If you’re serious about avoiding falls, training should entail more than reading from an OSHA toolbox talk.
According to the Occupational Safety and Health Administration (OHSA), employers are responsible for training any employee who could encounter fall hazards while working. But a significant number of construction companies seem to be falling down on the job.
According to the National Safety Council, this year’s annual Top 10 list of the most frequently cited OSHA standards, which typically changes little from year to year, features a brand new entry: Fall Protection – Training Requirements (1926.503). It has taken up the No. 9 spot, appearing among evergreen violations like Fall Protection – General Requirements (No. 1), Hazard Communication (No. 2) and Scaffolding (No. 3).
In fiscal year 2017, which ended on September 30, OSHA cited construction industry employers 1,523 times for violations of the fall protection training standard, which suggests employers have a lot of work to do when it comes to making sure their employees know how to protect themselves.
"When I hold a session, one of the first questions I ask is what kind of training they've had in the past," said Peter Chocholik, fall protection trainer at United Academy, "and I don't see a lot of it. There's a big gap in the fall protection industry in the U.S. as far as the training part of it."
According to OSHA, a training program must enable each employee to recognize the hazards of falling and train them in procedures for minimizing those hazards. The person doing the training, aka the "competent person," needs to know their stuff. Specifically, the person needs to:
- Understand the nature of fall hazards in the work area
- Know how to erect, maintain, tear down and inspect required fall protection systems
- Know how to use guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones and other protection
- Understand the role each employee plays in fall protection plans and in monitoring the safety of fall protection systems
- Know the limitations on the use of mechanical equipment during work on low-sloped roofs
- Know how to properly handle and store equipment and materials and erect overhead protection
- Understand OSHA's requirements around fall protection
OSHA publishes a guide for training workers on fall protection. But if you’re trying to do the training yourself vs. asking your workers to take a course (check out the benefits of team fall protection training), holding a few toolbox talks likely isn’t enough. United Academy uses these strategies in its classes:
Get hands-on. A critical component of United Academy’s classes is hands-on practice and evaluation session. Chocholik said it reinforces what students learn and helps them retain the information. Some United Academy students complete an online course prior to attending the live session, but Chocholik said the practical component augments the theory. For example, a focus of United Academy’s fall protection class is on how to properly fit a body harness and do a thorough partner check. On the job, this training is invaluable as some pieces of the harness are not visible to the wearer.
Have them say it out loud. Just as hand-writing notes can help with information retention, so can talking out loud. Students in United Academy classes are encouraged to do it while practicing a task during class. "They talk about it as well as do it," said Loretta Foley, United Academy director. "You can remember what you did more so than what you read."
Outline worker accountability. The responsibility for safety lies with workers as well as employers, said Chocholik. “They're the [people] who are ultimately going to get hurt." Good fall protection training should include explaining what an employee’s responsibilities are. For instance, workers need to cooperate with employers by adhering to their fall protection policies and be ready to inform supervisors of unsafe conditions when they see them, Chocholik noted. Workers must also be prepared to stop work until hazards are removed.
Train supervisors, too. Unsafe conditions are not always obvious, even to experienced construction staff. United Academy recommends that supervisors, project managers and others in charge at the jobsite take the training as well.
Students hopefully leave the class realizing they have to pay attention to the details of fall protection every day and routinely practice proper procedures. "They've seen the forces involved," Chocholik said. "They understand they can get hurt if they don't follow the rules. A fall is like winning the lottery. [It only has to] happen once to change your life."