What You Need to Know:
• All employees working at any leading edge require the use of a fall restraint system, warning line system, or PFAS.
• Skylights and roof openings: an open roof access hatch must have a restraint system (the hatch is treated as a “hole”). Skylights must be rated to hold 4 times the intended load or be covered and/or protected.
• Window, wall openings, and knee walls: all openings on any floor or roof that expose an employee to a 6’ fall or greater need a secure marked cover, a top rail between 42” (±3”), a warning line 16’ back, or the use of a PFAS. Knee walls on roofs and window openings must be a minimum of 39” high.
• Stud placement: if a stud opening is wider than 19 ½ inches, a barricade is required, a CAZ established at 16 feet back, or use of a PFAS.
• Areas at loading docks and chutes are included in this requirement. If removing debris from an elevation using a loading dock or chute, a barricade is required or a CAZ established at 16 feet back. Individuals inside that area must use a PFAS.
• Elevated work platforms: when using a boom lift – ALWAYS utilize a PFAS. For scissor lifts, follow the required policies of the GC or Owner.
• “Safety Monitoring Systems” – although allowed by OSHA, this procedure is NOT allowed on any job sites.
• Level 1 & Level 2 fall protection retractables – understand the difference and how to set up and use each type.
• All employees must be trained on fall hazards. If you are not trained or do not understand fall protection requirements – STOP WORK and ask your direct supervisor.
• Safety professionals and supervisors will evaluate fall prevention and control procedures at least annually to ensure effectiveness.
• All employees will evaluate and inspect any equipment used for fall protection and STOP WORK, remove themselves and others from the hazard, and report it immediately to their supervisor.
Systems: General Requirements & Exceptions
• Trigger Height: Typically 6 feet (10 feet for scaffolding).
• Fall Protection Plan: Required if conventional methods are infeasible or create greater hazards; developed by a competent person with documented alternatives.
• Training: Workers must be trained on hazard recognition, equipment use, inspection, and rescue.
1. Guardrail Systems (Passive)
Height: Top rail 39–45 inches above work level; midrails/screens halfway.
Strength: Must withstand 200 lbs. of force applied downward/outward without deflecting below 39 inches.
Openings: No openings greater than 19 inches wide (excluding walls/structures over 21 inches high).
2. Personal Fall Arrest Systems (PFAS) (Active)
Components: Full body harness, connecting device (lanyard/SRL), anchor point, deceleration device.
Force Limit: Arrest force < 1,800 lbs. (for D-rings).
Free Fall: Max 6 feet.
Deceleration: Max 3.5 feet.
Anchor Strength: Must support 5,000 lbs. or be designed per a qualified person’s criteria.
Inspection: Inspect before each use; remove from service if used in a fall or damaged.
3. Safety Net Systems (Passive) (Not often used in construction)
Placement: Within 8–13 feet horizontally from the work edge, depending on fall height.
Height: Not permitted as primary protection for falls greater than 30 feet.
Key Components of PFAS:
Anchorage: OSHA Standard Subpart M – Fall Protection – 1926.502(d)(15). Anchorages must be independent and capable of supporting at least 5,000 pounds per employee or be designed as part of a complete system under a qualified person.
Review: Anchorage, Body Wear, Connection Device, Fall Distance, Swing, and Clearance.
Anchor Point “Options” and Connections:
OSHA Standard Subpart M – 1926.502(d). Lifelines, lanyards, and deceleration devices must be properly attached to anchorages and harnesses.
OSHA Standard Subpart M – Snap-Hooks – 1926.502(d)(6). Avoid the following unless using approved locking snap hooks:
(i) Direct connection to a horizontal lifeline.
(ii) Two or more snap hooks connected to one D-ring.
(iii) Two snap hooks connected to each other.
(iv) A snap hook connected back onto its own lanyard.
(v) A snap hook connected to a webbing loop or lanyard.
(vi) Improper connection points that allow roll-out.
Considerations When Selecting Connecting Devices:
- Application and environmental conditions (moisture, dirt, grease, oil, acids, hazards, obstructions, temperature).
- Potential fall distance, including device length, deceleration, worker height, and safety factor.
- System component compatibility—components from different manufacturers may not be compatible.
- Product quality and regulations—use high-quality components and follow both OSHA and ANSI standards.
Connecting Devices & Use: Anchor Points, Lanyards & Retractables
Class 1 (Level 1) devices are designed only for anchorage at or above the user’s dorsal D-ring.
Class 2 (Level 2) devices are designed for anchorage above, at, or up to 5 feet below the dorsal D-ring and are rated for leading-edge work with potential free fall up to 6 feet.
It is all about positioning, anchor points, and relationship to sharp edges.
- Don’t grab any lanyard or SRL without confirming it will protect you.
- Don’t use Level 1 (Class 1) lanyards or SRLs for leading-edge work.
- Don’t ignore manufacturer instructions and labels.
- Don’t forget shock-absorbing lanyards are for heights over 18 ½ feet.
- Don’t forget daily inspections are required.
- Don’t ignore signs of wear; if labels are unreadable, remove from service immediately.
- Don’t forget lanyards and SRLs have a limited lifespan of 5 years after being placed in service.
LEVEL 1 – Adequate
LEVEL 2 – Required
Inspections:
Harnesses: OSHA Standard Subpart M – 1926.502(d)(16). PFAS must limit arresting force to 900 pounds with a body belt and 1,800 pounds with a body harness. Systems must be designed and used under supervision of a qualified person with a safety factor of at least two.
Meeting Documentation: Fall Protection Review
I will communicate all known fall protection hazard conditions to my immediate supervisor immediately. If I cannot isolate, eliminate, or protect others from that hazard, I will utilize my “STOP WORK” authority when needed.
