The OSHA Fall Protection & Prevention Standard for Construction (1926.501(b)(10)) stipulates the employer’s duty to provide fall protection for his employees working on low- or high-pitch roofs with unprotected sides and edges 6 feet or more above a lower level.
After 35 years walking a pitch and 15 years of safety training, I can assure you that this “duty clause” is practically time and cost prohibitive to implement all the time on every job. On a small portion of roof jobs, fall protection installation and use may be impossible to construct, or if worn properly, make it infeasible to complete the roofing tasks. Fall protection systems may also create another (or multiple) hazard that is more likely to cause an accident (probability) or else increase the damaging physical effects of an accident (severity).
The point is simple: It’s all about a good-faith intent on the part of the employer to protect his workers. Whenever the employees’ fall protection is ignored, the employer should be prepared to either rescue a fall victim or retrieve a body. More than 33 percent of our workplace fatalities are falls from heights. Almost 25 percent of these falls initiate from a roof. The worst statistic for the U.S. roofing industry is the continuing rise in these percentages.
The two most effective ways to prevent worker fall injuries and fatalities is to develop a corporate fall prevention program and encourage on-site safe work practices. The typical methods of roof fall hazard abatement fall into two separate categories: fall prevention (such as knee-walls, guardrails, warning lines, roof brackets, slide guards and safety monitor systems); and fall protection (such as safety net systems and fall arrest systems). This article is meant to address the criteria for employers to consider when designing a roof fall rescue plan in conjunction with personal fall arrest systems (PFAS).
OSHA and PFAS FallsWhen properly installed and worn, PFAS are designed to ANSI standards to protect the attached roofer from the physical effects of terminal impact. By now, most of us understand that a 180-pound roofer falling 6 feet to a lower level may impact with the force of 5,000 pounds due to increased mass during acceleration. Properly attached to a PFAS, the roofer may now fall the length of his 6-foot lanyard plus the 3 1/2-foot length of his “shock absorber.”
The deceleration device initially deploys at 400 to 450 pounds of force and continues to rip out at 900 pounds of force, providing a maximum terminal impact force of 1,800 pounds. That 3,200-pound force reduction in several seconds might be considered a great engineering achievement to some, but if you were the one who fell, you certainly wouldn’t consider it a “soft stop.”
The Fall Protection Standard also states in Section 1926.502(d)(20) (Personal Fall Arrest Systems): “The employer shall provide for the prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.”
This statement requires three serious evaluations on the part of the contractor.
First, what does OSHA mean by “prompt rescue”?In most cases, compliance officers have told me that OSHA considers a “prompt rescue” to be completed within 15 minutes. There were over 50 two-point suspended scaffold accidents (more than 100 victims) in the five boroughs of New York during 2001. No one was fatally injured primarily due to the proper implementation of PFAS. Out of over 100 victims, there were no documented self-rescues, as everyone was eventually rescued by FDNY. One rescue took over four hours from the time of arrival, due to entanglement, injuries, high winds and darkness. Fifteen minutes is often a recommended rescue window because of the deleterious physiological effects of impact followed by suspension for a longer period.
Notification of rescue services is not usually as prompt as it could be. It often takes precious minutes before the site confusion and panic subsides. Several unskilled “hero” rescues inevitably fail before professionals are called. Someone should always immediately call 911 for emergency medical response.
Without a designated rescue commander, there is usually a great deal of time and effort spent yelling orders at one another. The loudest contributor, if conscious, is usually the victim. Victims are the last people in a position to direct a rescue because their viewpoint is hardly objective. The only pertinent information they can contribute is a factual description of their injuries and the condition of only those parts of their PFAS that are directly observable.
In PFAS accidents that I have investigated, on the average, it takes untrained rescuers from the time of fall:
five to 10 minutes to accurately complete a 911 call
10 to 20 minutes to asses the condition of the fallen worker
10 to 40 minutes to attempt to organize personnel, equipment and rope rigging.
Without training and practice, it may take co-workers an hour or more from the fall event to even initiate the rescue procedures themselves. They are typically inventing procedures as they go. Add to that sufficient time to carefully get the worker up or down to safety and necessary emergency medical care, and they have contributed to the victim’s consequential injuries.
Similar to all safety management, dependable communication is the skeleton that actually supports every rescue effort. If you need proof, just disable radios or communication methods during a rescue drill and time how long, if at all, it takes to re-establish rescue procedures. In one recent case, a fall victim was suspended in a 4-foot-wide gap between a storage tank and a wall unit in a mill area and was not heard or seen by a co-worker for almost 30 minutes. This is a good argument for using the “buddy system” whenever workers are in elevated work areas.
Second, how can the employer practically “assure” when any of his workers may be able to self-rescue and when they won’t?While suspended in a deployed PFAS, a foreman should always ask the fall victim if he or she can perform a self-rescue safety. A reply of “I don’t know,” or “I think so” is hardly a confident reply. Likewise, overconfidence can lead to disastrous results. Has the victim been trained and drilled in self-rescue techniques?
Other questions to consider: Will a self-rescue attempt in this case increase the probability or severity of further unprotected falls? Was the PFAS equipment damaged as a result of the fall? Is there a possibility that the anchor point was compromised? Will moving about the structure cause it to move, shift or even collapse?
Post-fall self-rescue must happen quickly. Within minutes, with no other serious injuries, a fall victim may experience circulatory problems that may damage the heart or cause loss of consciousness. When trained elevated workers carry two Prusik cords (foot loops), they can attach them quickly to their lifeline post fall, then step into them. This relives harness pressure while enabling them to ascend or descend.
Under no circumstances should self-rescue be initiated until the competent person on site assesses the fall victim’s physical and mental condition. During most construction-related falls, rebounding, entanglement and structural impact all play a factor in the victim’s injuries and ability to escape unaided. It is nearly impossible to verbally dissuade a fall victim from attempting self-rescue if he or she is adrenalized, athletic and has a natural take-charge mentality.
The first-aid-trained competent person should also try to reconstruct and evaluate the fall incident for any potential injuries the victim may have received. Conscious or unconscious, the victim may be in shock, or may have received critical injuries such as arterial/venal lacerations, spinal cord injury, or head, spleen or lung damage. As there will be an eventual PFAS disconnection point in self-rescue, critical injuries (broken bones, concussion, muscle sprains, groin injuries) may play a significant role in this maneuver.
A brief verbal interview with the conscious worker should be attempted. I keep a pair of miniature binoculars in my first-aid backpack to look for signs of an undisclosed injury or possible entanglement from a distance. While it may be impossible to prevent the injured victim — who is typically in some degree of pain or discomfort — from attempting self-rescue, communication will always be essential to improving his or her chances. As is often the case in rescue, even a successful event can be a simple matter of degree. Choosing to climb up, down, right or left, may be the decision that saves a life. A victim’s chances of survival are vastly improved if he and his rescuer work together.
The best way for the employer to be confident in a fallen worker’s ability to self-rescue is to train, evaluate and drill self-rescue techniques to your workers on an annual basis. While this may appear to be a costly and time consuming chore that cannot possibly improve your profits, it is the only way for you to know if your workers possess the abilities necessary to self-rescue or if they should wait for your rescue team to access them.
Training self-rescue should only be done under carefully controlled conditions with skilled and experienced rescue trainers and back-up fall protection employed. Rescue drills should begin with simple, low-risk exercises and continue through levels of increased difficulty (called evolutions) until each worker is prepared for the “worst case” scenario. Often worst-case conditions involve darkness and rain.
Roofing may be an extremely hazardous occupation, but a well-trained employee is always your best insurance against accident and loss.
Third, if a fallen worker cannot self-rescue promptly, what is the employer’s plan to rescue or retrieve the victim?Most OSHA compliance officers will recommend that all employers must either have the in-house capability to rescue a fallen worker or have immediate access to a professional rescue service. The typical six- to eight-employee-member rescue team should be trained and organized by a competent person rescue commander who is designated by the employer by name in the fall protection section of the corporate safety and health plan.
The employer should evaluate any rescue service to ensure that it is capable of patient medical evaluation and packaging, as well as both high- and low-angle rope retrieval. He should have a copy of the service’s rescue safety program to review and approve. He should make his roof sites available at least annually to perform a rescue drill and evaluation.
While most large cities have established rescue services incorporated in their fire departments, outlying suburban and rural areas may not have all the required member capabilities and equipment necessary for extreme condition or high-angle rescues and aerial EMT services. A call to your local emergency services will give you enough information to ensure their fall rescue capabilities.
ConclusionIn my experience, workers trained in the selection, care, use and inspection of PFAS always adapt their work practices around their personal protective equipment. Eventually everyone gets used to the gear as well as being tied off 100 percent of the time. Some just take a little longer than others.
But ask anyone who has fallen in PFAS and you’ll get only one response — gratitude. As bad as the fall might have been, they thank their employer who insisted that wearing PFAS was a condition of employment. They thank themselves for enacting the safe work practices that saved them during the fall. They all remarked that in their memory, there was no imaginary boundary line between the fall and the rescue. It was all part of the same nasty, traumatic event. So why is it that rescue typically receives so little consideration in fall protection training? In an upcoming column, I will discuss the six phases of PFAS rescue and how and why addressing each one will assist roofing contractors in developing their own effective fall rescue plan.