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ESH Manual Page: 7000: Occupational and Subcontractor Safety

Fall protection is required at all times when working at heights.

Anyone involved in work or construction activities and exposed to a fall hazard must be trained:

  • To recognize fall hazards
  • To select and use fall prevention

This policy applies to all activities at the Sanford Laboratory that expose workers to fall hazards while performing work or construction activities. Construction activities differ from work activities in that construction is the alteration, demolition or repair of structures or buildings. This policy is in force whenever activities are conducted

  • Work activities: at greater than four (4) feet from the individual’s feet to a lower level
  • Construction activities: greater than six (6) feet.

3.1. Department Directors are responsible for:

  • Assuring that supervisors are following the fall protection policy.
  • Ensuring that fall protection requirements are incorporated into designs for new and retrofitted equipment as well as future and existing structures where known or predictable fall hazards are expected to occur.
  • Ensuring general fall rescue plans are established to cover activities requiring fall protection.

3.2. Sanford Laboratory Project Managers are responsible for:

  • Exchanging information regarding fall hazards and fall protection in SURF owned facilities during pre-construction meetings.
  • Verifying that the contractor and subcontractors have a written fall rescue plan in place before any worker is exposed to a fall hazard.
  • Verifying that fall protection training has been completed for contractor workers who will be exposed to a fall hazard.
  • Obtaining information from the contractor regarding fall protection methods that the contractor will follow while engaged in work activities.

3.3. Supervisors are responsible for:

  • • Identifying activities that present a fall hazard to workers for whose safety they are responsible.
  • • Defining work as Construction, if applicable.
  • • Determining applicable standards, precautions, and training. Reference flow charts are in Appendix 1 – Fall Protection Flow Charts.
  • • Identifying workers exposed to fall hazards and assuring they are trained before using a fall protection device.
  • • Observing workers while engaged in work at heights and observing protection methods and at-risk behaviors.
  • • Assuring that fall rescue plans are incorporated into the work plans if free fall distance could result in workers left in suspended position..
  • • Assuring that fall arrest equipment inspections are performed.

3.4. The EHS Department is responsible for:

  • Providing consultation on fall protection requirements, assessments and rescue plans to departments when requested.
  • Developing, providing and updating fall protection training.
  • Assuring that annual inspection of fall arrest equipment is performed and recorded annually by a competent person.

3.5. Workers (working at heights) are responsible for:

  • Recognizing areas and tasks that require fall protection.
  • Visual inspection of Fall Prevention, Fall Arrest and Fall Rescue Systems (including personal fall arrest equipment) before each use.
  • Use of fall protection
  • Anchorage – A secure point of attachment for lifelines, lanyards or deceleration devices able to withstand 5000 pounds of dead weight per person for fall arrest and 3000 pounds for travel restraint.
  • ANSI – American National Standards Institute
  • Body Harness - Straps which may be secured about the worker in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a personal fall arrest system.
  • Carabiner – A connector component generally comprised of a trapezoidal or oval shaped body with a normally closed gate or similar arrangement which may be opened to permit the body to receive an object and, when released, automatically closes to retain the object. It has a self closing mechanism that requires at least two consecutive deliberate actions to open.
  • Competent Person - A person who is capable of identifying hazardous or dangerous conditions in any personal fall arrest system or any component thereof, as well as in their application and use with related equipment.
  • Construction Activities - Construction, alteration, demolition, or repair of buildings, structures or other real property. All work perfomed throughout Sanford Laboratory that has not been deemed “construction” is termed “work activities”.
  • Deceleration Device- Any mechanism with a maximum length of 3.5 feet, such as a rope grab, rip stitch lanyard, tearing or deforming lanyards, self-retracting lifelines, etc. which serves to dissipate a substantial amount of energy during a fall arrest, or otherwise limit the energy imposed on the worker during fall arrest.
  • Deceleration Distance - means the additional vertical distance a falling worker travels, excluding lifeline elongation and free fall distance, before stopping, from the point at which the deceleration device begins to operate. It is measured as the distance between the location of a worker's body belt or body harness attachment point at the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location of that attachment point after the worker comes to a full stop
  • Fall Protection System– A system of criteria, procedures and equipment to protect persons from injuries due to a fall that consists of both Fall Prevention and Personal Fall Arrest.
  • Fall Prevention System –A barrier erected to prevent workers from falling to lower levels. It can also be a system/procedure intended to prevent workers from falling off, onto or through working levels, or can be a travel restraint.
  • Free Fall Distance - The vertical displacement of the fall arrest attachment point on the worker’s body harness between onset of the fall and just before the system begins to apply force to arrest the fall (maximum of 6 feet). This distance excludes deceleration distance, and lifeline/lanyard elongation, but includes any deceleration device slide distance or self-retracting lifeline/lanyard extension before they operate and fall arrest forces occur.
  • Lanyard - A flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body harness to a deceleration device, lifeline or anchorage.
  • Lifeline - A component consisting of a flexible line for connection to an anchorage at one end to hang vertically or for connection to anchorages at both ends to stretch horizontally and which serves as a means for connecting other components of a personal fall arrest system to the anchorage.
  • Suspension Trauma – Unconsciousness and/or other symptoms caused by remaining suspended in a fall protection harness for an extended period of time.
  • Personal Fall Arrest System - a system used to arrest a worker in a fall from a working level. It consists of an anchorage point, connectors, and a body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these.
  • Rope Grab- A deceleration device which travels on a lifeline and automatically engages the lifeline and locks so as to arrest the fall of a worker. A rope grab usually employs the principle of inertial locking, cam/level locking, or both.
  • Self-Retracting Lifeline/Lanyard - A deceleration device containing a drum-wound line which can be slowly extracted from, or retracted onto, the drum under slight tension during normal worker movement, and which, after onset of a fall, automatically locks the drum and arrests the fall.
  • Travel Restraint –A fall protection system that prevents the user from reaching an edge where the user can fall. The system is composed of a body harness, along with an anchorage, connectors and other necessary equipment.
  • Work Activities –All work performed throughout Sanford Laboratory that has not been deemed “construction activities”


5.1. Education and Training Requirements

Any worker, visitor, or contractor involved in work activities and exposed to a fall hazard at or greater than four (4) feet, or construction activities to a fall hazard at or greater than six (6) feet must be trained and made aware of the fall hazards and the use of fall protection equipment. As a minimum, the training shall include:

  • Recognition of fall hazards
  • The correct way to use, inspect, and maintain fall protection systems
  • Responsibilities of employees and the employer

5.2. Fall Rescue Plan

A Fall Rescue Plan is required whenever the free fall distance could result in the worker left in a suspended position. A general fall rescue plan is used for routine operations. A fall rescue plan must be included in the JHA for special projects. Fall Rescue Plans shall include rescue procedures and methods for a timely rescue to prevent the consequences of suspension trauma.

A rescue plan may include one or more approaches of the following

  • Self-rescue – a means for a fallen person to raise or lower themselves to a safe location and remove themselves from the fall protection.
  • Buddy rescue - a means for another person to raise or lower a fallen person to a safe location and remove them from the fall protection.
  • Contacting the Emergency Response Coordinator before work starts to arrange for timely response by emergency responders.

5.3. Fall Protection Systems

The following diagram shows options for fall protection – Fall Prevention or Fall Arrest as needed.

All fall protection systems must either be labeled to meet OSHA and ANSI standards or be approved by an engineer.

5.4. Working from Articulating and/or Telescoping Boom Lift

Anyone working from a telescoping and/or articulating boom lift, commonly known as JLG lifts, or bucket trucks, must wear a personal fall arrest system attached to the manufacture’s designated anchorage point.

According to OSHA, scissor lifts must follow the regulations related to mobile scaffolding. This standard does not require the use of a personal fall arrest system on scissor lifts if the guardrail system is intact.

5.5. Working from Scaffolding and Ladders

5.5.1. Scaffolding

When working from scaffolding, all requirements in OSHA 1926 Subpart L must be followed. Additionally, SURF requires the use of guard rails for scaffolding systems over 4’ high in all situations.

5.5.2. Ladders

Ladder use at SURF will follow all requirements of OSHA 1926 Subpart X, and OSHA 1910 Subpart D. Alternative methods, such as scaffolding, scissor lifts, or a boom lifts are recommended whenever the task places the worker at an elevation of more than 6 feet. If a ladder must be used, arrangements must be made to install anchor points for the use of fall arrest system to provide 100% fall protection.