Part 3 - Special Fall Protection Feature

Want to have a Safer Jobsite? Focus on Fall Protection.

Since its inception, OSHA has had a profound influence on construction jobsite safety through their 29 CFR 1926 regulations. As with most rules that are promoting a change of conduct, confusion exists regarding the interpretation of these rules and questions about fall protection are chief among them. This confusion is evidenced by the issuance of more than 369 letters of interpretation by OSHA for fall protection alone in response to questions seeking clarifications. The reason fall protection is such an important component to jobsite safety is that falls are the number one cause of death on construction sites and the leading cause of serious injuries. In the most recent two years of OSHA statistical data, construction jobsite deaths from falls accounted for over one-third of all construction related deaths, or just under 600 total deaths due to jobsite falls in 2013 & 2014 combined. That’s too many people whose families are left devastated by an avoidable accident. No construction worker should have to pay with their life or experience a debilitating injury on a construction site in today’s environment of safety apparatus and level of training available. Yet, 573 souls in the past two years, left home to go to work on their construction jobsite in the morning and never came home to their family that night.

In our last “Exploring the True Cost of Jobsite Safety” installment, we identified eight areas of direct safety costs and assigned a dollar value regarding their annual impact on an average 5-man framing crew. The total ranged from $31,650 to $35,650. We did not include Fall Protection in that original exposé feeling that the topic deserved a more elaborate exploration. The confusing and somewhat complicated nature of Fall Protection safety, especially since the six-foot rule came into effect in 2011, dictated a featured article all its own. When the new OSHA requirement was issued to replace the Interim Fall Protection Compliance Guidelines for Residential Construction, that had been in effect since 1995 and allowed residential builders to bypass fall protection requirements, the industry ushered in an entirely new level of fall protection standards, and with it, confusion and added expense. Workers engaged in residential construction six (6) feet or more above lower levels were to be protected by conventional fall protection. For roofers, the 25 foot, ground-to-eave height threshold no longer applied, nor did slide guards as an acceptable form of fall protection, regardless of the roof pitch or height of the roof eave. Conventional fall protection meant a worker must be protected if they met the six foot fall criteria in one of three manners; a guardrail system, a safety net system, or a personal fall arrest system. Safety net systems never were practical in residential construction so that left the guardrail and personal fall arrest systems. 

It could be argued that the powerful homebuilding industry lobby that perpetuated the “feasibility” component to the interim guidelines, prolonged the inevitable. Essentially, feasibility defense became synonymous with economic practicability. A contractor who endured a safety expense that was not reasonable for the time duration of the task could claim that it was financially infeasible and did not have to abide by a rule or substantive standard. If you claimed that fall protection was infeasible or created a greater hazard for leading edge work (by attaching fall arrest equipment to incomplete structure), you didn’t have to address fall protection like the rest of the construction industry. This infeasibility argument stymied a process that the homebuilders, given a little time and commitment, could have worked through just like the rest of the construction industry. Now, the homebuilding industry finds itself challenged to adopt and enact standards on residential jobsites that have become commonplace on commercial-oriented construction sites. Now, you do it per CFR or you take a risk of being fined.    

I realize that there will be overlapping costs from Part II of our series and this piece dedicated to fall protection, specifically, the material and labor to install guardrail systems around floor openings. You can also easily include a safety harness, which is an essential part of fall protection apparatus, as part of your Personal Protective Equipment (PPE) package. All that really matters is that we capture the costs somewhere and include them in our final cost analysis.  

Fall Protection (Starting) from the Ground Up
The concept of fall protection really does start on the ground. It is essential that a written plan be in place before the first boot ever leaves the dirt on a project and it needs to be written by a qualified person, someone with a recognized degree or professional certificate and extensive knowledge and experience in analyzing, identifying, and communicating methods of jobsite fall protection safety. This document needs to be both comprehensive in nature and specific to the potential fall protection risks on each individual project as determined by a hazards analysis. It must include components to communication, training, execution, maintenance, inspection and recovery and is meant as a supplement to your overall safety and health plan document. Paramount to any successful fall protection program is designating and training a competent person. As we mentioned in Part II of our series, a competent person is responsible for the overall jobsite safety execution of the employer. They must have the ability to identify existing and predicable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees. The competent person must also have the authority (and willingness) to take prompt corrective measures to eliminate them. In many ways, there is no more important person on a jobsite than the designated competent person because their effectiveness provides the greatest opportunity to save lives. This is a leadership position and choosing (and supporting) the right person is essential if you want a vibrant safety mentality on your jobsite. In many ways, your program will only be as effective as the efficacy of your competent person.

Coming Out of the Ground
As a structure goes vertical, there is obvious framing operations where fall protection is warranted. The first is the installation of treated sill plates on masonry foundation walls of 8-feet or higher. You may be able to stand on the ground around the structure, depending on its height and condition, but the use of scaffolding and ladders or field-built scaffolding inside the foundation is typical since there is still a fall potential to the inside of the foundation that is greater than 6 foot. The next step is installation of the first floor joist. Once again, it is not unusual for carpenters setting the first floor joist to work from outside the foundation wall with partners working off scaffolding or ladders in the basement. The basement floor area is void of diagonal bracing that is typical of floors above so it is a clearer space for scaffolding and ladder maneuvering. Installing the floor decking requires sheathing to be laid-out onto the joists in a pattern that enables workers to have a solid surface to work. There is very little fall risk to the inside of the structure as floor joist (typically 16” on center) act as a barrier. If the structure includes a walkout feature that leads to a greater than 6-foot fall potential to the outside, an exterior guardrail system should be installed to protect workers. At this time openings for stairwells and mechanical chases should be cut out with the openings protected by installing guardrails or covers. We now have a functional first floor ready for the exterior and interior first floor walls to be built. Again, assuming there is no fall greater than 6 foot to the outside of the structure, conventional fall protection is not necessary when installing first floor walls. Exterior wall sheathing is either installed using ladders or a scaffolding setup or more often, applied to wall sections built on the first floor deck and stood into place. 

Working From Heights    ($450-500 per house)
As the building progresses to fabrication of the second floor, fall protection measures become more pronounced. Installing the second floor joist can be done by working from the first floor deck using ladders or traditional scaffolding, or by creating an elevated walking/working surface properly planked and supported. Once a rim or band board has been installed boxing in the floor joist, installation of an exterior guardrail system to protect any falls to the exterior should proceed. The guardrail system should include 2 x 4 vertical stanchions every 7 feet and a 3 rail barrier made of 2 x 4.  Total cost for material and labor to install a guardrail system on an average 3,000 SF home is $450-500. Once the guardrail system is up, framers can commence installation of the second floor deck without additional fall protection. Similar to the first floor, openings are cut out and guarded and walls are built, sheathed and stood in place. 

Raising the Roof
The intensity levels ratchet up on fall protection when it comes to roof work. Multiple safety concerns exist during the construction and installation of the roof structure and OSHA has documented that a significant percentage of construction jobsite fall fatalities originate from the roof area. Aside from the obvious distance of a potential fall and the inherent issues that pitched roofs present, air hoses, power cords and equipment & tools serve to complicate footing. 

On a majority of structures, the first component of building the roof involves setting trusses. This can be accomplished by working off of ladders, traditional scaffolding set on the second story deck, or the elevated walking/working surface built and supported just under the 6 foot threshold. Trusses are individually flown (picked) by crane and controlled by manned “tag lines” allowing each truss to be landed on the top plate and toenailed into position. Temporary and permanent bracing is then added from ladders and work surfaces to tie the truss system together. Once the trusses or rafters are secured, the structure is ready for application of the roof decking, typically 4x8 sheets of OSB or plywood. Applying the roof decking represents some of the most challenging leading edge work in construction when it comes to protecting workers against falls. 

Essentially, there are two practical ways to adequately protect decking installers and the roofers that follow them. The first involves installation of a guardrail system that encloses the perimeter of the roof and the eve and gable edges. This type of system is considered a “passive system” that prevents a person from possibly reaching a potential fall edge. They are considered passive control systems because they perform their designed purpose without any required or complicit action on the employee’s part. The beauty of this type of system is that it permits working totally unencumbered on a decked roof without any concern for further regulatory compliance. What complicates usage of this type of system, especially in residential construction, is the ability to attach to uneven eve and rake details consistent with most structures. The system pictured below, from Hugs Safety, is one of several rooftop perimeter fall protection guardrail systems on the market. The post and bracket combination attaches to an open soffit’s roof framing at every 8 feet (up to 7:12 pitch), 6 feet (8:12 – 10:12 pitch) and 4 feet (11:12 pitch & greater). While the Hugs Safety system may seem cost prohibitive at first glance, (around $6,000 for the initial post, brackets, wood and labor to install on a 3,000 SF house), if you use the same case study criteria that we used in our last report of a crew doing 25 homes per year, the cost of the Hugs Safety rooftop guardrail system averages just over $500 per house. To me, that seems like a real value for an OSHA approved passive system that requires no training and can benefit multiple subcontractors. It needs to be noted that with the guardrail system a person applying roof decking would not be in total OSHA compliance. Generally, the first course of roof decking is installed from ladders off the floor deck below or the makeshift scaffolding set to the inside wall. Once that course is on, the worker jumps to that surface and continues applying sheets going up the roof towards the ridge. Because the risk of falling towards the open edge of the decking as it is being applied represents a fall of greater than 6 foot, additional fall restraint is necessary. That brings us to option two.  

The second, and easily most common method of fall protection for installing decking and generally working at heights, is to wear a Personal Fall Arrest System, or PFAS. While the guardrail system is considered a “passive system”, a PFAS is anything but. The PFAS’ include a full body harness, fixed and retractable lanyards, lifelines, rope-grabs and anchorage devices. The system requires constant fit testing, reconfiguration, guarding, maintenance, rope management, certified employee training and site inspections by a competent person on site. It is an “active system”, to be sure. There has been a myriad of fall protection apparatus come on the market the past 5 years, much of it to answer OSHA’s renewed focus on the rewritten CFR. Evaluating what’s out there and then matching it to a person’s budget can be overwhelming. Unfortunately, many contractors go the route of acquiring the least expensive fall protection system they can get, and certainly just having equipment is a step up in many cases. Many carpenters choose a fall protection kit, typically sold in a 5-gallon bucket, which contains a full body harness, a length of rope with a rope grab, and a roof anchor. The basic bucket kits typically run between $100 to $175 depending on the brand, quality and items included. They represent a good value compared to individually purchasing each piece.  

Breaking Down Your PFAS Options
There are three vital components that make up a complete fall protection system, anchorage, body support, and a means of connection. Each one must be in place and properly used to provide maximum worker protection but there are many options within each of those three components, some of which can impact the level of risk a worker is subject to. 

Anchorage : $20 - $240
The simplest component in a PFAS to discuss is the anchorage, or as defined by OSHA, a secure point of attachment for lifelines, lanyards, or deceleration devices. ANSI describes an anchorage or tie-off point as a fixed structural component such as a beam, girder, column or floor that can support the forces in arresting a fall. A connecting device, of which there are many types and styles, including anchors, straps, and bolts, serve as a point of attachment for the lifelines, lanyards, or deceleration devices which are fastened to the body support mechanism and must be able to withstand 5,000 pounds of arresting force. Roof anchors range in price from between $20 - $240, depending on their sophistication. 

Body Support – Good…Better…Best Scenarios : $50 - $270+
Essentially, the only true means of body support for a PFAS is a full body harness. Body belts, which is a belt that encircles the waist, can be used for positioning and fall prevention but is not recognized as part of a personal fall arrest system. The full body harness is designed to distribute fall arrest forces across the shoulders, thighs and pelvis. They include a center back attachment for connecting to the lifelines, lanyards, or deceleration devices and may have other D-rings for use in worker positioning, fall prevention, suspension or ladder climbing. All full body harnesses are not created equal. The basic harness that comes in the “safety in a bucket” kit is generally a one-size-fits-all version that offers slide/pass-through buckle-type adjustments for legs, shoulders and chest and have one D-ring located on the back. Almost every safety gear manufacturer has a low-cost full body harness and cost for this bare-bones version is typically under $50

If you step up to a better full body harness you will start to add a few bells and whistles, especially related to comfort. The webbing tends to be wider, thus stronger, and the legs and shoulder straps have grommeted adjustment capabilities for a more customized fit. You may have some padding in the shoulder areas and improved ease of use over the lower priced version. Cost for an upgraded harness are in the $150 range. 

Taking another step up to the best category gets you additional features like breathable, moisture-wicking, water-repellent webbing, padded legs, shoulders and back, an incorporated belt feature for lower back support, additional positioning rings, and tool pouch assembly, enhanced spring-loaded D-rings for fast, easy and safe connections, as well as aluminum alloy hardware to reduce the overall weight. Costs for full body harnesses in the “best” class would start in the $270 range and go up. 

The thing to keep in mind regarding full body harnesses is that they all do the job if used correctly but if you are going to be wearing one all-day, every day, comfort really needs to enter into your decision process because a full body harness that stays in the truck will have absolutely no chance to save you.     

Connection Device
The connecting system or “lifeline” is the critical link which joins the body wear to the anchorage connector. Connectors come in four basic forms, standard lanyards, shock-absorbing lanyards, self-retracting lifelines and rope grabs. They predominately come in three materials, rope, webbing and cable.  

Each type of lanyard has its own advantages and disadvantages. For example, rope is easily cut or abraded. Steel cable lanyards have no stretch and can conduct electricity, while web lanyards have less stretch than rope, but are more durable and easier to inspect. You’ll have to understand each, in order to select the appropriate product for the type of work tasks you perform and hazards you are exposed to. 

Rope Grabs : $110 - $340
Rope grabs, which operate on vertical lifelines, are the most common connection device used on construction jobsites, partly because that is what is packaged in the “bucket of safety” kits. A rope grab consists of a length of rope attached to a roof anchorage by a connector with a self-closing gate.  A fall arrest device can travel along the rope, which when loaded, locks to the line. The user’s dorsal D-Ring on his full body harness is connected to the activating lever of the rope grab. There are two types of rope grabs, a manual version that you control by holding down the grab lever so you can move along the vertical line. When you release the lever, the rope grab latches in place. A trailing rope grab moves up and down the lifeline by itself. Any tug, jerk, or fall, locks the system into place and keeps the user from falling further.

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Standard Lanyards : $30 - $60
Traditional or fixed lanyards can be described as a length of webbing, rope or cable with connectors at both ends that tie a workers harness to an anchorage point or adequate support member. This type of lanyard is used more as a positioning or restraint device that allows a hands-free work environment with minimal or no “play” in the lanyard, limiting fall distance. The device should be rigged to prevent falls of no more than 2 feet and should not allow a worker to move farther than the leading edge of the working surface. These types of devices are not considered fall arresting.  

Shock Absorbing Lanyards : $40 - $130 (6’ length)
A shock absorbing lanyard has a built-in deceleration device that reduces the impact forces on the body in case of a fall. They come in two styles, pack or pouch style, and the in-line style and feature a specially woven inner core that elongates during a fall and allows dissipation of energy by extending deceleration distance. To be effective, it is critical that the user include the length of the entire lanyard when the shock absorber component has been deployed when determining what length lanyard to choose. For instance, a 6-foot shock-absorbing lanyard allows for up to 6 feet of free-fall distance before activating, and another 3.5 feet of deceleration distance before arresting a fall. If the wearer only calculated an 8-foot fall hazard, well, let’s just say that those kind of mistakes are not uncommon when it comes to fall protection accidents. Once this type of lanyard has been activated it must be disposed of.  

Retractable Lanyards : $300 - $550 (20’ length)
Also known as self-retracting lifelines/lanyards or “fall limiters”, these devices contain a drum-wound line of webbing or cable which can be slowly extracted or retracted onto the drum under slight tension during normal worker movement away from and towards the device. At the onset of a fall, the mechanism automatically locks the drum and arrests the fall in less than 2 feet, reducing the kinetic force significantly. Retractables are designed to fasten to an overhead anchor point with the “play” component attached to the users dorsal D-Ring. Some models even incorporate a retrieval winch for self-rescue capabilities. One issue with retractable lanyards is that as a worker moves sideways away from the anchor point they add length to the “play” in their line. If a fall occurs when the line is extended, the drum mechanism locks in place with the worker subject to a swing fall hazard as well as additional length in the line. A swing fall is when the fallen worker swings like a pendulum potentially striking objects they had not originally considered in a fall’s path. Workers using shock absorbing and self-retracting lanyards should never exceed 30 degrees from vertical to avoid swing fall hazards.

Rescue Planning
Before a fall protection or fall arrest system is used by anyone, there first must be a written rescue plan and procedures set in place. The plan must account for simple rescues as well as complicated ones. All workers must receive training regarding what to do in the event of a fall. The plan should cover the on-site equipment available, personnel and procedures for different types of rescue. This critical component of a fall protection plan is often only an afterthought when it is too late, potentially exposing a stranded co-worker to further risk or worse. Calling 911 may not be enough when a co-worker is in distress.

Training is Critical to Preventing Injuries and Saving Lives
Regardless of the type or price of your personal fall arrest system, it will do little good if the workers are not thoroughly trained in its usage. Live, hands-on training for all users is essential to help understand the capabilities and limitations of their PPE. This training promotes confidence and must include periodic re-training to be effective over the long-term. There is another issue to keep in mind regarding training. It is the law that workers receive training in a language they understand. It is incumbent upon the employer to know the speaking/listening and writing/reading language skills of their workforce. Ignorance in this matter is not an excuse in a court of law and there has been catastrophic fines and damage awards as legal precedence. 

In conclusion, the “game” has changed for residential construction regarding fall protection since the advent of OSHA’s six-foot rule. And while it may be a somewhat complex and murky standard for some, progress has been made in making jobsites safer when it comes to fall hazards. This article is, by no means, a comprehensive appraisal of the topic or all the costs incurred with compliance, but progress can only be measured by getting one convert at a time. If you have braved this article to its end, then hopefully some aspect, some trinket has hit home and you have enhanced your knowledge or your commitment, or both, to all construction jobsite safety, but especially, fall protection safety. Ask yourself this question: If I were preparing my son or daughter to ascend to a house’s 25-foot peak to work for the day, how would they be outfitted and trained to assure that they come home safe to me tonight? I believe we should answer that question the same way when you substitute employee, co-worker, or subcontractor into the question. And, if we acted on it, American construction jobsites would become appreciably safer overnight.   

Our next installment of Exploring the True Cost of Jobsite Safety series will take a look at indirect costs of safety producing activities, specifically the productivity impact associated with jobsite safety compliance. Until next time…Be Safe!!!

*The use of the roof perimeter guardrail is an option in lieu of PFAS Costs

*The use of the roof perimeter guardrail is an option in lieu of PFAS Costs

Pricing Summary
The pricing chart above includes direct safety costs from Part II and Part III of our Exploring the True Cost of Safety series. The only costs I have included from part III is the second floor guardrail system and personal fall arrest systems. As I did in part II, I used a price range to accurately capture the many options available when making safety expenditure decisions. I left out any costing for the roof perimeter guardrail system as it would be an option to using PFAS.