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Construction Fall Prevention – Non-Routine Fall Protection

- May 8, 2018 by Mark Yeck, CIH, CSP (View all posts by Mark)

During work at heights, non-routine fall hazards are often overlooked in job plans, fall protection plans, and Job Safety Analysis. This can include transitioning from one working level to another before the working levels are finished (and guarded) or leading edge work (building in virtual space at height).

One method of managing fall risk that is unique or non-routine for your normal operations is understanding why it may need to occur, recognizing what the hazard is by clearly defining it, and eliminating or developing mitigation for instances where it has to occur.

Areas worth noting that can pose a non-routine fall hazard could include:

  • Mezzanines with unprotected edges
  • Ladder to platform interfaces
  • Roof access hatches and skylights.
  • Leading edge work (Work building items in virtual space such as concrete foundations, steel erectors, and residential construction (Top Plate, roof frame install)

It is common to have inadequate design here and well worth considering eliminating the need to use fall protection by engineering out hazards in advance of the work.

Why Non-Routine?

Tasks that are out of the ordinary or possibly never before performed by your team are non-routine. Some reasons for conditions that create a non-routine hazard could include;

  • Improper design construction (Guard rails missing or wrong specifications)
  • Poor design. Simply installing parts where they may not work together. (Example could be a fixed ladder with cage leading to an unguarded roof edge – a bad choice for access and missing the transition protection. Adding a staircase outside the building provides safe guarded access and can be used as an extra egress path depending on design.  Another area to think about is skylights and roof access. These areas are typically not guarded or installed wrong)
  • Access was not provided.  (Need to update or retrofit items like HVAC, Cameras, Sensors. Often these items are installed in odd mezzanine or attic like locations. It is worth noting they will all later need servicing and service technicians will be exposed to the same hazard as installers)
  • Poor project management of job phases. (Workers may need to get at areas where the access has yet to be installed during build and quality check (punch list or inspection) activities.)

How to identify non-routine fall hazards in a job plan?

A key often missed in a job plan is a pre-work survey or pre-job planning walk. During the walk, the team that includes “qualified and competent” fall protection leaders locates where the workers need to go. This is where non-routine items can be clearly identified. (For example, “Securing rebar on a 60’ high structural connection) The survey could have several photos of the area and measurements taken as needed.

In instances where modeling is available, a 3D fly through of the model with build teams can aide in mitigation strategies for every step of a build before it is actually constructed.

The best way to mitigate fall risk during non-routine tasks is to eliminate it. When that is not possible developing unique or advanced fall protection via a qualified engineer is also appropriate;

  •  Manage all phases of construction to eliminate the need for workers to be in areas missing guarding.
  • Perform an engineering review to identify and build in advanced fall arrest or protection system during construction where needed (Example could be a horizontal life line with capability for Team members and rescue)
  • Develop a temporary job plan that could include “First man up” installing fall arrest with rescue equipment to allow safe transition. (Often accomplished from a safe position via extension pole device from a man lift)
  • Erect proper scaffolding
  • Create a defined access plan. (An example may be exiting a man lift at greater than 6’ from a flat roof edge and proceeding straight ahead to the work area with a monitor present.
  • Use robotics and technology to avoid the height exposure
  • Use  “rope access” techniques to perform work (“Rope access” qualified employees or subcontractor only, typically used for the most difficult access challenges)

A key to safe non-routine task completion is safe build coordination and safe design.