminated or controlled using more effective method (see section 7)
 Anchorages
 Inspection, maintenance, and storage of equipment
 Training performance assessments
 Rescue plan and drills
 Consideration for new buildings, facilities, and equipment
 Incident investigations

8.2 The fall protection program shall be evaluated when deficiencies are identified, when there
are audit findings or when incidents occur.
8.3 The program evaluation shall identify the strengths and deficiencies of each element of the
fall protection program along with recommendations for improvement.
8.4 A documented plan of action shall be developed that identifies what changes will be made.
Who is responsible for the changes and when the changes will be completed.
8.5 Program evaluations shall be retained for at least five years.

9 References
9.1 ANSI/ASSP Z359.2-2023 - Minimum Requirements for a Comprehensive Managed
Fall Protection Program

9.2 OSHA 1910.140 - Personal Fall Protection Systems

9.3 OSHA 1910 Subpart D – Walking and Working Surfaces

10 Revision history
Revised on Version
Description of the change Author
(MM/DD/YY) (Number)

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