For as long as I can remember, fall protection has been in the top 10 of OSHA’s most-cited safety violations. More times than not it has been in the top five. No matter how many national stand-downs OSHA or individual companies sponsor, nothing seems to work. We need to ask ourselves, why? The standards governing the work we do in the electrical industry are fairly clear, and whether you’re working under 1910.269 or 1926, there are specifics you need to cover.

Every job we do requires a certain amount of training to ensure that workers are proficient in their jobs. Fall protection is no different. Staff must be trained in the proper fall protection equipment needed for the specific job, no matter if it’s work on towers, poles, roofs, scaffolds, elevated work platforms, bucket trucks or any other structure that takes a person up “in the air.” It also takes into account various “floor” openings that may exist in facilities. There are many fall protection areas, but this article will focus on those involving heights.

Here are some highlights of a few of the changes made in 2014 to the final OSHA CFR 1910.269, Electric Power Generation, Transmission and Distribution standard:

1910.269(g)(2) Fall Protection

On and after April 1, 2015, qualified workers must use fall protection when climbing or changing location on poles, towers or similar structures, unless climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.

Fall-arrest equipment must be capable of passing a drop test after exposure to an electric arc with heat energy of 40±5 cal/cm² if the workers using the fall protection are exposed to flames or electric arc hazards.

On and after April 1, 2015, work-positioning equipment must be rigged so that workers can free-fall no more than 0.6 meters (2 feet).

While this is only a small portion of rules governing fall protection, you can see some significant impacts. Yes, it’s 2022, and by now employers should have all of these in place, but I would venture a guess that once again we will see fall protection as one of OSHA’s top 10 citations for last year. Again, why? Because when dealing with topics such as fall protection, you need to look at more than just what equipment is required or what training you must do.

All too often, simple activities such as wearing your fall protection properly can mean the difference between having a close call or a serious incident. Do you see your employees wearing their harnesses in the proper manner? Are they properly cinched up on the legs? Are they belted in when working from an aerial lift? These are the things that matter in fall prevention.

Listed below is an excerpt from the best practice “Safety at Heights,” which was adopted by the OSHA Electrical Contractor Partnership. For brevity, I have included enough to show what must be done. This partnership has worked over the years to reduce serious injury and fatalities in the industry and has had tremendous results. This partnership is by far the model for what OSHA considers successful collaboration.

Practice Description

“Fall hazards associated with aerial work shall be assessed and fall hazard mitigation plans developed. Fall Protection Device shall be ‘engaged’ ground-to-ground.

A. Climbers shall be competent in the application of all necessary fall protection methods used for the fall hazard mitigation of the tasks that will be performed.

B. The following information must be considered and addressed on the job briefing form when planning aerial work:

• Identify tasks to be performed while working aloft.

• Client/Owner Fall Protection policies, procedures and hazard analysis documentation as applicable.

• Identify suitable anchorage points that are going to be used for the task to be performed.

• Employers shall address rescue considerations and develop appropriate procedures that will allow successful performance of a given rescue technique for varied field conditions.

• Determine/identify necessary FPE [fall protection equipment] and/or Work Positioning Equipment (WPE).

• Determine climber qualification in the use of FPE and/or WPE.”

The practice description runs through section G, but this gives a flavor of what it takes to have a successful fall protection program. Review your fall protection programs and see where you stand.