Safety Requirements for Using Fall Protection on Ladders

This document outlines the safety requirements for using fall protection, specifically safety harnesses, when working at heights on ladders. It aims to prevent falls and ensure worker safety by providing comprehensive guidelines and procedures. These requirements are essential for any workplace where employees use ladders at heights, as falls are a leading cause of serious injuries and fatalities.

General Fall Protection Requirements

Fall protection is required when working at heights that could result in injury from a fall, typically around 3 meters (10 feet), but this can vary by jurisdiction. Always comply with local legal requirements for fall protection.
A fall protection plan is essential for identifying fall hazards and implementing measures to prevent injury. This plan should include the selection, assembly, maintenance, inspection, use, and dismantling of equipment like ladders and fall protection gear. Emergency procedures for rescuing fallen workers, including those suspended by their harnesses, must also be included. Fall protection plans must be specific to each site, as a 'one size fits all' approach is not suitable.

Hierarchy of Controls

When addressing fall hazards, implement the most effective measures first. This includes eliminating the need to work at heights altogether or installing fixed barriers such as handrails and guardrails.

Fall Protection Systems

Fixed barriers (e.g., handrails, guardrails)
Surface opening protection (e.g., covers, guardrails)
Warning barriers or control zones
Fall or travel restraint systems (preventing falls from a work position)
Fall containment systems (e.g., safety nets)
Fall arrest systems (stopping a fall before hitting the surface below)

Personal Fall Arrest Systems (PFAS)

Components of a PFAS include a full body harness, lanyard, and a suitable anchorage point. These systems must meet specific requirements to ensure their effectiveness.

Full Body Harness Requirements

Full body harnesses must be approved to specific standards such as:
CSA Standard Z259.10-18, Full body harnesses
ANSI/ASSE Standard Z359.1-2007, Safety requirements for personal fall arrest systems, subsystems and components
CEN Standard EN 361:2007, Personal protective equipment against falls from a height - Full body harnesses
Workers using a personal fall arrest system must wear and use a full body harness.

Lanyard Requirements

Lanyards manufactured after March 31, 2023, must be approved to:
CSA Standard Z259.11-17, Personal energy absorbers and lanyards
ANSI/ASSE Standard Z359.1-2007, Safety requirements for personal fall arrest systems, subsystems and components
CEN Standard EN 354:2002, Personal protective equipment against falls from a height - Lanyards
If tools or corrosive agents are used that could damage the lanyard, it must be made of wire rope or another appropriate material.
When working near energized conductors, lanyards made of conductive material should not be used. Use alternative fall protection methods in such cases.

Shock Absorber Requirements

If a shock absorber or shock-absorbing lanyard is used, it must be approved to:
CSA Standard Z259.11-17, Personal energy absorbers and lanyards
ANSI/ASSE Standard Z359.1-2007, Safety requirements for personal fall arrest systems, subsystems and components
CEN Standard EN 355:2002, Personal protective equipment against falls from a height - Energy absorbers
A personal fall arrest system should include a full body harness and a lanyard equipped with a shock absorber.
A shock absorber may not be required if the fall arrest system is used according to specific guidelines or if the manufacturer of a fixed ladder fall arrest system does not require it.

Connector Requirements

Connecting components like carabiners, D-rings, and snap hooks must be approved to:
CSA Standard Z259.2.5-17, Fall arresters and vertical lifelines
ANSI/ASSE Standard Z359.1-2007, Safety requirements for personal fall arrest systems, subsystems and components
CEN Standard EN 362:2004, Personal protective equipment against falls from a height - Connectors
CEN Standard 12275:1998, Mountaineering equipment - Connectors - Safety requirements and test methods
Carabiners and snap hooks must be self-closing and self-locking, requiring at least two deliberate manual actions to open.
These connectors must be marked with their breaking strength in the major axis.

Ladder Safety Systems

Ladder safety systems should allow the employee to climb using both hands without needing to continuously hold, push, or pull any part of the system.
The connection between the carrier or lifeline and the body harness should not exceed 9 inches (23 cm).
Mountings for rigid carriers must be attached at each end, with intermediate mountings spaced to ensure the system's strength.
Flexible carrier mountings are attached at each end, with cable guides installed at intervals of at least 25 feet (7.6 m) but no more than 40 feet (12.2 m).
The design and installation of mountings and cable guides should not reduce the ladder's structural strength.
Ladder safety systems and their support systems must withstand a drop test of an 18-inch (41-cm) drop with a 500-pound (227-kg) weight without failure.

Falling Object Protection

Toeboards used for falling object protection must be erected along exposed edges of overhead walking-working surfaces to protect employees below.
Toeboards must have a minimum vertical height of 3.5 inches (9 cm) from the top edge to the walking surface.
The clearance or opening above the walking surface should not exceed 0.25 inches (0.5 cm).

Training and Competency

Employees climbing fixed ladders without fall protection must be physically capable of performing the duties, demonstrated through observation or physical examination.
They must complete a training or apprenticeship program that includes hands-on training in safe ladder climbing and be retrained as necessary.
Employees must demonstrate the skill to climb ladders safely through formal classroom or on-the-job training and performance observation.
Climbing duties should be a routine part of their work activity.

Inspection and Maintenance

Fall protection equipment must be regularly inspected and maintained to ensure it is in good working condition. The wearer should inspect their equipment before each use.

Specific Situations and Equipment

On boom-supported elevating work platforms, boom-supported aerial devices, or forklift truck work platforms, workers must use a personal fall arrest system connected to an anchor specified by the manufacturer or certified by a professional engineer.
On scissor lifts or elevating work platforms with similar characteristics, workers should use a travel restraint system consisting of a full body harness and lanyard connected to a specified anchor.
If a worker's movement cannot be adequately restricted by a travel restraint system, a personal fall arrest system must be used.

Fall Protection Plans

A fall protection plan is required if workers may fall 3 meters or more and are not protected by guardrails.
The plan must specify fall hazards, the fall protection system to be used, and the anchors to be used.

Hazard Assessment

Identify areas where falls may occur, such as heights of 3 m (10 ft) or more, or less than 3 m (10 ft) where required due to increased risk.
Assess risks of falling into operating machinery, water, hazardous substances, or through openings.
Ensure all equipment, including ladders and scaffolding, is stable and in good repair.
Verify that workers are trained to recognize and report new fall hazards.

Emergency Procedures

Emergency procedures for rescuing fallen workers, including those hanging in mid-air by their harness, are also needed.

Additional Considerations

Ensure that ladder safety systems are inspected for proper operation and component compatibility before each use.
If a ladder is obstructed, use an alternative means of fall protection.
When working on structures without adequate tie-off points, ensure employees are trained as authorized climbers and that a detailed fall protection plan is in place.

R 408.42910 Fall protection. (cont.)

The planning and inspections shall be performed and documented. The documentation shall be maintained on-site while work is being performed. The documentation shall include the date of the planning and inspection, the name of the competent person performing the planning and inspection, and the site location.

Conclusion

Adhering to these safety requirements is crucial for preventing falls and ensuring the safety of workers using ladders at heights. Regular training, proper equipment, thorough planning, and consistent enforcement of safety protocols are essential components of a comprehensive fall protection program.