9 NS Fall Protection Safe Work Procedures and Plans

In any work area where fall protection is required, unless a person working at height is protected by a permanent guardrail or is working from a guarded elevating work platform, a written safe work procedure is required where the max fall distance is less than 7.5 m.

Written fall-protection safe-work procedure^[1]

Section 21.3 (3) from the Nova Scotia Workplace Health and Safety Regulations

3. A fall-protection safe-work procedure must be based on a hazard assessment of the work typically performed by the employer and must include all of the following information:
   1. the nature of the work to be performed;
   2. the typical duration of the work;
   3. a description of the work;
   4. a list of the primary tools or equipment used in the work;
   5. reference to applicable health and safety legislation and regulations;
   6. a list of potential fall hazards of the work and their associated risks;
   7. the risk controls to be used to prevent injury to persons coming in contact with known hazards;
   8. the effect of weather conditions;
   9. the name of the person or position that has supervisory responsibility for the work, whether the person
   10. the training and qualifications required for persons who will perform the work, as determined by the employer;
   11. a method for communicating the fall-protection safe-work procedure to any person who may be affected by the procedure.

For a specific work area where fall protection is required, unless a person working at height is protected by a permanent guardrail or is working from a guarded elevating work platform, a written safe work plan is required where the max fall distance is 7.5 m or more. See s21.4 of the NS Workplace Health and Safety Regulations (WHSR) for full details.

WHSRs S21.4

3. A fall-protection safe-work plan must be established based on a hazard assessment of the specific work to be performed in the work area and must include all of the following information:
   1. the nature of the work to be performed;
   2. the anticipated duration of the work;
   3. a description of the work;
   4. a list of the primary tools or equipment to be used in the work;
   5. reference to applicable health and safety legislation and regulations;
   6. a list of potential fall hazards of the work and their associated risks;
   7. he fall-protection system or systems to be used at the work area;
   8. any anchorages to be used during the work;
   9. if a fall-arrest system is to be used, confirmation that the clearance distances below the work area are sufficient to prevent a person from striking
      1. the nearest safe surface or water,
      2.  a surface or thing that could cause injury to the person on contact, or
      3. exposed hazardous material, such as an open tank, pit or vat;
   10. a procedure to address the risks associated with the potential for swing as a result of anchorage placement when a person is using a fall-arrest system;
   11. the procedures to be used to assemble, maintain, inspect, use and disassemble a fall-protection system, as applicable;
   12. schedules for inspecting any fall-protection systems and the names of any persons responsible for carrying out the inspections;
   13. adequate written rescue procedures to be used if a person falls and requires rescue, including if a person is suspended by a fall-arrest system or personnel safety net;
   14. the effect of weather conditions;
   15. the name of a designated competent person to supervise the work area;
   16. the training and qualifications required for persons who will perform the work, as determined by the employer;
   17. a method for communicating the fall-protection safe-work plan to any person who may be affected by the plan.
4. If a workplace has more than 1 work area for which a fall-protection safe-work plan is required, an employer may create a separate plan for each specific work area or one overall plan for the workplace that includes all of the requirements necessary for each specific plan.

Guidance from Nova Scotia FAQ document^[2]

Question: According to the Workplace Health and Safety Regulations, in Section 21.3(1) a fall protection safe work procedure is required when working from below heights of 7.5m and in Section 21.4 (1) a safe work plan is required for heights at 7.5m and above. Do you need both a procedure and a plan for the same worksite if you are working both below and above 7.5m? Can this procedure and plan be combined into one document with more detail/information being given to meet the needs of a plan?

Answer: There is no requirement to have both a safe work procedure in accordance with Section 21.3 and a safe work plan under 21.4 at the same worksite. They are meant to have different applications. The safe-work procedure is intended for the company that does regular work at multiple sites where they typically would not exceed 7.5 metres. A safe-work plan, on the other hand is meant for site-specific work at heights where there is more risk and may involve a longer and more elaborate requirement, such as the building of multiple story condo, or office building. It is recognized that, at a site where there is a risk of falling a distance of 7.5 metres or more, there will also be personnel working at heights greater than 3 metres, but less than 7.5. The regulation did not intend that the employer would require both a safe-work procedure (at say 4 metres) and a separate plan (at 8 metres). This would be too literal an interpretation of the regulation. If a safe-work plan is created for a site, it is meant to include anyone that is at risk of falling from any height at that site. Since the plan requirements are more stringent than those of a procedure, it is expected that the plan would cover all work conducted both below and above 7.5m without the need for a separate procedure for work below 7.5 m.

Federal Fall-protection Plans

12.06 (1) If there is a risk of injury due to falling in any of the circumstances described in paragraphs 12.07(1)(a), (b) or (c) in a work place, the employer must, before any work activities begin,

1. 1. develop a fall-protection plan in consultation with the work place committee or the health and safety representative; and
   2. ensure that a copy of the fall-protection plan is readily available at the work place for consultation.
2. The fall-protection plan must specify
   1. the hazards that have been identified for each work area and each activity to be carried out at the work place;
   2. the fall-protection systems that have been chosen to protect against the identified hazards;
   3. if a personal fall-protection system is used, the anchorage to be used during the work;
   4. if a fall-arrest system is used, the clearance distance below each work area;
   5. if there are no manufacturer’s instructions with respect to the storage, maintenance, inspection, testing, fitting, installation, use or dismantling of equipment that is used in a fall-protection system and that is provided by an employer, the procedures to be followed for the purposes of paragraphs 12.05(1)(a) to (d); and
   6. the rescue procedures to be followed if a person falls.
3. The fall-protection plan must include, in annex, a copy of any manufacturer’s instructions with respect to the storage, maintenance, inspection, testing, fitting, installation, use or dismantling of equipment that is used in a fall-protection system and that is provided by an employer.

Elevating Work Platforms

Regulations require that elevating work platforms (including scissor and boom lifts) are used and inspected in accordance with the appropriate CSA standard.
Daily, before use inspections are required and the inspection record must include the name and signature of the person who performed it.

Before operating the elevating work platform, fall arrest equipment must be worn and anchored to a suitable anchorage (the specified anchor point, not the guardrail).

Inspection and Maintenance of Fall Arrest Systems

Inspection considerations:

• Before use: all components of the system must be inspected by the competent user.
• Always refer to and follow the manufacturers’ recommendations for care, use and inspection of your fall arrest equipment.
• First two inspection points: labels and load indicators.
• Most components of a fall arrest system must comply with specific CSA standards. When inspecting your equipment, ensure that there is a tag or label confirming compliance. It must be legible.
• You trust your life to this equipment. Remember to inspect every component prior to each use. Respect it, and inspect it carefully!

After a fall: refer to manufacturer’s instructions. Most manufacturers require components must be immediately removed from service and destroyed.

• Fall arrest equipment must be inspected annually, by a competent inspector.
• Equipment that fails inspection must immediately be tagged “Unserviceable” and taken out of service. Follow the manufacturer’s recommendations. Unless equipment is returned to the manufacturer for repair, it must be destroyed and replaced.

Inspection Details

How do you inspect the webbing (body of belt, harness or lanyard)?

• Inspect the entire surface of webbing for damage. Beginning at one end, bend the webbing in an inverted “U.” Holding the body side of the belt toward you, grasp the belt with your hands six to eight inches apart.
• Watch for frayed edges, broken fibers, pulled stitches, cuts or chemical damage. Broken webbing strands generally appear as tufts on the webbing surface.
• Replace according to manufacturers’ guidelines.

What should you know about hardware (forged steel snaps, “D” rings)?

• Inspect hardware for cracks, dents, bends, rust, signs of deformation, or other defects.
• Replace the belt if the “D” ring is not at a 90 degree angle and does not move vertically independent of the body pad or “D” saddle.
• Make sure that any hardware is not cutting into or damaging the belt or harness.
• Inspect tool loops and belt sewing for broken or stretched loops.
• Inspect snaps for hook and eye distortions, cracks, corrosion, or pitted surfaces. The keeper (latch) should be seated into the snap nose without binding and should not be distorted or obstructed. The keeper spring should exert sufficient force to close the keeper firmly.

How do you inspect the buckle?

• Inspect for loose, distorted or broken grommets. Do not cut or punch additional holes in waist strap or strength members.
• Check belt without grommets for torn or elongated holes that could cause the buckle tongue to slip.
• Inspect the buckle for distortion and sharp edges. The outer and center bars must be straight. Carefully check corners and attachment points of the center bar. They should overlap the buckle frame and move freely back and forth in their sockets. The roller should turn freely on the frame.
• Check that rivets are tight and cannot be moved. The body side of the rivet base and outside rivet burr should be flat against the material. Make sure the rivets are not bent.
• Inspect for pitted or cracked rivets that show signs of chemical corrosion.

How do you inspect the rope?

• Rotate the rope lanyard and inspect from end to end for fuzzy, worn, broken or cut fibers. Weakened areas have noticeable changes in the original rope diameter.
• Replace when the rope diameter is not uniform throughout, following a short break-in period.
• The older a rope is and the more use it gets, the more important testing and inspection become.

What should you look for during the safety strap inspection?

• Inspect for cut fibers or damaged stitches inch by inch by flexing the strap in an inverted “U.” Note cuts, frayed areas or corrosion damage.
• Check friction buckle for slippage and sharp buckle edges.
• Replace when tongue buckle holes are excessively worn or elongated.

Inspection Notes

After a fall

Any component of a fall arrest system that has arrested a fall must be immediately removed from service. Refer to manufacturer’s instructions. Most manufacturers require components must be immediately removed from service and destroyed.

Care of Fall Arrest Equipment

Basic care of all safety equipment will prolong the durable life of the unit and will contribute toward the performance of its vital safety function. Proper storage and maintenance after use are as important as cleansing the equipment of dirt, corrosives, or contaminants. Storage areas should be clean, dry and free of exposure to vapours or corrosive elements. Avoid extended or unnecessary exposure to the sun and other sources of UV radiation.

• Cleaning nylon or polyester webbing: Remove all surface dirt with a sponge dampened in plain water. Squeeze the sponge dry. Dip the sponge in a mild solution of water and commercial soap or detergent. Work up a thick lather with a vigorous back and forth motion; then wipe with a clean cloth. Hang freely to dry, but away from excessive heat.
• Drying: Equipment should dry thoroughly without close exposure to heat, steam, or long periods of sunlight.

Rescue Planning

A person should never work alone when using a fall arrest system. It is important not to overlook how a worker will be rescued if he/she falls. Workers who have had an arrested fall may be unconscious and injured. They may not be able to rescue themselves. Rescue planning addresses these concerns. The employer is responsible for developing a rescue plan and the workers are responsible for knowing and understanding it.

• Before workers use a fall arrest system, the employer should develop a written rescue procedure. The Joint Occupational Health and Safety Committee or Safety Representative should be consulted.
• A victim must be retrieved as quickly and safely as possible.
• If a victim is not breathing, you have approximately 4 minutes before there is permanent brain damage. If a victim is breathing but unconscious, you have a 10 – 15 minutes before discomfort may become injury.

Suspension Trauma

• Suspension trauma (otherwise known as orthostatic intolerance) can occur when a person remains at height, after a fall, for even short periods of time.
• Suspension in a harness may cause blood to pool in the legs, which can result in unconsciousness; if not rescued promptly, serious injury or death may occur.
• Anyone who has developed suspension trauma is also at risk from reflow syndrome – caused when the pooled blood in their legs is allowed to flow quickly back into the body. It is potentially fatal. A person who has had an arrested fall and has been suspended in a harness for any significant length of time should not be placed in a horizontal position too quickly.
• Treating someone with these conditions is not basic first aid. Call 911 when there is an arrested fall and have paramedics on the way.

Rescue Planning Options

There are 4 possibilities:

• Self rescue
• Ad-hoc rescue bu co-workers and others
• Rescue by a trained on-site team
• Rescue by a fire department