Fall Protection

Guardrail system on overpass by E18 parking lot

Fall protection equipment notices

3M™ issued a Stop Use/Recall Notice for DBI-SALA® ShockWave™2 Arc Flash Shock Absorbing Lanyards 3M issued a Product Advisory for select DBI-SALA® ExoFit™ XP Arc Flash Harnesses 3M issued a Stop Use and Inspect Notice for Protecta® Self-Retracting Lifelines *Read additional safety notices in the EQUIPMENT SAFETY NOTICES* section of this page.**

Falls are among the most common causes of serious work-related injuries and deaths. The University of Washington, through the UW Fall Protection Program Manual, is committed to protecting employees and others from fall hazards through safe design, hazard elimination, engineering controls, safe work practices, training, and personal protective equipment when necessary.

If a fall hazard cannot be eliminated, effective fall protection shall be planned, implemented, and monitored to control the risks of injury due to falling. According to Washington State Department of Labor and Industries regulations, regardless of the fall distance in Washington State, ALL employers have a duty of care to protect employees from being exposed to serious injury or death while working at heights, including above or adjacent to dangerous equipment or machinery.

Whether you work in a shop, laboratory, office, research facility, medical center or you are just walking on campus, you must be protected from fall hazards. The following major areas covered by the UW Fall Protection Program Manual may not include all situations where fall hazards exist and need to be addressed.

Fall protection requirements

Identifying fall hazards involves recognizing any work process, activity or situation with the potential to cause injury or harm to a person due to a risk of falling when working at heights. The hazards must always be identified, risks assessed, and the proper controls put in place prior to starting work and when changes to work activities are planned or occur. Use the Job Hazard Analysis (JHA) template (Word) to identify hazards and controls to manage the risk of fall hazards.

The five levels in the hierarchy of fall protection controls are listed below.

Temporary guardrails at Mechanical Engineering building

Hazard elimination is the first and best control to protect employees from fall hazards. The controls in this list are progressively less protective, with Administrative Controls being the least protective.

Hazard Elimination: Evaluating the design to eliminate fall hazards or changing the task, process, controls, or other means to remove the need for any employee to be exposed to a fall hazard.
Passive Fall Protection: Fall protection that does not require the wearing or use of personal fall protection equipment. An example is a guardrail system.

Fall restraint system

Fall arrest system on horizontal lifeline
Fall Restraint: The technique of securing an employee to an anchorage using a full body harness and lanyard short enough to prevent the person’s center of gravity from reaching the fall hazard.
Personal Fall Arrest System: A system comprised of, at a minimum, an anchorage, full body harness, lanyard, and connectors used to arrest an employee from free falling more than six feet in a fall from an elevated level.
Administrative Controls: Employer mandated safe work practices or procedures that prevent exposure to a fall by signaling or warning an employee to avoid approaching a fall hazard. Examples include warning lines and safety monitors.

Fall Protection Work Plan

A written and approved fall protection work plan is required when working at heights greater than 10 feet (with some exceptions).

Use the Fall Protection Work Plan template to document your plan.

Type of fall protection system to be used and procedures for setup, inspection, ongoing monitoring and removal
Procedures for securing tools and equipment for overhead protection
Method planned for prompt, safe rescue and removal of injured workers
Employee training on the fall protection work plan
Inspection of fall protection equipment prior to work
Necessary approvals

Walking-working surfaces

A walking-working surface is any horizontal or vertical surface on or through which an employee walks, works or gains access to a work area. According to the Bureau of Labor Statistics, slips, trips and falls are the leading cause of workplace fatalities and injuries. Falls from heights and on the same level are historically among the leading causes of serious work-related injuries at the University.

Walking-working surfaces need to be inspected periodically to ensure that they are free of hazards.
Guardrails or appropriate fall protection must be provided where required.

Ladders

Portable and fixed ladders are used by many employees for various tasks at the University. Falls from ladders are one of the leading causes of occupational injuries according to the Occupational Safety and Health Administration. Instead of using a ladder to access or work at an elevated height, consider using a mobile scaffold or mobile elevating work platform.

If a ladder must be used for a job:

Select the appropriate ladder.
Inspect it thoroughly.
Use it properly.

Refer to the Ladder Safety focus sheet (PDF) for detailed information about selecting, inspecting and using ladders safely.

Scaffolds

Scaffolds are temporary elevated platforms that support employees or materials and can be supported or suspended.

Supported scaffolds can consist of one or more platforms supported by rigid means such as outrigger beams, brackets, poles, legs, uprights, posts or frames.
Mobile scaffolds are supported scaffolds that are on casters or wheels.
Suspended scaffolds are working platforms suspended by ropes, chains, or lifting gear and capable of being raised and lowered by mechanical means. Suspended platforms can be classified as permanent and temporary.

Employees must be protected from fall hazards on all scaffolds, and protected from falling objects from above.

Before starting work each day, a Competent Person must complete a Scaffold Pre-Use Daily Inspection to verify the scaffolding is safe for work.

Mobile elevating work platforms (MEWPs)

Mobile elevating work platforms (MEWPs) include:

Scissor lifts and vertical personnel lifts, where the elevating work platform cannot be positioned beyond the base of the unit. The guardrail around the work platform is the main fall protection system. Personal fall protection may be required for certain activities.
Aerial lifts, and boom, telescoping and articulating lifts, where the work platform can be positioned beyond the base of the unit. Personal fall protection is always required on these lifts.

Prior to using a MEWP, inspect the MEWP to verify it is safe for work.

Roof activities

A fall protection system is required when employees are exposed to fall hazards of 4 feet or more to the ground or lower level.

The best fall protection on a roof is a parapet wall or permanent guardrail system 42 inches (plus or minus 3 inches) high at the roof edge.

Fall protection must be provided on unguarded roofs when employees and others need to access the roof and do work.

Use the Roof Access Permit Template to control contractor access to conduct work on the roof of a University building.

Window cleaning/suspended maintenance operations

Window cleaning and building facade maintenance workers must pay close attention to all parts of their fall protection system. This includes ensuring that rigging points, lifelines and working lines are in good condition and properly attached. Having adequate and certified anchorage points is critical when working suspended at any height on buildings.

What you need to know

Provide the necessary resources to ensure the implementation and maintenance of the fall protection program.
Identify areas at UW owned and leased facilities where there is a risk of serious injury due to falling.
Appoint Competent Person(s) to assess fall hazards, develop, implement and evaluate fall protection work plans.
Appoint Qualified Person(s) to design, engineer and maintain fall protection systems as required.
Ensure employee(s) are trained to identify and control fall hazards.
Know and follow the UW Fall Protection Program Manual.
Approve alternative fall protection systems as needed.
Coordinate emergency fall rescue.

Review new or revised Fall Protection Work Plans used by client groups as needed during the planning phase of a project requiring fall protection safeguards.
Provide guidance on appropriate fall protection equipment, tie-off points and engineered systems.
Maintain the UW Fall Protection Program Manual and update as needed.
Assure the UW Fall Protection Program is compliant with state and federal regulations, building codes and UW policies, standards, documented procedures and industry best practices.
Conduct periodic and documented audits of the UW Fall Protection Program.
Work with UW Facilities to maintain and update the UW Facilities Design Guide, Architectural and Accessibility Guidelines for design guidance and requirements for safe access and fall protection.

Read and understand fall protection controls, systems, procedures and work plans.
Attend required training on the procedures for safely working at heights and near fall hazards, and the proper use of personal fall protection equipment.
Inspect and wear the appropriate personal fall protection equipment provided by the University.
Prepare fall protection work plans.
Report all incidents and unsafe conditions.

The roles and responsibilities of Qualified Persons, Competent Persons, Authorized Persons, and employees are different in specific work activities that require fall protection. See the UW Fall Protection Program Manual for details.

Provide the UW point of contact a copy of their company's fall protection program documents for review prior to performing work.
Provide appropriate fall protection systems for company employees as required by law, including but not limited to guardrail systems and personal fall protection systems.
Complete Job Hazard Analyses and Fall Protection Work Plans in accordance with regulatory requirements, standards and industry best practices.
Complete UW Roof Access Permits as required.

Equipment safety notices

3M™ issued a Stop Use/Recall Notice for DBI-SALA® ShockWave™2 Arc Flash Shock Absorbing Lanyards.

3M issued a Product Advisory for select DBI-SALA® ExoFit™ XP Arc Flash Harnesses manufactured between January 2005 and July 2021 due to potential for inconsistent performance during an arc flash event.

3M™ issued a Stop Use and Inspect Notice for select models of Protecta® Self-Retracting Lifelines due to a manufacturing issue that could result in the self-retracting lifeline not engaging properly. University units in possession of 3M™ Protecta® Self-Retracting Lifelines must take immediate action to identify whether the equipment is affected by the manufacturing issue. Review the instructions in the notice to identify the manufacture date and lot number, and perform an inspection if needed.

3M™ issued a Product Advisory for DBI-SALA® Delta™, ExoFit™, ExoFit™ Plus & ExoFit™ XP Cross Over Style Harnesses due to certain models not meeting the ANSI Z359.11, Section 3.2.2.3.1 dynamic requirement on the front (sternal) D-ring. This non-compliance of the ANSI requirement affects specific part numbers on harnesses manufactured before May 1, 2021.

3M issued a Stop Use and Inspection Notice for specific versions of the 3M™ DBI-SALA® Nano-Lok™ Self Retracting Lifeline with Anchor Hook due to the potential for the equipment to be assembled with an unformed top swivel eye rivet, which may become displaced from the top swivel eye and could result in severe injury or death. University units in possession of a 3M™ DBI-SALA® Nano-Lok™ Self Retracting Lifeline with Anchor Hook should immediately remove the product from service until an inspection is performed.

3M Fall Protection issued a Product Advisory to notify users of the 3M™ PROTECTA® PRO-Stop™ Single Leg & Pro™ Pack Twin Leg Shock Absorbing Lanyards are not consistently meeting the OSHA requirements for breaking strength. During internal testing of certain PRO-Stop™ and Pro™ Pack lanyard models manufactured before December 1, 2020, 3M found that a small percentage of tested units did not meet the OSHA 1926.502 (d)(9) static requirement of achieving 5,000 pounds minimum breaking strength. The University must provide and install fall protection equipment that complies with the OSHA standard. University units with PRO-Stop™ and Pro™ Pack lanyard models should check the part numbers and model numbers listed on the Product Advisory and follow instructions provided on the 3M website. If you have any questions regarding this notice, please contact the 3M Fall Protection Customer Service Team at 3musfpserviceaction@mmm.com or call 833.638.2697.

3M™ Fall Protection has identified a potential manufacturing issue with a limited number of 3M™ Protecta® Rebel Self-Retracting Lifelines (with galvanized or stainless-steel lifelines) produced between October 14, 2019 and February 25, 2020. This manufacturing issue could result in the SRL not engaging properly but can be easily detected through the pre-use inspection as specified in the Protecta® Rebel Instruction for Use (IFU) document. University units in possession of this fall protection equipment should immediately inspect the equipment according to the instructions in the Inspection Notice. Impacted part numbers can be found on the 3M website.

STOP USE NOTICE: 3M™ Fall Protection Specific DBI-SALA® Delta™ & Exofit XP™ Arc Flash Harnesses

3M announced an immediate Stop Use and Product Recall Notice for its 3M™ DBI-SALA® Self-Rescue Descent fall protection systems manufactured before July 2020. 3M identified a potential cracking issue in the inner rope spool that may occur as a result of embrittlement over time of the plastic inner rope spool in all models; and after repetitive descents of the training model. This issue could impact the ability of a user to descend in the event of a fall. University units in possession of 3M™ DBI-SALA® Self-Rescue Descent fall protection systems (part numbers 3320030, 3320031, and 3320037) should immediately remove these products from service. Read the complete Stop Use and Product Recall Notice on the 3M website.

3M™ issued a Stop Use and Product Recall Notice to replace any 3M™ DBI-SALA® Delta™ Arc Flash Web Loop Rescue Safety Harnesses and 3M™ DBISALA® ExoFit™ XP Arc Flash Rescue Web Loop Harnesses with specific part/model numbers were produced during a specific date range. University units in possession of a 3M™ DBI-SALA® Delta™ Arc Flash Web Loop Rescue Safety Harnesses or a 3M™ DBISALA® ExoFit™ XP Arc Flash Rescue Web Loop Harnesses should follow the instructions in the Stop Use and Product Recall Notice to identify whether the harnesses are affected. If any harnesses are confirmed to be affected, remove the unit from service immediately and contact 3M Fall Protection Customer Service Team (contact information is listed in the Appendix).

Climbing Technology issued a Request for Inspection of the ROLLNLOCK pulley/rope clamp due to a defect in the functioning of the sheave position lever (part F in the image below), which can lead to an accidental locking of the lever. As a result of this defect, when using the device in “hauling pulley” mode, the lever may inadvertently engage the pin, suddenly disabling the locking function and releasing the load or person. Products with batch numbers 0120, 0220, 0320, 0121 and 0221 are affected.

University units in possession of ROLLNLOCK pulley/rope clamps should check the batch number on the product to confirm whether it is a defective product. If you are in possession of a defective product, immediately remove it from service and contact Climbing Technology at commerciale@aludesign.it or vendite@aludesign.it for a replacement.

Harken Industrial™ issued a Product Inspection Notice for CMC CLUTCH™ units after identifying a number of units that may have shipped without the stainless steel Friction Shoe installed. While a missing Friction Shoe does not present an immediate safety concern, there may be impacts to long-term device durability and performance.

University units using fall protection systems with a CMC CLUTCH are instructed to inspect all 11 mm and 13 mm CLUTCH units following the instructions on the Product Inspection Notice to confirm whether the Friction Shoe is installed.

If your CLUTCH is missing its Friction Shoe, or if you have any questions, please contact the CMC Customer Support team by calling 800.513.7455 or 805.562.9120, or send an email to info@cmcpro.com.

CMC CLUTCH unit with and without Friction Shoe — Source: gravitec.com

Honeywell issued an Immediate Mandatory Inspection Notice for users of Miller® MightEvac and MightyLite Self-Retracting Lifelines. Any University unit in possession of this equipment must read the inspection notice and carefully follow the instructions. Failure to do so many result in serious injury or death.

Honeywell has identified a potential issue with reworked brake components on specific model numbers that may cause the products to not operate to specification. The inspection notice steps include:

Step 1: Look for the model number on the product label and date of manufacture.

Step 2. If the model number is listed in Table 1 and the equipment was repaired between 9/1/2019 and 3/5/2021, perform the pre-use inspection of the braking mechanism as described in the inspection notice.

In the event of a malfunction, or if you have any questions, please contact Honeywell Repair Center at 1-800-873-5242 (option 5) or email hsprepairs@honeywell.com.

MSA issued a User Safety Notice to inform you that MSA has received field reports of a limited number of Latchways Standard Self-Retracting Lifelines (SRL) in which some internal bolts came loose.

MSA is advising all customers remove from service and return to MSA for rework any Latchways Standard SRL with a part number shown in User Safety Notice AND a manufacturing date from 05/2020 to and including 12/2020.

Petzl issued a Safety Alert after identifying two defects causing rope slippage while using the ZIGZAG, ZIGZAG PLUS and ZILLON fall protection equipment. University units using ZIGZAG, ZIGZAG PLUS and ZILLON products are asked to perform a manual inspection and function test of this equipment to detect any possible slippage.

Two defects were identified that cause premature wear of the release levers, resulting in slippage that can be observed after a few months of use, or even on new products. The affected equipment is for the following products: ZIGZAG (D022AA00), ZIGZAG PLUS (D022BA00), ZILLON (L22A 025, L22A 040, L22A 055) with serial numbers between 18L 0000000 000 and 21G 0000000 000.

Follow the instructions in the Safety Alert. If the results of these tests are not satisfactory, immediately stop using your product and return your product by contacting your local after-sales service center listed on the Petzl website.

What you can do to stay safe

UW employees should:

Attend required training provided for all work that may have a fall hazard.
Ask for training if unsure about procedures or equipment.
Always use designated controls, safe work practices and proper personal protective equipment when working at heights.
Follow fall protection work plans.
Know accident and rescue procedures.
Inspect fall protection equipment before each use; do not use if not deemed safe.

Services available

EH&S provides the following services:

Conduct and advise on fall protection training
Advise on job hazard analysis and fall protection work plans
Consult on fall protection controls and safe work practices
Recommend specific personal protective equipment when working at heights

More information

General fall protection

WAC 296-24 Working surfaces, guarding floors and wall openings, ladders

WAC 296-24-88050 Personal fall arrest system

WAC 296-155, Part C-1 Fall arrest and fall restraint

WAC 296-800-260 Floor openings, floor holes, open-sided floors, walkways and platforms

OSHA 1910.28 Walking Working Surfaces

ANSI/ASSE Z 359 The Fall Protection Code

Scaffolding

WAC 296-874 Scaffolds

Mobile elevating work platforms

WAC 296-869 Elevating Work Platforms

ANSI A92 Vehicle Mounted Elevating and Rotating Work Platforms

Window Cleaning

WAC 296-878-15025 Personal fall arrest systems

WAC 296-24, Part J-3 Personal fall arrest systems

WAC 296-24-88050 mandatory Appendix C, Part I Personal fall arrest systems

ANSI/IWCA I-14 Window Cleaning Safety Standard

Ladders

WAC 296-876 Ladders, Portable and Fixed

Frequently asked questions

Yes. Walking-working surface regulations require that employers inspect walking-working surfaces regularly and correct, repair, or guard against hazardous conditions. This includes walkways, stairways and any areas where people work or travel to or from their work area.

Many factors may contribute to slips, trips and falls (e.g., poor lighting, housekeeping, poor drainage, or needed repairs). Contact UW Facilities to address issues on the Seattle campus.

If you need to use a stool or step ladder, ensure it is in good condition and appropriate for the task.

Before using fall protection on a conventional portable step ladder, consider safer access such as a mobile elevating work platform (MEWP), scaffold or portable platform ladder. If it is not possible, a personal fall protection system is required while using a ladder:

Anytime a worker is on a ladder greater than 24 feet off the floor
Working on a ladder at or above 10 feet off the floor (to the worker’s feet) where both hands are occupied with a task. Some short-term light work may be permitted if it does not affect maintaining balance on ladder. A Competent Person should review and approve the Fall Protection Work Plan before work begins.
If the worker is turned around on the ladder, or an excessive amount of reaching or leaning is necessary to conduct the task.

The anchor point for personal fall protection on a ladder must be determined by a Competent Person, be located overhead, and meet the requirements for anchors.

Refer to the LADDER section in the UW Fall Protection Program Manual for more details.

According to Washington Administrative Code (WAC) regulations and American National Standards Institute/American Society of Safety Engineers (ANSI/ASSE) standards, anchorages attached to personal fall arrest systems shall be capable of supporting at least 5,000 lbs. for each person attached, or shall be designed, installed, and used as part of a complete personal fall arrest system that maintains a safety factor of at least two, under the supervision of a Qualified Person.

Depending on the application and work environment, the basic rule is:

If you are working below 17.5 feet you should use a self-retracting lanyard.
If you are working above 17.5 feet you can use an energy-absorbing lanyard or a self-retracting lanyard. When using an energy-absorbing lanyard, you need to be anchored at least 17.5 to 18 feet above the ground or lower level to ensure proper clearance. If mobility is a requirement, self-retracting lanyards have a wider range of movement and minimize trip hazards as the lanyard is always pulled taut under retraction tension.

Fall clearance is the minimum vertical distance a worker needs in the event of a fall to safely arrest the fall and avoid striking the ground or an object below.

Factors to consider include:

Deceleration distance
Height of the worker
Whether a shock-absorbing lanyard or self-retracting lanyard is being used.

A correct calculation is critical tfor a safely arrested fall and avoid serious injury. Diagrams and formulas for calculating fall clearance are on page 4 of the Fall Protection Work Plan.

If the distance between the anchorage point and the nearest obstruction is less than the calculated fall clearance distance, the fall arrest system cannot effectively protect a worker from the dangers of a fall from height.

A swing fall is a pendulum-like motion that can occur when a worker falls and their connector device is in a position located horizontally away from the anchorage point and not directly above the worker. In such situations, swing fall distance must also be considered. Because a swing fall generally lengthens the overall vertical fall distance, clearances must be adjusted.

The term “100% fall protection” means that, at all times when a person is exposed to fall hazards, they must be protected by an active or passive fall protection system. An example is when a person working on an aerial lift, who is tied off to an anchor on the platform, must leave the platform to work at another location with a fall hazard. The worker needs to wear a “Y” lanyard so they can connect to an anchorage at the new location and transfer while still connected to the platform anchor. Alternatively, a guardrail system can be set up at the new location prior to transfer.

Definitions

An individual knowledgeable of fall protection equipment, including the manufacturer's recommendations and instructions for the proper use, inspection, and maintenance; and who is capable of identifying existing and potential fall hazards; and who has the authority to take prompt corrective action to eliminate those hazards; and who is knowledgeable of the rules contained in this part regarding the installation, use, inspection, and maintenance of fall protection equipment and systems