Attachment XI. DON Fall Protection Guide (PWS attachment B).pdf

DEPARTMENT OF THE NAVY (DON)

FALL-PROTECTION GUIDE

02 July 2020

DEPARTMENT OF THE NAVY FALL PROTECTION GUIDE

October 2019

TABLE OF CONTENTS

SECTION # PAGE #

TABLE OF CONTENTS-------------------------------------------------- 2

1.0 INTRODUCTION------------------------------------------------------------ 8

1.1 PURPOSE-------------------------------------------------------------------- 8

1.2 BACKGROUND------------------------------------------------------------- 8

1.3 APPLICATION--------------------------------------------------------------- 9

1.4 SCOPE------------------------------------------------------------------------ 9

1.5 NAVY/MARINE CORPS FALL PROTECTION POLICY---------- 10

1.6 ACTIVITY FALL PROTECTION POLICY----------------------------- 11

1.7 THRESHOLD HEIGHT REQUIREMENTS FOR FALL

PROTECTION---------------------------------------------------------------- 11

1.8 COMPLIANCE---------------------------------------------------------------- 12

1.9 COMPARISON AMONG OSHA STANDARDS

NAVY/MARINE CORPS AND USACE EM 385 FP

REQUIREMENTS------------------------------------------------------------ 13

1.10 INSTRUCTIONS, REGULATIONS AND STANDARDS------------ 14

2.0 DEFINITIONS------------------------------------------------------------------ 16

3.0 FALL PROTECTION PROGRAM----------------------------------------- 33

3.1 COMPONENTS OF A FALL PROTECTION

PROGRAM--------------------------------------------------------------------- 33

3.2 SAMPLE WRITTEN FP PROGRAM------------------------------------- 34

3.3 FP PROGRAM COMPLIANCE AND AUDIT CHECKLIST--------- 40

3.4 STEP BY STEP HOW TO ESTABLISH, MANAGE

AND IMPLEMENT A FP PROGRAM------------------------------------ 48

3.5 AUDITS AND EVALUATION----------------------------------------------- 48

4.0 DUTIES AND RESPONSIBILITIES-------------------------------------- 49

4.1 QUALIFIED PERSON FOR FP------------------------------------------- 49

4.2 COMPETENT PERSON FOR FP---------------------------------------- 49

4.3 FP PROGRAM MANAGER ----------------------------------------------- 50

5.0 WORKPLACE SURVEYS AND ASSESSMENT OF

FALL HAZARDS--------------------------------------------------------------- 51

5.1 FALL HAZARD SURVEY--------------------------------------------------- 51

5.2 FALL HAZARD ASSESSMENT------------------------------------------- 52

5.3 REQUIREMENTS FOR FALL HAZARD SURVEY REPORT------ 52

5.4 SAMPLE FALL HAZARD SURVEY REPORT------------------------- 54

5.5 SITE-SPECIFIC FALL HAZARD SURVEY REPORT

CHECKLIST-------------------------------------------------------------------- 57

6.0 TRAINING---------------------------------------------------------------------- 58

6.1 TRAINING REQUIREMENTS--------------------------------------------- 58

6.2 TRAINING MATRIX --------------------------------------------------------- 61

6.3 REFRESHER/UPDATE TRAINING------------------------------------- 68

6.4 RETRAINING ----------------------------------------------------------------- 68

6.5 AVAILABLE WEB-BASED FP TRAINING COURSES-------------- 68

6.6 FALL PROTECTION TRAINING ROSTER----------------------------- 70

6.7 FALL PROTECTION TRAINING ROSTER FORM------------------- 71

7.0 FALL HAZARD PREVENTION AND CONTROLS------------------- 72

7.1 PREFERRED ORDER OF CONTROL MEASURES---------------- 72

7.2 FALL PROTECTION AND PREVENTION PLANS------------------- 73

7.2.1 FALL PROTECTION AND PREVENTION

PLAN REQUIREMENTS---------------------------------------------------- 73

7.2.2 INSTRUCTIONS FOR PREPARING THE PLAN--------------------- 74

7.2.3 SAMPLE FALL PROTECTION AND PREVENTION

PLAN (FORM)----------------------------------------------------------------- 76

7.2.4 SITE-SPECIFIC FALL PROTECTION AND

PREVENTION PLAN CHECKLIST--------------------------------------- 78

7.2.5 WHEN A COMPETENT OR QUALIFIED PERSON FOR

FALL PROTECTION IS REQUIRED TO DEVELOP A

FALL PROTECTION AND PREVENTION PLAN--------------------- 79

8.0 FALL PROTECTION SYSTEMS, CRITERIA AND

DESIGN REQUIREMENTS------------------------------------------------ 82

8.1 FALL PROTECTION SYSTEMS------------------------------------------ 82

8.2 FALL PROTECTION SYSTEM, CRITERIA AND

REQUIREMENTS------------------------------------------------------------ 83

8.2.1 PREVENTION SYSTEMS-------------------------------------------------- 83

8.2.1.1 GUARDRAIL SYSTEM------------------------------------------------------ 83

8.2.1.2 PARAPETS--------------------------------------------------------------------- 89

8.2.1.3 COVERS------------------------------------------------------------------------ 91

8.2.1.4 SAFETY NETS---------------------------------------------------------------- 93

8.2.2 ACTIVE FALL PROTECTION SYSTEMS------------------------------ 94

8.2.2.1 FALL ARREST SYSTEM--------------------------------------------------- 94

8.2.2.2 FALL ARREST SYSTEM REQUIREMENTS-------------------------- 96

8.2.2.3 FALL ARREST SYSTEM, SUBSYSTEMS

AND COMPONENTS-------------------------------------------------------- 97

8.2.3 OTHER ACTIVE FALL PROTECTION SYSTEMS------------------- 123

8.2.3.1 FLEXIBLE HORIZONTAL LIFELINE SYSTEM------------------------ 123

8.2.3.2 RIGID HORIZONTAL RAIL SYSTEM------------------------------------ 126

8.2.3.3 SINGLE ANCHOR LIFELINE SYSTEM--------------------------------- 127

8.2.3.4 CLIMBING LADDER FA SYSTEM---------------------------------------- 129

8.2.3.5 RESTRAINT SYSTEM------------------------------------------------------- 130

8.2.4 OTHER FALL PROTECTION SYSTEMS------------------------------- 132

8.2.4.1 POSITIONING SYSTEM---------------------------------------------------- 132

8.2.4.2 WARNING LINE SYSTEM-------------------------------------------------- 133

8.2.4.3 DESIGNATED AREA-------------------------------------------------------- 134

8.2.4.4 OTHER ENGINEERED FP SYSTEMS---------------------------------- 135

8.2.4.5 SUSPENDED ROPE ACCESS-------------------------------------------- 136

8.2.4.6 LADDER CAGES------------------------------------------------------------- 138

8.2.5 PROHIBITED FALL PROTECTION SYSTEMS----------------------- 138

8.2.5.1 SAFETY MONITORING SYSTEM---------------------------------------- 138

8.2.5.2 CONTROLLED ACCESS ZONE------------------------------------------ 139

9.0 FP REQUIREMENTS AND GUIDELINES FOR

SPECIFIC WORK APPLICATIONS-------------------------------------- 140

9.1 REQUIREMENTS FOR ROOF WORK---------------------------------- 140

9.1.1 GENERAL INDUSTRY WORK ONLY (FINAL RULE)--------------- 140

9.1.2 CONSTRUCTION WORK--------------------------------------------------- 142

9.2 INSEPECTION, INVESTIGATION AND ASSESSMENT

WORK (GENERAL INDUSTRY AND CONSTRUCTION)---------- 143

9.3 COMMUNICATION TOWERS--------------------------------------------- 144

9.4 TOWER ERECTION---------------------------------------------------------- 144

9.5 LEADING EDGE WORK---------------------------------------------------- 145

9.6 SCAFFOLD WORK----------------------------------------------------------- 145

9.7 SUSPENDED SCAFFOLDS------------------------------------------------ 146

9.8 WORK-STANDS, STATIONARY WORK PLATFORMS

AND CATWALKS------------------------------------------------------------- 146

9.9 AERIAL WORK PLATFORMS--------------------------------------------- 147

9.9.1 AERIAL LIFT EQUIPMENT------------------------------------------------- 147

9.9.2 SCISSOR LIFTS--------------------------------------------------------------- 148

9.9.3 MOBILE SCAFFOLDS------------------------------------------------------- 148

9.9.4 SAFETY OPERATING PROCEDURES FOR

PREVENTING AWP FROM TIPPING OVER-------------------------- 149

9.9.5 TYPES OF AERIAL WORK PLATFORMS----------------------------- 150

9.10 FALL HAZARDS ENCOUNTERED DURING CONFINED

SPACE ENTRY---------------------------------------------------------------- 152

9.11 EXCAVATED TRENCHES OR HOLES MORE

THAN SIX FEET DEEP------------------------------------------------------ 152

9.12 SAFE WORK PRACTICES ON LADDERS AND

STAIRWAYS------------------------------------------------------------------- 153

9.12.1 PORTABLE AND FIXED LADDERS------------------------------------- 153

9.12.2. PORTABLE LADDERS-SELF SUPPORTING------------------------- 159

9.12.3 STAIRWAYS------------------------------------------------------------------- 159

9.13 WORKING NEAR WALL OPENINGS----------------------------------- 161

9.14 CLIMBING AND WORKING ON WOOD POLES--------------------- 161

9.14.1 METHODS OF INPECTING AND TESTING WOOD

POLES--------------------------------------------------------------------------- 162

9.15 WORKING OVER WATER------------------------------------------------- 164

9.16 AIRCRAFT MAINTENANCE----------------------------------------------- 165

9.17 ELEVATED WORK AREA NEAR GUARDRAIL---------------------- 165

10.0 GUIDANCE FOR FALL RESCUE PROCEDURES--------- --------- 166

10.1 INTRODUCTION-------------------------------------------------------------- 166

10.2 BACKGROUND---------------------------------------------------------------- 166

10.3 GENERAL REQUIREMENTS---------------------------------------------- 167

10.4 INITIATION OF RESCUE--------------------------------------------------- 167

10.5 FALL ARREST RESCUE PLANS AND PROCEDURES------------ 168

10.6 RESCUE EQUIPMENT INSPECTION----------------------------------- 169

10.7 TRAINING REQUIREMENTS FOR RESCUE-------------------------- 169

10.8 PROCEDURES FOR REQUESTING RESCUE

MEDICAL ASSISTANCE---------------------------------------------------- 170

10.9 TRANSPORTATION ROUTES TO A MEDICAL

FACILITY------------------------------------------------------------------------ 171

10.10 ANCHORAGES USED FOR RESCUE---------------------------------- 171

10.11 SELECTIVE RESCUE EQUIPMENT AND SYSTEMS-------------- 171

10.12 REFERENCES RELATED TO RESCUE------------------------------- 175

10.13 FALL ARREST RESCUE PLANS----------------------------------------- 175

10.14 SAMPLE FALL-ARREST RESCUE PLAN (FORM)

FOR FALL-HAZARD CONTROL------------------------------------------ 177

10.15 SITE-SPECIFIC FALL ARREST RESCUE PLAN

(CHECKLIST)------------------------------------------------------------------ 179

11.0 INSPECTION, MAINTENANCE, STORAGE AND CARE

PROCEDURES FOR FP EQUIPMENT--------------------------------- 180

11.1 SPECIFIC EQUIPMENT INSPECTION--------------------------------- 181

11.2 ADDITIONAL INSTRUCTIONS FOR ASSEMBLY,

DISASSEMBLY, STORAGE, INSPECTION, CARE

AND MAINTENANCE-------------------------------------------------------- 187

11.3 FALL PROTECTION EQUIPMENT INSPECTION

CHECKLIST-------------------------------------------------------------------- 189

11.4 FALL-ARREST SYSTEM AND EQUIPMENT

CHECKLIST-------------------------------------------------------------------- 191

12.0 TIE-OFF CONSIDERATIONS AND SELECTION

OF SAFE ANCHORAGES AND FALL ARREST SYSTEM

CONSIDERATIONS---------------------------------------------------------- 196

13.0 RESPONSIBILITY FOR DESIGN, INSPECTION,

CERTIFICATION AND RE-CERTIFICATION OF

ANCHORAGES--------------------------------------------------------------- 200

13.1 ANCHORAGE IDENTIFICATION, DESIGN,

CERTIFICATION AND RE-CERTIFICATION OF

ACTIVE FP SYSTEMS------------------------------------------------------ 200

13.2 INSPECTION, CERTIFICATION,

RE-CERTIFICATION OF ANCHORAGES----------------------------- 201

14.0 FALL PREVENTION CONSIDERATIONS

DURING PLANNING AND DESIGN PHASE-------------------------- 203

14.1 INTRODUCTION-------------------------------------------------------------- 203

14.2 PLANNING AND DESIGN CONSIDERATIONS---------------------- 204

14.3 FALL HAZARD IDENTIFICATION---------------------------------------- 205

14.4 RISK ASSESSMENT--------------------------------------------------------- 206

14.5 RISK CONTROL-------------------------------------------------------------- 207

14.6 HIERARCHY OF CONTROL MEASURES FOR

PLANNING AND DESIGN PHASE--------------------------------------- 207

14.7 APPLICABILITY OF UNIFIED FACILITIES GUIDE

SPECIFICATIONS TO FALL PROTECTION-------------------------- 207

15.0 GUIDANCE – FALL PROTECTION FOR AIRCRAFT

MAINTENANCE AND INSPECTION WORK-------------------------- 209

15.1 INTRODUCTION------------------------------------------------------------- 209

15.2 APPLICABILITY--------------------------------------------------------------- 209

15.3 PURPOSE---------------------------------------------------------------------- 209

15.4 APPLICABLE STANDARDS, REGULATIONS/SOP

AND INSTRUCTIONS------------------------------------------------------- 209

15.5 WRITTEN FALL PROTECTION PROGRAM-------------------------- 209

15.6 DUTIES AND RESPONSIBILITIES-------------------------------------- 210

15.7 WORKPLACE SURVEYS AND ASSESSMENT OF

FALL HAZARDS-------------------------------------------------------------- 212

15.8 TRAINING---------------------------------------------------------------------- 213

15.9 FALL PROTECTION SYSTEMS AND EQUIPMENT

USED FOR AIRCRAFT MAINTENANCE AND

INSPECTION WORK-------------------------------------------------------- 213

15.10 ADMINISTRATIVE CONTROLS------------------------------------------ 227

15.11 INSPECTION, STORAGE, CARE AND MAINTENANCE

OF FALL PROTECTION EQUIPMENT--------------------------------- 228

15.12 RESCUE PROCEDURES-------------------------------------------------- 228

15.13 AUDITS AND EVALUATIONS--------------------------------------------- 228

15.14 FUNDING AND PROCUREMENT OF FP EQUIPMENT----------- 229

15.15 FALL PROTECTION FORMS/CHECKLISTS-------------------------- 230

15.16 EXAMPLES OF FP PROGRAM DOCUMENTS

(TEMPLATES)----------------------------------------------------------------- 234

16.0 FALL PROTECTION REQUIREMENTS FOR A/Es AND

OTHER INSPECTORS CONDUCTING INSPECTION,

INVESTIGATION AND ASSESSMENT WORK OF

ROOFS, GENERAL INDUSTRY WORKPLACE

CONDITIONS OR CONDUCTING FALL HAZARD

SURVEYS---------------------------------------------------------------------- 240

17.0 OTHER FALL PROTECTION MEASURES---------------------------- 254

18.0 ANSI Z359 FALL PROTECTION CODE/STANDARDS------------- 258

19.0 REFERENCES/HOW TO ACQUIRE INFORMATION--------------- 260

APPENDIX A FALL PROTECTION REQUIREMENTS - COMPARISON

AMONG VARIOUS OSHA STANDARDS, DON and

EM-385 REQUIREMENTS---------------------------------------- --------- 262

APPENDIX B CALCULATING FALL DISTANCE AND CLEARANCE------------- 286

B.1 CALCULATING TOTAL FALL DISTANCE----------------------------- 286

B.2 CALCULATING THE REQUIRED CLEARANCE--------------------- 286

B.3 SCHEMATICS FOR CALCULATING THE REQUIRED

CLEARANCE------------------------------------------------------------------ 287

B.4 TOTAL FALL DISTANCE SCHEMATICS------------------------------ 288

APPENDIX C DISCUSSION, EXAMPLES/PROBLEMS

AND SOLUTIONS TO FALL HAZARDS-------------------------------- 291

APPENDIX D MAN OVERBOARD PLAN------------------------------------------------- 297

APPENDIX E GUIDANCE DOCUMENT - DESIGN

CONSIDERATIONS FOR MANAGEMENT OF

ALL HAZARDS---------------------------------------------------------------- 301

APPENDIX F FALL PROTECTION TRAINING COURSE SYLLABUS

FOR COMPETENT PERSON--------------------------------------------- 327

APPENDIX G HUMAN SYSTEM INTERFACE WITH PERSONAL

FALL ARREST SYSTEM---------------------------------------------------- 338

APPENDIX H FIXED METAL LADDER INSPECTION CHECKLIST---------------- 341

DON FALL PROTECTION GUIDE

FOR

NAVY AND MARINE CORPS FACILITIES

1.0 INTRODUCTION

1.1 PURPOSE

This Guide provides criteria, best practices and applications in accordance with (IAW) requirements prescribed in OPNAVINST 5100.23/5100.19 for developing and managing Fall Protection programs to protect all personnel (military and DON civilians) at Navy and Marine Corps Activities.

1.2 BACKGROUND

Falls from heights are a leading cause of work-related injuries and fatalities. They are the leading cause in construction and the second most common cause in general industry. The DON continues to experience serious fall related mishaps, which lead to reduced readiness and productivity, as well as high medical and compensation costs resulting from these mishaps and suffering to victims and their families.

According to Bureau of Labor Statistics (BLS), in 2018 there were 615 fatalities from falls to a lower level and 154 fatalities from falls on the same level. In the United States, three to four fatalities from falls occur each working day. Furthermore, thousands of workers suffer injuries due to falls with lost time from work. Half of fall fatalities occurred in the construction industry.

BLS data shows that fall fatalities from roofs are the most common, followed by falls from ladders, scaffolds, staging, and other surfaces. Aside from tragic loss of life and suffering to victims and their families, workers are very expensive to train to perform work efficiently. On the average, a single fall fatality costs approximately $800,000 to $2,400,000 (in 2016 dollars, from the latest data available). The average cost of a single injury due to a fall is over $30,000.

Additionally, exposure to fall hazards is the most cited violation by Occupational Safety and Health Administration (OSHA). The intent of this guide is to establish criteria, requirements and best practices for developing and managing Fall Protection programs in order to heighten awareness and protect all DON personnel exposed to Fall-Hazards in the workplace. Falls are preventable. Careful planning and preparation lay the necessary groundwork for an accident-free workplace.

In the Department of the Navy, there were 6 fall fatalities between 2009 and 2014. Between 2005 and 2014 there were 235 DON personnel who experienced falls while working on aircraft and sustained injury. Falls represented 19% of Marine Aviation Maintainer Injuries and 17% of Navy Aviation Maintainer Injuries.

1.3 APPLICATION

This guide applies to all Navy and Marine Corps Activities where there is a need for developing and implementing a Fall Protection program to ensure the safety of all personnel (military and DON Civilians) worldwide. When the word personnel is used in this guide, it refers to Navy and Marine Corps military and civilian personnel. It provides information on standards, regulations, formal criteria, requirements and best practices, for the protection of personnel and workers working at heights and exposed to Fall-Hazards.

1.4 SCOPE

The scope of this guide is to develop a managed Fall Protection program and to provide the requirements, criteria and best practices for Fall Protection for potentially affected workers exposed to Fall-Hazards while conducting work at heights at US Navy and Marine Corps Activities/Commands.

This guide provides:

a. Definitions applicable to Fall Protection and rescue.

b. Criteria and requirements for developing a managed Fall Protection program, a sample of a written program, program compliance audit checklist and a step-by-step procedures how to establish, manage and implement a fall protection program.

c. The duties, responsibilities, and qualifications of personnel involved in the managed Fall Protection program.

d. The requirements and instructions for conducting Fall-Hazard surveys and the assessment process including the preparation of Fall-Hazard survey report.

e. The training requirements for all personnel involved in the Fall Protection program including methods of training, refresher/update training and retraining, available web based training courses and fall protection training roster.

f. Fall-Hazard prevention and controls including the preferred order of control measures or the hierarchy of controls, Fall Protection and prevention plan criteria, requirements and instructions, sample of the plan, and site-specific plan checklist.

g. Various Fall Protection systems, criteria and design requirements.

h. The Fall Protection requirements and guidelines for specific applications (Working on roofs, inspection and investigation work, communication towers, scaffolds, aerial work platforms, common workplace conditions, ladders and stairs).

i. Guidance for fall rescue procedures, rescue equipment inspection, training requirements for rescue, selective rescue equipment and systems and a sample rescue plan for Fall-Hazard control and a site-specific fall arrest rescue plan checklist.

j. Requirements for Fall Protection equipment inspection, maintenance, storage, and care procedures including equipment inspection checklist and fall arrest system and equipment inspection checklist.

k. Tie-off considerations and selections of safe anchorages.

l. Responsibility for design, inspection, certification and re-certification of anchorages and active fall protection systems.

m. Fall Prevention considerations for management of fall hazards and responsibilities of architects and engineers during planning, design, construction, operations and maintenance activities.

n. Fall Protection guidelines for aircraft maintenance and inspection work.

o. Fall Protection requirements for architects/engineers and other inspectors conducting inspection, investigation and assessment work on roofs, or inspection and investigation of workplace conditions.

p. Other fall protection measures including falling object protection, hard hats, lockout tag-out, etc.

q. Information regarding American National Standards Institute (ANSI), ANSI Z359 series Fall Protection Code and Standards.

r. Fall Protection guidelines for shipboard (Afloat) maintenance, inspection, and repair work.

1.5 NAVY AND MARINE CORPS FALL PROTECTION POLICY

According to OPNAVINST 5100.23/5100.19 Series, Navy Safety and Occupational Health Program Manual, Chapter 13 and MCO 5100.29B Marine Corps Safety Program and NAVMC DIR 5100.8, Marine Corps OSH Manual, every Navy and Marine Corps Command/Activity having personnel working at height, exposed to Fall-Hazards and using Fall Protection equipment is responsible for establishing, implementing and managing a Fall Protection program, which includes identification, elimination, prevention or control of Fall-Hazards. Navy and Marine Corps activities are responsible for assigning responsibilities; surveying and assessing fall hazards; providing prevention and control measures; training of personnel; proper installation and use of fall protection systems and equipment; and the availability of rescue equipment with accompanying rescue procedures; inspecting the equipment and auditing and evaluation of the program. Fall protection must be provided to Navy civilians and military personnel exposed to fall hazards on any elevated walking working surface with unprotected sides, edges, roofs, or openings, from which there is a possibility of falling to a lower level; or where there is a possibility of a fall from any height onto dangerous equipment, into a hazardous environment, or onto an impalement hazard.

a. The Regional Commander, Commanding Officer, Director or Officer-In-Charge of the Navy

Command/Activity as well as Marine Corps Major Commands and Subordinate Commands are responsible for establishing, managing and implementing a Fall Protection program.

Each Navy command, unit, or activity, which has personnel working at heights or exposed to fall hazards, is required to establish a written fall protection program. The latest version of this guide provides overarching technical direction for a comprehensive fall protection program and reflects the minimum mandatory requirements for all commands, units, or activities implementing a fall protection program. The written program requirement is met either through management of a standalone command fall protection policy or issue of a policy statement communicating a decision to solely use this guide as the command’s written plan. The standalone policy or policy statement must be signed by the Commanding Officer, Director, Officer-In-Charge, or equivalent.

b. The Navy Fall Protection Working Group (FPWG) shall serve as the technical advisor for fall protection policy and manage revisions to this guide. The FPWG will report directly to the Navy Safety Quality Council and meet on a recurring basis, as directed. Working group membership will consist of a primary and alternate representative selected from Echelon 2 commands with personnel exposure to at-height falls at either their Headquarters or subordinate commands.

c. Naval Facilities Engineering Command is the designated Technical Warrant Holder for fall protection Engineering affecting Facilities Design and Construction, Unified Criteria and Guide Specifications for Commands, Units and Activities.

d. Naval Sea Systems Command SEA 04RS is designated the Technical Warrant Holder for

Safety and Occupational Health under which fall protection is covered. The scope covers shipboard and at Ship Repair Activities. Furthermore, there are other designated TWHs across SEA05 for specific fall protection subsystems/components.

e. For Aviation, Technical Warrant Holders are spread across various PMAs under NAVAIR, based on equipment and type/model/series of aircraft.

1.6 COMMAND/ACTIVITY FALL PROTECTION POLICY

Each command/activity may prescribe supplementary requirements for special conditions above and beyond the Navy and Marine Corps policy stated in paragraph 1.5 above. Development of a command/activity policy statement will provide general guidance and requirements and delineate responsibilities at the Command. The command/activity policy shall emphasize management commitment to provide a safe work environment for all personnel working at heights and that safety of personnel during performance of their work is of the utmost importance.

1.7 THRESHOLD HEIGHT REQUIREMENTS FOR FALL PROTECTION

The threshold limit for providing Fall Protection is mandated by OPNAVINST 5100.23/5100.19 Series, Marine Corps 5100.29 Series and the US Code of Federal Regulations (CFR).

The following is a table indicating the threshold limit for various industries, standards, regulations and instructions:

Industry Feet Standard, Regulation Source

General Industry 4 29 CFR 1910.28

Marine Terminals 4 29 CFR 1917.112

Shipyard/Ship repair/Shipboard ops (Afloat)

5 29 CFR 1915.159

Construction 6 EM 385-1-1

29 CFR 1926.500

Long-Shoring 8 29 CFR 1918

Note:

The 29 CFR 1910 Subpart D (1970) requirements for Walking Working Surfaces were replaced with the new requirements from 29 CFR 1910 (11/2016) for Walking Working Surfaces.

At construction sites, workers shall adhere to the threshold height no greater than 6 feet, as per US Army Corps of Engineers (USACE), Safety and Health Requirements Manual EM 385-1-1, and 29 CFR 1926.500, Subpart ‘M”, Fall Protection in Construction Industry. When Navy and Marine Corps personnel visit construction sites to inspect contractor’s work, they may comply with the 6-foot threshold height because it would be infeasible to install guardrails at 4 foot height just for Navy and Marine Corps Personnel, when the OSHA Standards require a 6-foot threshold height for construction workers.

DON activities may prescribe more stringent threshold requirements for federal employees as required, due to the site-specific facility needs.

1.8 COMPLIANCE

29 CFR 1960.16 and Section 19 of the Occupational Safety and Health Act (OSH Act) of 1970 and Executive Order 12196 prescribes requirements for federal employment occupational safety and health programs and contains provisions to assure safe and healthful working conditions for federal employees.

Under Section 19 of OSHA Act and 29 CFR 1960.16, (for Federal Agencies), Occupational Safety and Health (OSH) programs shall be consistent and in compliance with the standards promulgated under Section 6 of the OSH Act of 1970. Section 6 of OSH Act directed by rule the Secretary of Labor to promulgate the Occupational Health and Safety Standard 29 CFR 1910.

Navy and Marine Corps personnel shall comply with the legal applicable OSHA Standards and OPNAVINST 5100.23/5100.19 Series, unless there are other alternate promulgated standards that are more specific to an Activity, Command or industry, such as the six-foot requirement for DON contractors performing construction and demolition work.

NOTE:

Exceptions: When erecting or dismantling supported scaffolds when it is determined by a Competent Person for Fall Protection after conducting an evaluation, that providing Fall Protection is not feasible or creates a greater hazard (for example: When it is necessary to erect scaffolding before erection of the structure, and requiring the scaffold structure to be erected or put in place.)

Department of Defense Instruction # 6055.01 titled Safety and Occupational Health Program applies to all DoD components; it does not apply to DoD contractor personnel and contractor operations. The contractor is directly responsible for complying with federal and State occupational safety and health standards for its employees. All regulations and standards for Fall Protection and health and safety contain minimum requirements. However, DoD Instruction 6055.01 does not preclude DoD components from developing different standards that are more protective than OSHA.

1.9 COMPARISON AMONG OSHA STANDARDS, DON AND USACE EM

385-1-1 FALL PROTECTION REQUIREMENTS

Appendix A of this guide provides comparison among various OSHA Fall Protection standards (Construction and General Industry), OPNAVINST 5100.23/5100.19 Series, MCO 5100.29 Series, NAVMC DIR 5100.8 and the USACE EM 385-1-1 Series, Fall Protection Requirements.

When all the Fall Protection standards and regulations (specifically OPNAVINST 5100.23/5100.19 Series FP program chapter 13, and the USACE EM 385-1-1 Section 21 requirements) are compared, they are similar in the application and use of Fall Protection systems and equipment. The only difference is the threshold limit where Fall Protection is required (4, 5, or 6 ft. height) and few minor applications. These threshold heights primarily affect the level at which temporary guardrails and work platforms are installed or used.

According to the International Building Codes, if there is a break of 30 inches (2½ feet) or more between levels, the edges must be guarded by permanent guardrails. Fall-arrest equipment cannot be used at these low elevations (i.e., 4 or 6 feet). The minimum clearance required for safely using fall-arrest systems is approximately 11 feet (depending on the length and type of the energy absorbing lanyard used, [e.g., Self-retracting Devices], the height of anchorage point, and available clearance. Other fall-arrest systems will require more clearance. Work platforms, with minor modifications, can be adjusted to the required threshold height. A positioning system will require a minimum of 8 feet or more below the tie-off point. Additionally, restraint, travel restraint, warning line systems or designated area that may be used at any elevation will not be affected by the prescribed threshold limits of 4, 5 or 6 feet, because when using those systems personnel will not be exposed to a Fall-Hazard. The only effect the threshold height limitations will have on safe walking working surfaces is the installation of temporary guardrails, existing loading docks, and parts of ramps above 4 feet.

1.10 INSTRUCTIONS, REGULATIONS and STANDARDS

1.10.1 OPNAVINST. 5100.23 Series, Navy Safety and Occupational Health Program Manual;

Chapter 13, Fall Protection Program;

1.10.2 OPNAVINST. 5100.19 Series Navy Safety and Occupational Health Program Manual for Forces Afloat; Chapter 13, Fall Protection Program;

1.10.3 MCO 5100.29B Marine Corps Safety Program;

1.10.4 NAVMC DIR 5100.8 Marine Corps Occupational Safety and Health (OSH) Program Manual: Chapter 18 Fall Protection Program;

1.10.5 US Army Corps of Engineers (USACE), Safety and Health Requirements Manual, EM 385-1-1, current edition; shall be included and enforced on all DOD contracts involving construction, dismantling, demolition or removal work. Contractors performing such work shall comply with all pertinent provisions of the latest version of the manual (FAR 52.236-13 Accident Prevention);

1.10.6 29 CFR, PART 1926.500, Subpart M, Fall Protection Requirements in the Construction Industry;

1.10.7 29 CFR, PART 1910, Occupational Safety and Health Standards for General Industry, Subpart D, Walking Working Surfaces;

1.10.7.1 29 CFR 1910.140 Subpart I Personal Fall Protection Systems;

1.10.8 29 CFR PART 1915, Occupational Safety and Health Standards for Shipyard Employment;

1.10.9 29 CFR 1917, Marine Terminals;

1.10.10 29 CFR PART 1918, Safety and Health Regulations for Long-shoring;

1.10.11 29 CFR PART 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs;

1.10.12 Department of Defense Directive 6055.1, Occupational Safety and Health Program;

1.10.13 American National Standards Institute (ANSI);

1.10.13.1 ANSI/ASSP Z359 Fall Protection Code/Standards, (See Chapter 18 for description of these standards);

1.10.13.2 ANSI/ASSP A1264.1 (R2007): Safety Requirements for Workplace

Walking/Working Surfaces and Their Access, Workplace Floor and Wall Openings, Stairs and Railing Systems;

1.10.13.3 ANSI/ASSP A14.3 (R2008) Safety Requirements for Fixed Ladders;

1.10.13.4 ANSI/ASSP A10.32 (2012) Personal Fall Protection Used in Construction and Demolition Operations.

End of Section

2.0 DEFINITIONS

Activation Distance. The distance traveled by fall-arrester or the amount of line paid out by self-retracting lanyard from the onset of a fall to the point where the fall arrester of self-retracting lifeline begins to apply a braking or stopping force.

Active Fall Protection system. A Fall Protection system that requires end-users to wear or use Fall Protection equipment and that requires fall protection training. Active fall protection systems can include any travel restraint or fall arrest systems.

Adjuster. A component that provides a means to enlarge or shorten the length of strap, webbing or rope.

Administrative Controls. Policies and procedures for safe work practices. This may include training, warning lines/signs or other methods to warn a person approaching a fall hazard.

Anchorage. A secure connecting point or terminating component of personal fall protection system that can safely withstand the forces exerted by the activation of Fall Protection and rescue equipment. The anchorage is a secured structure, can be in the form of a beam, girder, column, or floor. Anchorage is either engineered or improvised.

Anchorage Connector. A component or subsystem by which Fall Protection or rescue equipment is secured or attached to the anchorage. This can include a steel cable sling, tie-off adapter (anchor strap), load-rated hoist ring designed for construction applications, tripod, davit arm, or any other device designed to suspend human loads and capable of withstanding forces generated by a fall.

Anchorage Subsystem. A subsystem of a complete active fall protection system to which workers connect their personal equipment.

Anchorage System. A combination of anchorage and anchorage connector.

Arresting Distance. The total vertical distance required to arrest a fall. Includes activation and deceleration distance. Arresting distance does not include free-fall distance.

Arresting Force. The force exerted on a worker, when a Fall Protection System stops the fall.

The magnitude usually expresses the peak force experienced during a fall.

Arrest Load: The fall force exerted on the anchorage.

Assigned Safety Person (Spotter). An employee assigned to continually assure visually or verbally that an end-user has not fallen and is suspended in his/her harness. This assigned safety person shall have the ability to make quick contact with the jurisdictional public/Government-emergency response agency. This is also known as the “Buddy System”.

Assisted Rescue. A planned means of rescue, requiring the assistance of others.

Attachment Element Extender. Often also called a D-ring extender; a small lanyard temporarily or permanently attached to a harness intended to extend the attachment element away from the user’s body to facilitate ease of attachment.

Authorized Person. See the definition of End-user.

Authorized Rescuer. A person who is trained on rescue procedures and assigned by the Command/Activity to rescue end-user who may require rescue.

Automatic Descent Control Device. A load lowering device or mechanism that once engaged will automatically control payout speed of line or descent speed under load. Some automatic controlled descent devices have self-retracting lanyard capability.

Available Clearance. The distance from the walking working surface or platform to the nearest obstruction that the end-user might contact during a fall.

Back-Strap. A strap located on the back of a FBH that connects between the straps below the dorsal location and above the waist, which is intended to keep the body from exiting the rear of the harness.

Ballasted Anchor. An anchorage connector that rests on, but not mechanically connected to an underlying structure.

Body Belt. A body support comprised of a strap with means for securing it about the waist.

(Use of body belt in a personal fall-arrest system is prohibited).

Body Harness. Means of configuration of connected straps secured about the employee in a manner that will distribute the arresting forces over at least the upper thighs, waist, shoulders, chest and pelvis, with means for attaching a lanyard to other components of the personnel fall-arrest system. Full-body harness is the only body support device allowed by OSHA or ANSI when a free-fall distance exceeds two feet.

Boatswain’s (Boson’s) Chair. A single-point adjustable suspension scaffold consisting of a seat or strap designed to support one employee in a sitting position. The seat is made of a plywood or strap independently suspended from an anchorage, and the employee, using full-body harness attached to a separate lanyard or lifeline attached to an independent anchorage, may sit to help alleviate the pooling of blood in the legs.

Brake Bar Rack. A series of smooth bars connected together in parallel in which a synthetic rope is inter-twined so that the friction of the rope against the bars controls the descent of a lowering device (often used in a rope rescue system).

Buckle. A connector used for attaching the strap or webbing segments together or to themselves.

Cable Grab. See fall-arrester.

Cable Guide. A device that acts to guide or connect flexible carriers to the climbing ladder or structure at intermediate points along the carrier. Cable guides may be automatically by passable or may require the climber to remove the carrier cable from the guide before passing.

Cage. An enclosure mounted on the side rail of a fixed ladder or fastened to a structure behind the fixed ladder that is designed to surround the climbing space of the ladder.

Capacity. The maximum weight that a component, system, or subsystem is designed to hold.

This includes combined weight of the user, clothing, tools and other objects carried by the end user.

Carabiner. A connector component generally consisting of an oval- or trapezoidal-shaped body with a closed gate or similar arrangement that may be opened to attach another object and when released automatically closes to retain the object. Only self-locking carabiners are acceptable for use.

Carrier. The specified track of a climbing ladder fall arrest system consisting of a flexible or rigid member upon which the carrier sleeve travels. The carrier is secured to the climbing ladder or structure by carrier mounting brackets. The carrier may be continuous or may contain joints or splices.

Carrier Gate. A specific portion of the carrier designed to allow removal and installation of the carrier sleeve on or of the carrier. Carrier gates may be located at any point along the Climbing Ladder Fall Arrest System carrier but are most commonly located at the top and bottom of the system or at an intermediate entry/egress point.

Carrier Mounting Brackets. Elements of a climbing ladder fall arrest system that connects the carrier to the climbing ladder or structure. Top and bottom brackets for flexible carriers and intermediate brackets for rigid carriers are examples of carrier mounting brackets.

Carrier Sleeve. The device of a climbing ladder fall-arrest system that is connected to the user and travels along the carrier in response to climbing movements but automatically stops on the carrier in the event of a fall. Carrier sleeves are sometimes referred to as “cable grabs” for flexible carriers.

Carrier Stop. A device fitted to the carrier to prevent the carrier sleeve from unintentionally passing a specific point or becoming detached from the carrier. Carrier stops may or may not be subject to fall arrest loading depending on location. Some system carrier mounting brackets may function as a carrier stop.

Certification. The act of attesting in writing that the established criteria have been met.

Certified: An act or process resulting in documentation that determines and attests to criteria that meet the requirement of ANSI Z359 Standards. Such act or process may be carried out by testing or applying proven analytical methods, or both, under the supervision of a Qualified Person for fall protection or other entity (i.e. Professional Engineer).

Certified Anchorage. An anchorage for fall arrest, positioning, restraint or rescue system that a Qualified Person for Fall Protection certifies to be capable of supporting the potential fall forces that could be encountered during a fall.

Clearance. The distance from a specified reference point, such as the working platform or anchorage of a fall-arrest system, to the lower level that a worker might encounter during a fall.

Clearance Requirement. The distance below the end user, that must remain clear of obstructions in order to ensure that the End User does not encounter any object or obstruction during a fall.

Climbing Extension. A specialized carrier-mounting bracket of the climbing ladder fall arrest system that extends the system carrier above the top step or rung of the climbing ladder for purposes of transitioning on or off the climbing ladder.

Climbing Ladder. A climbing surface that includes rungs, step bolts, or similar foot and handholds that can be climbed while maintaining three points of contact, which is part of or affixed to a structure.

Climbing Ladder Fall Arrest System. An assembly of components whose function is to arrest the fall of a user. The system includes the carrier, carrier mounting brackets and the carrier sleeve. The carrier is securely attached to the climbing ladder or to the immediately adjacent structure.

Competent Person (CP) for Fall Protection. A person designated by the Command to be responsible for the immediate supervision, implementation and monitoring of the Fall Protection program, who through training knowledge and expertise is capable of identifying, evaluating and addressing existing and potential Fall-Hazards and in the application and use of personal fall protection and rescue system, or any component thereof, AND who has the authority to take prompt corrective measures to eliminate or control the hazards of falling.

Competent Person Trainer. A person who by training, knowledge and experience is capable of conducting a Competent Person for Fall Protection training.

Competent Rescuer. An individual designated by the employer who by training, knowledge and experience is capable of the implementation, supervision and monitoring of the Command/Activity fall protection rescue program.

Competent Rescue Trainer. A person who by training, knowledge and experience specific to fall protection rescue is capable of conducting rescue training.

Connecting Means. The method to connect body support to an anchorage, such as a lanyard, snaphook or a carabiner for the purpose of providing protected mobility for an elevated work task.

Connecting Subsystem. An assembly, including the necessary connectors, comprised of components, subsystems or both, between the anchorage connector and the D-ring of body harness.

Connection Linkage. A connector or a combination of elements, which is integral to the carrier sleeve, and which forms the link between the carrier sleeve and the attachment element of the full body harness.

Connector. A device used to couple (connect) parts of the personal fall protection system together. It may be an independent component of the system, such as a carabiner, or it may be an integral component of part of the system (such as a buckle or D-ring sewn into a body belt or body harness, or a snap-hook spliced or sewn to a lanyard or self-retracting lanyard).

Continuous Fall Protection. One or more fall protection systems that provide fall protection without interruption.

Controlled Access Zone (CAZ). A zone to restrict access to unprotected edge work. The CAZ is bounded by a control line and should run the full length of the unprotected edge and connect on each side to a guard or wall. The control line can be made of rope, wire, tape, or equivalent material and shall be supported by stanchions and marked with a highly visible material. (The use of controlled access zone is prohibited as a fall protection system).

Dangerous Equipment: Means equipment, such as vats, tanks, electrical equipment, machinery, equipment or machinery with protruding parts, or other similar units, because of their function or form, may harm an employee who falls into or onto the equipment.

Deceleration Device. Any mechanism, such as a fall-arrester (rope grab), rip-stitch lanyard, specially-woven lanyard, tearing or deforming lanyards, automatic self-retracting devices, etc., which serves to dissipate a substantial amount of energy during a fall-arrest, or otherwise limit the energy imposed on an employee during fall-arrest.

Deceleration Distance. The vertical distance, measured between the location of the user’s fall-arrest attachment point (dorsal D ring) at the onset of fall-arrest forces during a fall (and after the fall-arrest attachment point comes to a complete stop), is the additional vertical distance a falling employee travels (excluding dynamic elongation and free-fall distance) before stopping, from the point at which the deceleration device begins to operate or deploy.

Descent Controller. A device designed to be used by one worker for personal descent to lower another person from an elevation. Descent control may be used for egress, positioning or both.

Designated Area. A distinct portion of a walking-working surface, delineated by a perimeter warning line, in which employees may perform work without additional Fall Protection. The designated area is used only for general industry work.

D-ring. An integral “D” shaped connector typically used in harnesses, lanyards, energy absorbers, lifelines, and anchorage connectors as an attachment point.

Dorsal. A location on a full body harness that falls approximately between the user’s shoulder blades.

End-user of Fall Protection (Authorized Person). A person who has been trained in the use of assigned Fall Protection equipment, including hands-on training and practical demonstrations in a typical Fall-Hazard situation, and uses personal fall-arrest or restraint/positioning equipment while performing work assignments at heights.

Energy (Shock) Absorber. A component whose primary function is to dissipate energy and limit deceleration forces that the system imposes on the body and the anchorage system during fall-arrest.

Energy Absorber, Horizontal Lifeline. An energy absorber that is attached to one of the end anchorages or anchorage connectors of a horizontal lifeline subsystem.

Energy Absorber, Personal. An energy absorber that is attached to a harness.

Energy Absorber, Single Anchor Vertical Lifeline. An energy absorber that is attached to the top anchorage or anchorage connector of a single anchor vertical lifeline subsystem.

Engineered Anchor. An anchorage designed and approved by a Qualified Person.

Equipment: A general term referring to components, subsystems or systems, in any combination, singular or plural.

Evacuation harness. A component for rescue purposes consisting of elements designed and constructed so that the rescue subject is securely held during the rescue process. Evacuation harness is a special harness.

Failure. Load refusal, breakage, or separation of component parts. Load refusal is the point at which the ultimate strength is exceeded.

Fall Arrest. The action or event of stopping a free fall or the instant the downward free-fall has been stopped.

Fall-arrest System. A combination of equipment and components such as full-body harnesses, lanyards, deceleration devices, anchorages, horizontal or vertical lifelines connected together, designed to stop a person from striking a lower level or an obstruction during a fall.

Fall arrester. A device that travels on a lifeline and will automatically engage or lock onto the lifeline in the event of a fall. A rope grab is one example of fall arrester. .

Fall Hazard. Any location where a person is exposed to a potential free fall. This could be unprotected side or edge of a walking/working surface or unprotected opening from which a person will fall to lower surface.

Fall Hazard Survey Report. A written document that contains information about existing or potential fall hazards and a method or methods for eliminating, preventing or controlling those hazards.

Fall Prevention. The elimination and minimization of potential Fall-Hazards, lessening the chance of employee exposure to falls. Any same-level means used reasonably to prevent exposure to a Fall-Hazard; examples of fall prevention are guardrails, walls, floors, and area isolation. Also called passive fall protection system.

Fall Protection. Action and procedures to protect a worker effectively from Fall-Hazards. Any equipment, device or system that prevents an accidental fall from elevation or that mitigates the effect of such a fall.

Fall Protection Program Manager. A person assigned by the command to be responsible for developing and managing the Fall Protection program at a Navy Command. Must be in Paygrade E-7 or above for Shipboard/Afloat Operations.

Fall Protection System. A system that prevents workers from falling or, if a fall occurs, arrests the fall. Examples include guardrails, restraint, safety net and fall arrest systems.

Fall Restraint. See “Restraint System”.

Flexible Carrier. A carrier constructed of stranded wire rope or other flexible line materials.

Flexible carriers are typically mounted to the climbing ladder or structure only at the top…