Acquisition Safety - Fall Protection
Every year, work-related falls from elevations result in numerous critical injuries. These potential risks are common to construction and maintenance of many DOD/Navy facilities, systems and equipment, but, can be mitigated through the system safety process and early integration of control measures into design. FALLS ARE THE LEADING CAUSE OF DEATH IN CONSTRUCTION, but also affect maintenance activities on large platforms such as ships and aircraft.
The OSHA website reports that in 2010, there were 264 fall fatalities (255 falls to lower level) out of 774 total fatalities in construction. OSHA has created a special emphasis program https://www.osha.gov/stopfalls/index.html focusing upon the facts that These deaths are preventable and that Falls can be prevented and lives can be saved through three simple steps-plan-provide and train- each of which has particular relevance to the system safety process and DOD/Navy requirements for life-cycle risk management: While the OSHA website should be consulted for guidance related to construction activities and maintenance of existing facilities, supplemental considerations should be integrated into planning for, design and support of DOD/Navy platforms (such as ships and aircraft), facilities and related equipment.
An additional factor, recognition, is needed in optimal management of DOD systems.
Recognition of risk is required in the earliest stage of needs assessment. Requirements (capabilities) documents and planning documents should predict and recognize the potential for falls from elevated work areas as a factor to be considered and mitigated in design. For example, request for proposals (RFP) should indicated that safety and health controls in design and construction as a factor to be considered in review of proposals necessary to optimize cost and risk management. System safety planning includes a predictive process, preliminary hazard identification, consistent with military standard 882 Tasks (guidance for contract deliverables) 101 and 201. Where feasible, fall hazards and other risks, should be eliminated through design substitution and elimination.
Planning for management of know hazards should begin in the earliest feasible stages of design
Provide necessary control measures both during construction and in design for support/sustainment of facilities and defense systems.
Train users of the system regarding the presence of hazards and procedures for safe operation. All defense systems are required to include training materials for their users as part of the “deliverable” components of the system.
The U. S. Department of Labor, Bureau of Labor Statistics lists falls to a lower level as the second most frequent cause of work-related fatalities (after highway incidents).
Review of US Occupational Fatalities from the U. S. Department of Labor, Bureau of Labor Statistics www.bls.gov
|Fraction due to falls
Review of several years’ data suggests a gradual increase in the fraction of fatalities due to falls. This may be consistent with overall reduction in occupational fatalities, but a relatively constant level of fatal falls. Falls accounted for 13% of all workplace fatalities (714) in 2002, but crept up to 15% by 2012. Review of the narratives from OSHA fatality data between 1991 and 2001 indicated that approximately 15% of recorded shipyard fatalities were due to falls from heights.
The risk of falling from heights is inherent to Navy ship construction (drydocks) and aircraft maintenance sites and to any shipboard and shore facility work spaces containing scaffolds, platforms, weapons systems, auxiliary equipment, confined spaces, storage tanks, and other structures. The dangers of working at heights and the extra precautions needed to do so may mean that routine maintenance and inspections of equipment and structures that present fall hazards are carried out less frequently or may be less comprehensive than required. Falls from elevations also typically lead to negative publicity and contribute to the degradation of morale and mission readiness. In addition to harming personnel, conditions that contribute to severe fall injuries often result in expenditures for medical care, down time, and costly retrofits that could have been built-in during ship system planning and acquisition phases. Typical costs for a fatality range from $800,000 to $2,400,000, while the average cost of serious injury is more than $30,000. These are direct costs and do not include worker replacement, pain and suffering, employee morale, and other indirect costs.
The following is a general cost profile that compares incorporating fall protection and prevention measures at various stages of design, construction, and maintenance:
During conceptual design --------- If it costs $1
At the final drawing stage -------- it will cost $10
As a construction modification --- it will cost $100
During startup and testing ------- it will cost $1,000
During maintenance phase ------- it will cost $10,000
Defense acquisition and construction programs and projects include many products and facilities that require work at elevated locations. These programs and projects must manage the potentially fatal risk of working at heights as an integral part of the design and process control that provides safe and effective defense systems. Defense acquisition regulations (DoD 5000.02) require planning and risk management for life cycle cost control and safety. Federal Acquisition Regulations (FAR) require construction safety precautions consistent with the latest Army Corps of Engineer Safety Manual (AR 385-10).
Elimination or minimization of fall hazards can best be achieved by incorporating fall protection measures during planning and design phases. Fall protection and prevention measures must be considered during all phases of design, construction, use, maintenance, operation, and final disposal.
The ANSI Z 359 Standard for fall protection describes the critical role of design in the introductory section in a manner that every system safety and design engineer might use as general checklist: The Z359 Committee acknowledges the critical role of design in infuencing the use of proper fall protection equipment. Designs which eliminate fall hazards through the proper application of the hierarchy of safety controls are the preferred method for fall protection. Design defciencies often increase the risk for employees who may be exposed to fall hazards: examples are (1) lack of rail systems to prevent falls from machines, equipment and structures; (2) failure to provide engineered anchorages where use of personal fall arrest systems are anticipated; (3) no provision for safe access to elevated work areas; (4) installation of machines or equipment at heights, rather than door/ground level to preclude access to elevated areas; (5) failure to plan for the use of travel restriction or work positioning devices.
Note: Although fall protection is very much a concern at all Navy shore facilities, this section will deal for the most part with fall hazards onboard Navy ships.
Working Aloft or Over the Side
Many areas on ships are inaccessible to maintenance, inspection, or repair crews from decks or built-in work platforms. This may mean climbing masts and kingposts or being suspended over the side of the ship on temporary scaffolding, from cranes, or in man baskets. The greatest hazard associated with working over the side or aloft is falling onto the pier or into a drydock or the water. Working aloft or over the side requires much preparation and extra precautions. These include filling out check lists, certifying cranes and aerial lift equipment, informing nearby ships, restricting the work area, and inspection of rigging, staging and personal protection equipment. Personnel must receive special training on working from heights and wear special harnesses secured to anchorages that can withstand the forces of a fall. In addition, extra personnel are needed as observers who can assist people working at heights or call for help in the event of an emergency.
Masts - Several fall hazards are associated with the need to climb masts for general maintenance like painting, repairs, or maintenance of radar or other equipment. Ladders leading to masts are most often vertical. Not all of these ladders are equipped with ladder climbing devices, commonly called "climber rails," which allow for the use of full fall protection while climbing up the ladder. Other fall hazards when working on masts are the danger of being knocked off the mast by moving equipment such as radar or losing one's balance due to sudden shifting of the ship or while hoisting tools and equipment.
Confined Spaces, Tanks, and Voids
Working in confined spaces can involve fall hazards. Platforms inside confined spaces may not have adequate guardrail systems. Use of personal fall arrest systems may be complicated by the lack of adequate anchorage points inside confined spaces. Deep tanks on Navy ships generally span four to five frames, or bulkheads, which have sloping sides with multiple configurations and can be over 40 feet in depth. Typically, access is through a top hatch or elliptical passages with small diameters and no guardrails. Because of the damp atmosphere in many of these confined spaces, and their chemically corrosive nature, ladders can easily become corroded and subject to failure. Wet or oily residues can also contribute to personnel falling when they lose their grip or footing on slippery surfaces. In some cases "D"-holes cut into the tank baffle plates substitute for ladders but do not meet safe ladder criteria. In addition, the "D"-holes may be placed as much as three feet apart vertically, making climbing even more difficult. [For further information on confined spaces, see the Confined Spaces section of these Acquisition Safety web pages.]
Falls down ladders are a common shipboard hazard. Many ladder mishaps occur while sailors and shipyard workers are attempting to move equipment or carry various items up and down inclined ladders. Typically, ship ladders are inclined at a 68 degree angle, which is fairly steep. Ladders are often built at an even steeper angle or are completely vertical to allow more room for other items in the space constrained ship environment. Steep angles make climbing the ladders awkward, especially while carrying bulky materials. Other factors which lead to falls from ladders are uneven surfaces, poor traction (lack of non-skid surfaces), lack of materials handling alternatives, lack of adequate lighting to see ladder rungs, and lack of guard rails, chains, or man ropes at hatch openings (first four steps).
During ship maintenance, repair, or construction, particularly in drydocks, it is often necessary to construct, erect, and use temporary scaffolding. Factors that increase the risk of falls from scaffolding are:
• Difficulty providing fall protection during erection and dismantling stages because of inadequate anchorages or tie off points for fall arrest gear
• Poor construction
• Faulty erection
• Obstructions to reaching equipment created by the scaffolding
• Poor traction
• No guardrails around edges
• Lack of easy access
Working on aircraft presents unique fall hazards because of slippery surfaces on the wings, tail, and fuselage. Combat aircraft are typically "thin skinned" and don't readily accommodate anchorages for tying off fall arrest gear. Aircraft maintenance aboard ship can complicate the issue of providing suitable fall protection because of the issues of space, time, and limitations of shipboard support structures.
Incorporate Fall Protection And Prevention During Planning And Design Phases
Design innovations that can be considered to minimize the need to work at elevations and/or that make working at heights safer include:
Provision for secure handrails at tops of ladders and handrail extensions that can be collapsed when hatches are closed (see diagram at right)
Use of control panels and displays at ground level instead of at heights
Remote technology, like lamps that rotate downward for service and maintenance
Designs that minimize the need for personnel to climb masts like triangular sails and masts that rotate from their bases
Ladders and safety rails built into systems with location of ladders and access points away from edges or protected by guard rails.
Hatch guards that include circular openings (shown on left)
• A National Institute for Occupational Safety and Health (NIOSH) Evaluation of Shipyard Ergonomic Hazards found design for circular hatch guard at Japanese shipyard http://www.cdc.gov/niosh/topics/ergonomics/ergship/hatchguard.html
Ladder designs that consider movement of personnel and materials in order to lower life-cycle costs and risks to crew and maintenance workers
Using man lifts where possible instead of ladders
Designing in deck and other edge protection or use of portable edge protection or rails
Safe means to raise tools and equipment to elevated work platforms
Designs that minimize the need for maintenance on elevated systems like long life paint systems and tanks that don't need routine painting
As part of the Rapid Cure Ship Tank Coatings Program, the Navy has utilized advanced coatings to the extend service life of:
• Sea water tanks from 5 years to 20 years
• Collection, Holding and Transfer (CHT) tanks from 2 years to 8 years
• Fuel/comp fuel tanks from 5 years to 20 years
• Potable water tanks from 5 years to 20 years
Designs that include readily accessible anchorages for scaffolding and fall arrest systems. An example is to build permanent anchorage points into the inside of ship hulls on which to hang scaffolding.
Remote inspection of equipment and structures at heights
Use of treads with high coefficient of friction for ladders
Use of D-hole connectors in tanks; "Beamer" - mobile anchorage point for I or T beams; and "first man up devices."
• Puget Sound Naval Shipyard (PSNS) developed and patented "D-hole Anchorage Connector" (provides stable anchorage point at both sides of bulkhead)
Conveyors that eliminate the need to carry materials on ladders or to haul up tools and equipment
Use of robotic inspection devices to enter fuel tanks, eliminating the hazards of manned entry
Replacement of scaffolding with mobile lifts where feasible
Routine implementation of system safety review and root cause analyses of all fall mishaps to identify and remedy high-risk fall hazards.
Approximately 2/3 of a defense systems total cost occurs during operation, support and sustainment. DOD is increasingly emphasizing the responsibility of the program manager to manage all aspects of a systems cost over the entire life cycle-not just design and procurement.
Ship design must consider life cycle costs and risks. Acquisition programs are required to consider the support equipment and facilities as well as the primary platform and plan for safe and efficient maintenance. These issues must be considered in the design and fielding of new systems and equipment. System Safety programs identify fall hazards that have persisted from prototype to prototype, singling out hazards that indicate fall mishaps to come. Safe designs are seen as efficiency improvements and cost-avoidance opportunities. Systems are designed for safe maintenance and efficiency in accordance with human systems integration requirements (fitting the equipment design and tasks to the worker) and Key Performance Parameters (KPPs).
Incorporating fall protection during the planning and design phases of any new acquisition decreases operation and maintenance costs compared to the cost of retrofitting fall protection into an already built system. Including fall protection in an original design also helps meet key performance parameters for life cycle costs and availability by reducing operational costs per unit of time.
• DoD/Navy Instructions and Regulatory Requirements
• Fall Protection Design Guidance Documents
• General Fall Protection References
• Fall Protection Regulations
• Fall Protection Standards
• OSHA Fall prevention Campaign
• Information on Robotic Tank Inspection
DoD/Navy Instructions and Regulatory Requirements
American Society for Testing and Materials (ASTM), Standard Practice for Human Engineering Design for Marine Systems, Equipment and Facilities (Re-approved 2000) - Establishes general human engineering design criteria for marine vessels and systems, subsystems, and equipment contained therein. Provides a useful tool for the designer to incorporate human capabilities into a design.
Establishes a simplified and flexible management framework for translating mission needs and technology opportunities, based on approved mission needs and requirements, into stable, affordable, and well-managed acquisition programs that include weapon systems and automated information systems.
Guidance Notes for the Application of Ergonomics to Marine Systems American Bureau of Shipping , ABS April 2003. American Bureau of Shipping, ABS Plaza, 16855 Northchase Drive, Houston, TX 77060 USA.
Mil Std 882, System Safety
Provides guidance for identification of hazards through a system safety process. Its application to all acquisition projects is required by SECNAVINST 5100.10H.
• Data Item Descriptions (DIDs) - Mil Std 882E (2012) is the most current guidance, but technical information useful to contract development can be found in the earlier version, Mil Std 882C. This prior version contains DIDs that can be used to require and monitor safety evaluations.
MIL-STD-1472G 11 Jan 12 Human Engineering (previously
DoD Design Criteria Standard for Human Engineering
OPNAVINST 5100.23 Series
Navy Safety and Occupational Health (SOH) Program Manual
OPNAVINST 5100.19 Series
Navy Occupational Safety and Health (NAVOSH) Program Manual for Forces Afloat
Fall Protection Design Guidance Documents
Fall Protection for Aircraft Maintenance & Inspection Work
Provides tools, criteria, and safe work practices to identify, assess, abate, and control fall hazards when working at heights during aircraft maintenance operations, inspection, and other related work.
EXSUM for Fall Protection for Aircraft Maintenance & Inspection Work
Department of the Navy, Fall Protection Guide for Ashore Facilities
This Guide establishes criteria for developing fall protection programs to protect all Navy personnel (military and Department of Navy civilians) on Navy Ashore Facilities.
US Department of Labor Protection Standards Website
Maritime and General Industry standards
General Fall Protection References
Ellis, J. Nigel PhD, CSP, PE Introduction to Fall Protection Fourth Edition American, 2001
Application of Human Systems Engineering Guidelines to Improve Safety, Access and Maintainability in Aircraft Carrier Storage Tanks
Geiger, M.B., Proceedings of American Society of Safety Engineers Symposium on Human Systems Integration, June 2003
Application of System Safety to Prevention of Falls from Height in Design of Facilities, Ships and Support Equipment for Weapons Systems
Geiger, M.B., Journal of System Safety, e-Edition, Volume 44, No. 3, June 2008
Maritime Fall Protection Issues Presentation at the National Safety Congress
Geiger, M.B., Chicago, Illinois, September 2003
NIOSH (2000) Review of Worker Death by Falls
A Summary of Surveillance Findings and Investigative Case Reports. U.S. Department of Health Education and Welfare, Center for Disease Control, CDC, National Institute for Occupational Safety and Health (NIOSH) Publication 2000-116
In 2012, OSHA partnered with NIOSH to create the Fall Prevention Campaign to raise awareness on fall safety and provide training materials for employers. The campaign emphasizes that planning ahead, providing the right equipment, and training all employees in proper use of equipment can save lives.
Fall Protection Regulations
29 CFR Part - http://www.osha.gov/SLTC/fallprotection/standards.html
• 1910 - General Industry
• 1910.23 - Guarding Floor and Wall Openings and Holes
• 1910.66 - Powered Platforms for Building Maintenance
• 1910.132 - General Requirements -- Personal Protective Equipment
• 1910.269 - Electric Power Generation, Transmission and Distribution
• 1915 - Shipyard Employment
• 1915.159 - Personal Fall Arrest Systems (PFAS)
• 1915.160 - Positioning Device Systems
• 1918 - Longshoring
• 1918.85 - Containerized Cargo Operations, includes Requirements for Fall Protection
Fall Protection Standards
- ANSI Standard A10.11-2010 - Safety Nets Used During Construction, Repair and Demolition Operations
- ANSI A10.11-1989 (R1998) Safety Nets Used During Construction, Repair, and Demolition Operations
- New ANSI Standards:
- ANSI/ASSE Z359.2-2007 Minimum Requirements for a Comprehensive Managed Fall Protection Program
- ANSI/ASSE Z359.1-2007 Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components ANSI/ASSE Z359 FALL PROTECTION CODE Revisions Strengthen Benchmark Consensus Standard By Joseph Feldstein in By Design, A special issue on the new ANSI Z359.3 Fall protection Code, Fall 2007, American Society of Safety Engineers www.asse.org available at http://www.asse.org/practicespecialties/engineering/docs/ByDesign_Z359Special_Fall2007.pdf
- ANSI Z359.3-2007 - Requirements for Assisted Rescue and Self-Rescue Systems, Subsystems and components
- ANSI/ASSE Z359.12-2009 Connecting Components for Personal Fall Arrest Systems Components
- ANSI/ASSE Z359.13-2013 Personal Energy Absorbers and Energy Absorbing Lanyards
- ANSI/ASSE Z359.14-2012 Self-Retracting Devices For Personal Fall Arrest and Rescue Systems
- ANSI/ASSE Z359.3-2007 Safety Requirements for Positioning and Travel Restraint Systems ASSE ANSI ESS
- ANSI/ASSE Z359.4-2013 Safety Requirements for Assisted-Rescue and Self-Rescue Systems, Subsystems and Components ASSE ANSI ESS
- ANSI/ASSE Z359.6-2009 Specifications and Design Requirements for Active Fall Protection Systems ASSE ANSI ESS
- ANSI/ASSE Z359.7-2011 Qualification and Verification Testing of Fall Protection Products
- Several additional ANSI Standards are under development, but are not yet available for purchase. Check at www.ansi.org
OSHA Fall Prevention
Prevention Videos (v-Tools)
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