STEPS IN THE FALL PROTECTION PLAN DEVELOPMENT PROCESS
Many Safety Practitioners are too lazy or “too busy” to develop risk specific documents such as fall protection plans. In a day and age where nearly everything can be “Googled”, fall protection plans are not the exception. As a Height Safety Trainer and Fall Protection Planner, I have seen many generic fall protection plans that are not worth the paper they are printed on.
According to the 2014 Construction Regulations in South Africa, a fall protection plan is a documented plan which includes and provides for all risks relating to working from a “fall risk” position. Fall risk is then defined as any potential exposure to falling either from, off or into something. The purpose of the fall protection plan is to eliminate the risk of falling. The fact that the legislator chose to use the word “eliminate” rather than “mitigate”, is an indication that some sort of hierarchy must be used during the risk assessment process. A safety harness on its own will simply not do it.
Also worth noting is the legislator’s instruction that the fall protection plan must be developed, implemented and maintained as required where there is risk of falling. Implementing and maintaining the fall protection plan are therefore continual processes.
The importance of the fall risk site survey cannot be underestimated as this will give the Fall Protection Planner the opportunity to collect data in the form of documents and records and to identify critical tasks and hazards on site. If the site is relatively new, the Fall Protection Planner may have to survey a similar site and/or sample historical documents in order to gain a better understanding of the company’s operations.
A well prepared Fall Protection Planner will usually take a lot of photos and be able to measure heights of structures etc. during the survey. Typical data that can be collected and/or verified during the fall risk survey include but are not limited to:
- HSE appointment records
- Risk assessment records
- Training records
- Medical surveillance records
- Equipment inventory records
- Equipment inspection records
- Incident records
Other documents that could be sampled during the survey are company policies, procedures and work instructions. Without this information, a risk specific fall protection plan will not be possible.
During step 2 of the fall protection plan development process, the Fall Protection Planner will either review the client/employer’s issue-based risk assessment for tasks performed at height or draft the issue-based risk assessment from scratch. An issue-based risk assessment is preferred to a baseline risk assessment as not all critical tasks are performed at height. All the hazards that were identified during step 1 must be recorded during step 2 as this will make it easier to assess the associated risk and to make control decisions.
During step 3 of the fall protection plan development process, the Fall Protection Planner must develop the fall protection plan. A plan is a “set of actions that have been thought of as a way to do or achieve something”. The fall protection plan must therefore be 100% aligned to the work at height issue-based risk assessment in order for it to become “risk specific”. In short, every single control decision that was made during step 2 must be thoroughly explained during step 3. For example, if fall arrest training was identified as a control measure during step 2, then it must be properly explained during step 3.
Last but not least, it is also the Fall Protection Planner’s responsibility to explain how the fall protection plan will be implemented and maintained in future. If done properly, it will ensure continued adherence to the fall protection plan.
SAPERE AUDE by Andreo du Preez
