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WHAT TO CONSIDER WHEN DEVELOPING A FALL RESCUE PLAN A fall protection plan in South Africa must include a “rescue plan” detailing the necessary procedure, personnel and suitable equipment equipment required to affect a rescue of a person in the event of a fall incident to ensure that the rescue procedure is implemented immediately following the incident. Highlighted here is the fact that the rescue plan must include a step-by-step instruction how the rescues will be performed, the rescue personnel that will be involved in such rescues, the rescue equipment that will be utilized during such rescues and the fact that such recue procedures must be implementable immediately after fall incidents has occurred. A fallen worker that is trapped in a safety harness, may suffer from internal injuries, may be exposed to other hazards and will most likely sustain suspension trauma if left unattended for too long. It is therefore crucial that the rescue plan is implemented immediately following the fall incident. A slow rescue, in this case, can kill. General Safety Regulation 2(5) stipulates that “An employer shall instruct his employees in the proper use, maintenance and limitations of the safety equipment and facilities provided”. All fall protection equipment, including rescue equipment, has limitations. These limitations range from safe working loads that must not be exceeded to the physical limitations of what the equipment can or cannot do Developing the fall rescue plan can be a daunting task for an inexperienced Fall Protection Planner to get right if he/she is not careful. In their eagerness to boost their sales, most training providers’ and equipment suppliers neglect to inform their customers of the “limitations” of their training programs and/or rescue equipment. As a result, their customers often end-up with skills and rescue equipment that are of no value to them. If you think about it, multiple access methods are used to perform multiple tasks at height in various industries. MEWPS, telecommunication towers, overhead cranes, tower cranes, scaffolds, fixed ladders, portable ladders, roofs, gantries, mobile work platforms, suspended work platforms, manholes and excavations are but a few of the structures/situations were fall risk exist. Due to this, Fall Protection Planners must understand the risk first before they can make recommendations to their employers about the training and equipment that may be needed to affect the rescues of their fallen workers. They must be very wary of the limitations of training courses, machinery and rescue equipment that may have to be procured. Pre-assembled rescue equipment is very popular in South Africa today. Many employers send their employees for fall arrest rescue training on pre-assembled rescue systems which they then end-up buying too due to bad advice from the training providers. Such employers are often convinced that their Fall Arrest Rescue Technicians will be able to do multiple types of rescues with a single skillset and a single pre-assembled rescue system. In my opinion, there is not a single pre-assembled rescue system available on the market today that can do “everything”. All these systems have limitations and Fall Protection Planners should take note of them. Further to the above, many Fall Protection Planners recommend the use of lifting machines to conduct fall arrest rescues with, without taking the operator’s competency and the lifting machine’s limitations into account. Lifting machines are by their very nature not designed to “rescue” people with and their operators are not trained to use such machines for rescue purposes either. Such rescues should only be considered if standard operating procedures were developed for them and if the operators have been properly trained on these procedures. In conclusion, should multiple fall scenarios be possible on site, the services of Rope Access Rescue Technicians may be required. These technicians are highly skilled individuals who can rig various rope systems to raise casualties to higher levels or who can lower casualties vertically or even diagonally depending on the circumstances. Unlike Fall Arrest Rescue Technicians, their skills are not limited using pre-assembled rescue systems. Andreo du Preez

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: 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 Andreo du Preez

HIRA HIERARCHIES OF CONTROL The health and safety “hierarchy of hazard controls” is a widely accepted system that is promoted by numerous safety organizations all over the world to eliminate or minimize worker’s exposure to hazards. For the sake of this blog, let’s refer to this hierarchy as the “general hierarchy of hazard controls”. The “general hierarchy of hazard controls” is however not the only hierarchy that organizations use to eliminate or minimize worker’s exposure to hazards. The American National Standards Institute or ANSI as they are commonly known developed the ANSI Z359.1 and ANSI Z359.2 fall protection standards to enable employers in the US to identify, evaluate, eliminate, or control fall hazards in their workplaces. Through these standards, ANSI promotes the use of the “hierarchy of fall protection controls” which differs from the “general hierarchy of hazard controls” on some levels. As a health and safety risk assessor, do you know what the differences are between these two hierarchies and do you know how to apply these two hierarchies to your own work at height risk assessments? Both of these hierarchies are often used by many risk assessors all over the world when doing their work at height risk assessments. After reading this article, you should hopefully be able to incorporate both of these hierarchies into your work at height risk assessments. So let’s begin. Both hierarchies ranks the controls from highest to lowest based on their effectiveness and/or desirability. The “general hierarchy of hazard controls” ranks the controls as follows: The “hierarchy of fall protection controls” on the other hand, ranks the controls as follows: So which hierarchy should you use? What is important to note here is that “work at height” risk assessments are “issue-based” risk assessments. The need for them is usually identified via “baseline” risk assessments. So if your company’s risk assessment methodology requires you to apply the “general hierarchy of hazard controls” to your risk assessments, it makes no sense to revert to the “hierarchy of fall protection controls” during an issue-based risk assessment. As long as you understand that “fall prevention” is always preferred to “fall arrest” and that “personal fall restraint” and “personal fall arrest” are PPE controls at best, you should be able to incorporate these principles into any methodology. Further to this, based on ISO 31000 principles, ISO 45001 suggest a step-by-step approach using the “general hierarchy of hazard controls” to enhance occupational health and safety and to reduce or control workplace risk. Irrespective of where you are based, I therefore recommend you apply the “general hierarchy of hazard controls” to all your risk assessments, including your “work at height” risk assessments. SAPERE AUDE by Andreo du Preez Andreo du Preez

What are hazards and why is it so difficult for us as SHEQ Practitioners worldwide to identify them correctly in our workplaces? Clause 6.1.2 of ISO 45001 states that “Hazard identification should aim to determine proactively all sources, situations or acts (or a combination of these), arising from an organization’s activities, with a potential for harm in terms of injury or ill health”. As a result, many SHEQ Practitioners “assume” that all sources, situations and acts that poses health or safety risk to people or the environment, are indeed hazards. To be clear, ISO 45001 does not state that all sources, situations or acts that poses health or safety risk, are hazards. Clause 6.1.2 merely states that all “sources, situations or acts” arising from an organization’s activities, must be evaluated during the risk assessment process to determine their potential for harm. Now, it would be very easy for us as SHEQ Practitioners to blame the International Organization for Standardization and in some cases, even our very own legislatures, for such ambiguous “hazard” descriptions. However, part of the blame will always remain with us if we don’t educate ourselves properly and if we are complacent in the performance of our tasks. Complacency is after all the “kiss of death” for any SHEQ professional. Further to this, part of the problem may also be the way in which we conduct or SHEQ risk assessments. Let me explain. How many of you refer to your workplace risk assessments as your “HIRA” where you follow a two-step process namely “Hazard Identification” and “Risk Assessment” only? You see, there is actually a crucial third step that often gets ignored during the so-called HIRA process namely “Hazard Analysis” or “Hazard Evaluation”. Hazards constantly interact with each other and it is through this constant interaction of hazards that different levels of risk are created. You will therefore only be able to accurately predict such risk if you understand the unique characteristics of hazards and how they interact with each other. So, without further delay, let’s look at the characteristics of hazards: Simply put, a workplace hazard is therefore any tangible object that has the potential to cause harm due to its ability to move on its own or to be moved by another force. The ability of a hazard to move on its own or to be moved by another force, is also often referred to as the “closing and collision” potential of a hazard. If you are ever unsure whether any natural element, object or substance is a hazard, benchmark it against the characteristics of hazards that I explained in the previous paragraphs. If it is tangible, if it can move on its own or be moved by another force and if it can harm you, it is a hazard. So where does this leave us as human beings? In short, we as human beings have all the inherent characteristics of hazards that I explained previously. We have mass, symmetry, density, surface, shape and energy. We are undoubtedly governed by natural laws and above all, we interact with other hazards and therefore pose risk to other hazards. Human beings are therefore hazards. Our “acts” on the other hand are not hazards as not all our acts have the potential to cause harm. What sets us apart from all the other hazards is the fact that we have minds of our own. Due to this unique characteristic, human behavior is often inconsistent and unpredictable with high levels of health and safety risk. As a result, human beings and their interactions with other hazards should always be at the heart of all your risk assessments. Now that you know what hazards are, let’s wrap the lesson up with what hazards are not: Remember the following saying as it always applies to hazards: “ONCE A HAZARD, ALWAYS A HAZARD” Something cannot be classified “a hazard” the one day and then “not a hazard” the next day due to ever-changing human behavior or circumstances. Andreo du Preez

TYPES OF WORKPLACE HAZARDS A workplace hazard is any tangible object that has the potential to cause harm due to its ability to move on its own, or to be moved by another force. The ability of a hazard to move on its own or to be moved by another force, is also often referred to as the “closing and collision” potential of a hazard. There are three types of hazards namely single hazards, compound hazards and multiple hazards. All three are often grouped together as physical hazards, chemical hazards or even biological hazards but in the end, due to their unique compositions, they remain either single, compound or multiple hazards. A single hazard is any object that is a pure element on the periodic table of natural elements. Examples of such elements include pure iron, pure lead, pure oxygen and pure nitrogen. A compound hazard is created when two or more elements on the periodic table of natural elements, also known as “single hazards”, are chemically joined. Examples of compound hazards are water, paint and metal alloys such as those found in metal hand tools. A multiple hazard is a combination of any type of single or compound hazard that interact with other hazards on the basis of their combined characteristics. Examples of multiple hazards are electrical hand tools, pressure equipment, driven machinery and believe it or not, human beings. About 99% of the mass of the human body is made up of six of the elements listed on the periodic table of natural elements. That means that every single human being on planet earth is basically a “multiple” hazard! If you are ever unsure whether any natural element, object or substance is a hazard, benchmark it against the characteristics of hazards which I will explain in a follow-up blog post. In short, if it is tangible, if it can move on its own or be moved by another force and if it can harm you, it is a hazard. SAPERE AUDE by Andreo du Preez Andreo du Preez

CAN SAFETY PRACTITIONERS IN SOUTH AFRICA BE HELD ACCOUNTABLE FOR THE QUALITY OF THEIR ADVICE? In South Africa, under Section 37 of the Occupational Health and Safety Act of 1993, the legislator “presumes” that employers have committed the wrongdoings of their employees and contractors (vicarious liability). In a workplace context, an employer can be held liable for the acts or omissions of their employees and even contractors, provided it can be shown that the events took place in the course of their employment. Companies usually appoint CEO’s, as required by Section 16 of the Act, to ensure compliance with the OHS Act and other applicable HSE legislation​.  Should an incident occur, as a result of willful misconduct or negligence, the CEO, as the employer representative, will have to prove three things in order to counter the presumption-in-law as contained in Section 37 of the OHS Act: CEO’s rely on the advice they receive from their Safety Practitioners to determine what reasonable steps they can take to eliminate/mitigate health and safety risk within their companies. Having said this, Safety Practitioners in South Africa often think that the CEO of a company can only delegate responsibility but not accountability or liability to them. They don’t seem to understand that with their responsibilities comes accountability and with accountability comes liability. Accountability does not necessarily live at the very top but rather it is positioned at the most appropriate level, with the person who can be accountable for the work. The Occupational Health and Safety Act of 1993, requires the employer to bring about and maintain, as far as reasonably practicable, a work environment that is safe and without risk to the health of their workers. However, it is not expected of the employer to take sole responsibility for health and safety. The Act is based on the principle that dangers in the workplace must be addressed by communication and cooperation between the workers and the employer. The workers and the employer must share the responsibility for health and safety in the workplace. Both parties must pro-actively identify dangers and develop control measures to make the workplace safe.  Further to the above, business owners and their employees should also know that according to Section 332 of the Criminal Procedure Act 51 of 1977, the following persons may be prosecuted individually and/or jointly with the company for deaths that occurred as a result of their negligence: In conclusion, the implementation of health and safety control measures is a line function. Safety Practitioners are not responsible for the implementation of health and safety controls and can therefore not be held accountable or liable for their implementation or lack of implementation. Safety Practitioners can however be held accountable for the quality of the advice they provided to their employers. Should a Risk Assessor or a Fall Protection Planner for example fail to advise the CEO properly in terms of health and safety, he/she may be held accountable and therefore liable for their poor advice. SAPERE AUDE by Andreo du Preez Andreo du Preez