ABSTRACT
by Jeffrey W. Rogers, Jennifer Schneider, and Frank Radio — The Annual Census of Fatal Occupational Injuries Report located on the Bureau of Labor Statistics website concluded that falling from heights is the second leading cause of fatalities within the Facility Management sector over the last 10 years. The objectives of this paper are to (1) examine the reasons behind the rise in historical fall fatality rates and (2) present recommendations for mitigating this rise into the future. The paper concludes that facility managers are required to use their accumulated experience and tacit knowledge in conjunction with mandatory and voluntary fall protection standards to develop, implement, and monitor effective comprehensive fall protection plans that minimize the risk from injury and death. The outcome of this understanding will be an associated decrease in the fall fatality rate that is currently seen today.
Keywords: Workplace Safety; OSHA; Fall Protection; Suspension Trauma;
INTRODUCTION
Fall hazards are present at facilities within the United States, and many workers die every year due to this high risk activity. This paper examines the reasons behind the rise in historical fall fatality rates and presents recommendations for mitigating this rise into the future. Once a fall incident occurs, the Fall Protection Regulations under 29.CFR.1926 for construction functions and 29.CFR.1910 for operation and maintenance functions provide general guidance for facility managers to understand, analyze, and report these incidents.
The Annual Census of Fatal Occupational Injuries (CFOI) Report, located on the Bureau of Labor Statistics (BLS) website, concluded that falls from height are a leading cause of fatalities in the work place (CFOI-DOL, 2009). The data shows that from 1999 thru 2008 falls resulting in a fatality were the second leading cause of death, surpassing workplace homicide and trailing motor vehicle crashes. The data also shows that in 2007 the fall fatalities reached an all-time high of 823 incidents. Figure 1 shows an increasing trend in the number of fall fatality incidents in the workplace from 1992 through 2008.
Figure 1 – Increasing Trend in Number of Annual Fall Fatality Incidents
Figure 1 suggests an approximate linear relationship showing an additional 15 incidents per year over the 15-year analysis period. This equates to a 2.50% annual increase in the fall fatality rates in the workplace, which certainly warrants further investigation.
Overall, 90% of all fall fatalities within the facility management sector occur during either construction or general industry (i.e. operations and maintenance) functions. Figure 2 reveals that as expected over the last six-years of the 15-year analysis period a significant percentage of fall fatality incidents occurred during construction functions.
Figure 2 – Number of Fall Fatality Incidents within the Facility Management Sector
Figure 2 shows that on average 400 fall fatality incidents occur each year during construction functions, while on average 291 fall fatality incidents occur each year during operation and maintenance (O&M) functions. This means that on average there is a higher risk of fall fatality incidents during construction functions. Facility managers must be more vigilant during periods of high construction volumes to ensure safer workplaces for their workers.
A (CFOI- DOL, 2009) report concluded that fall fatality incidents were least likely to occur when work activities were conducted on the same elevation level. Fall fatality incidents are most likely to occur when the work activities involve significant differences in elevation. Figure 3 reveals that the three leading work activities involving fall fatality incidents include ladders, roofs, and scaffolds.
Figure 3 – Number of Fall Fatality Incidents by Work Activity
Figure 3 shows that over the past twelve years the average numbers of fall fatalities involving ladders, roofs, or scaffolds are 154, 118 and 87 incidents, respectively. The impacts from these incidents were that approximately 359 productive workers did not return home to their families.
ANALYSIS OF SUSPENSION TRAUMA
Another significant factor with regard to the increasing fall fatality rates is characterized as suspension trauma or orthostatic intolerance within the workforce. A report issued by National Institute of Occupational Safety and Health (NIOSH) in 2008, concluded that a significant segment of the workforce is unable to survive from a suspension lasting more than 11 minutes. This segment of the workforce is adversely affected by suspension intolerance because these workers suffer from obesity, hypertension, abnormal circulation, and respiratory conditions. Therefore, the adverse effects of suspension intolerance must be a major consideration when developing and implementing a formal prequalification process. Facility managers across all industries need to understand the importance of suspension intolerance when conducting contingency planning scenarios for prompt rescues.
A safety and health Information Bulletin issued by OSHA, entitled “Suspension Trauma / Orthostatic Intolerance” provides employers and employees with important information regarding the signs and symptoms of orthostatic intolerance as well as recommendations for prevention (U.S. Department of Labor, 2004). This safety and health bulletin states that unless the employee is promptly rescued, the results of a fall can be fatal. This conclusion is supported by a 1984 research study conducted by the U. S. Air Force (Report No AF-AMRL-TR-84-021). The research efforts assessed all reported fall arrest and post-fall suspensions across their workforce. The research efforts also conducted human suspension tests to develop a better understanding of the fall fatality phenomenon. The study determined that the fundamental pathos-physiological mechanism responsible for clinical adverse effects associated with prolonged suspension is venous pooling in the dependent lower extremities. This condition is due to the failure of muscle operation during the period of motionless (Hearon & Brinkley, 1991). Without muscle contraction in the lower extremities, venous pressures in the legs rise rapidly.
Furthermore, it was reported that capillary pressures rise, causing fluid to leak from the circulatory system into the tissue spaces (Hearon & Brinkley, 1991). A similar condition is commonly seen on the parade grounds when recruits are standing at attention for prolonged periods of time and lose consciousness. These situations are not life threatening as blood flow is restored when the victim is moved to a horizontal position. However in a vertical fall suspension without a timely rescue or response, the consequences can be fatal due to heart failure. The malfunction in the heart is caused by an increasing rate, followed by the heart’s inability to return blood from the restricted lower extremities. Even if circulation is restored, consideration must be given for the build-up of lactic acid that develops in an anaerobic (without oxygen) condition. The sudden release of pressure from the harness straps causes the blood and the toxins to surge through the body, prompting a physical reaction that can lead to delayed shock (Peleaux, 1991). The primary conclusion of the 1984 USAF study is that orthostatic intolerance employees had a significantly higher risk of dying, while hanging in their harnesses.
Additionally, in 1987 the USAF and OSHA conducted a joint study regarding prolonged motionless suspension (Peleaux, 1991). The joint study concluded that the average amount of time that test-subjects could hang motionless in a full body harness before experiencing nausea, tingling, or numbness was 14.38 minutes. Interestingly, this joint study did not consider the force of the fall and the resulting injuries due to the shock on the body. However, the results of this joint study prompted NIOSH to update its current physiological data through a series of tests carried out on men and women with a mean age of 34 (Turner, 2008). This NIOSH study required test subjects to wear a full-body harness in different configurations. One configuration had the d-ring attachment located on the subject’s back. The other configuration had the d-ring attachment located on the subject’s chest. The results revealed that the average suspension time in a full-body harness prior to experiencing adverse physiological effects with the: (1) d-ring located on the back was 31 minutes with rescue needed within 11 minutes and (2) d-ring located on the chest was 28 minutes with rescue needed within 7 minutes (Turner, 2008). Although a smaller percentage of the test group ended the testing early, it is understood that a small segment of the workforce would need to be rescued in under 7 minutes and some in as little as 4 minutes depending on their respective suspension intolerance factors such as obesity, hypertension and other adverse circulatory conditions.
HEAVIER WORKERS — THE PHYSIOLOGICAL EFFECTS OF OBESITY
Due to the North American population increase in size and weight, the need to address the current upper range limit must be recognized (Wingfield, 2008). The Fall Protection Code, ANSI Z-359 establishes the current capacity for weight to range from 130 lbs to 310 lbs, which is governed by the available physiological data. OSHA currently requires that the maximum arrest force applied to the body must not exceed 1800 lbs, while providing language that permits workers to wear fall arrest equipment who are greater than 310 lbs. This discrepancy creates major considerations that need to be addressed including proper energy absorption, greater clearance requirements, and greater energy generation during the fall of taller and heavier workers. However, the ANSI standards are not enforceable necessitating many facility managers to independently develop testing strategies for workers who weigh up to 440 lbs (Wingfield, 2008). Since the ANSI standards and OSHA regulations lack common ground on this significant fall protection issue, facility managers must continue to consult with the equipment manufacturers to fully understand the limitations of their current fall arrest equipment.
During the 2008 International Society of Fall Protection Symposium, Gravitec, a leading engineering and consulting fall protection firm presented information on the topic of obesity (Gravitec, 2008). They reported that over the past several years the working population has increased in weight, and 3% of the full time workforce is in the category of morbid obesity with a Body Mass Index (BMI) greater than 40. Gravitec (2008) stated that approximately 75% of adults that are morbidly obese have co-morbid conditions. Moreover, this fact was found across all ethnic categories. In an effort to design and test equipment for heavier workers, Wingfield, (2008) conducted a study that evaluated factors for harness design, upper body support, sub-pelvic support, ability to self-rescue, suspension trauma, and harness adjustability. The study consisted of volunteers with BMIs ranging from 23 — 70, which translated into weights of 155 lbs to 575lbs, respectively. The results indicated that 50% of the tests were terminated early for medical conditions such as nausea and loss of sensation (Wingfield, 2008). Additionally the study concluded that since harness design has not changed for the larger worker, rescue efforts are much more difficult, which adds time and ultimately can lead to a failed rescue attempt.
Continuing to allow heavier workers to perform tasks at height needs to be thoroughly evaluated by facility managers. The decision must be made by facility managers as to whether the heavier worker should be exposed to fall hazards when wearing inadequately designed fall arrest equipment. OSHA offers many on-line resources for facility managers to use to evaluate the proper fall protection method for workers. In fact, when the topic of fall protection is explored, the OSHA website provides information on the current regulations, proposed rulemaking standards, and letters of interpretations. Finally, a strong level of competence is required by facility managers to understand how these fall protection resources apply across all construction, operation, and maintenance functions.
REVIEW OF THE 29.CFR FALL PROTECTION REGULATIONS
Over 12,000 fall fatality incidents have occurred over the past 15 years (DOL, 2009) within the Facilty Management sector. This number of deaths among productive workers require facility mangers to focus on safety and rescue planning procedures to mitigate the number of future deaths. Reducing future deaths within the workplace will require the development and implementation of comprehensive fall protection regulations. The current federal fall protection regulations for construction functions are contained within 29.CFR.1926, Subpart M, while the fall protection regulations governing operation and maintenance functions are contained within 29.CFR.1910, Subparts D and I. However, the promulgation of updated and/or new standards within the Code of Federal Regulations (CFR) is a long and tedious legislative process.
For instance, the 29.CFR.1910 standards have been scheduled for a final rulemaking since the 1980’s. However, these standards were republished for comment in 1990 and again resubmitted for comment in 2003 (Epp, 2007). Although these proposed rules were issued, they were never adopted. When federal regulations, such as 29.CFR.1910, remain in a state of flux and are subject to multiple interpretations, it generates a confusing process to understand the actual requirements within the Facility Management sector. To illustrate this point, a search in the interpretations section of 29.CFR.1910, Subparts D and I for “fall protection” returns 377 results. Facility managers would need to spend a tremendous amount of time attempting to review and understand the relevance of each document before rendering fall protection assessments to their organizations. Additionally, facility managers must also seek supporting interpretations from regional OSHA regulators to ensure the accuracy and future compliance of their assessments under the current fall protection requirements.
OSHA is the primary federal agency that is tasked with reducing all workplace injuries and fatalities relative to the promulgated occupational health and safety regulations. Historically, the number of OSHA workplace citations for fall protection noncompliance has been a significant percentage of all issued workplace citations. For example, in 2009 OSHA’s enforcement efforts regarding fall protection noncompliance was the second most cited regulation with 6,771 violations (OSHA, 2010). Additionally, in the preceding twelve month period from October 2008 through September 2009, construction functions were inspected at over 3,000 locations, resulting in approximately $2.5 million in accessed penalties. These financial penalties are not to be taken lightly, since budgets are very tight in the Facility Management sector.
SIGNIFICANT DISPARITIES IN THE 29.CFR REGULATIONS
A significant disparity in the application of the 29.CFR.1926 requirements for construction functions relative to 29.CFR.1910 requirements for operation and maintenance functions is with “trigger” height requirements. Under 29.CFR.1926 a “trigger” height is defined as a difference in evaluation of six feet or more above the floor or next lower level with an unprotected edge (OSHA, 2010). Under 29.CFR.1910 a “trigger” height is defined as a difference in evaluation of four feet or more above the floor or next lower level with an unprotected edge (OSHA, 2010). This non-uniformity in fall protection requirements can be traced back to the early 1970’s when injury and fatality rates were reviewed as part of the same rulemaking process. Based on the available data at the time, a fall from an elevation difference of four feet resulted in a disabling injury on a regular basis, while a fall from an elevation difference of six feet resulted in a fatal injury on a regular basis. This disparity between “trigger” height requirements has created significant confusion among facility managers, which has led to unintentional noncompliance fall protection citations.
Another significant disparity in the application of the 29.CFR.1926 requirements for construction functions relative to 29.CFR.1910 requirements for operation and maintenance functions is with a provision that authorizes the use of a guardrail as a control method for fall protection (OSHA, 2010). This provision permits the use of personal fall protection equipment when a guardrail is not feasible. Personal fall protection equipment such as a restraint system will actually protect workers from the fall hazard of an unprotected edge. A restraint system is typically a tethered system that incorporates the use of an anchor in conjunction with a lanyard of a specific length and in many applications may not actually be suitable in lieu of a guardrail. However, the fall restraint system is only mentioned in the proposed rulemaking provisions for 29.CFR.1910 and referenced in 29.CFR.1926.
Another significant disparity in the application of the fall protection regulations is with a “rescue” provision contained in 29.CFR.1926, which states, “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves” (OSHA, 2010). The provision uses the word “prompt”, but fails to stipulate a requirement when developing rescue plans. The current 29.CFR.1910 requirements as well as its’ proposed rulemaking provisions do not reference a “rescue” provision for a fallen worker. This oversight is disturbing given that construction functions have similar fall fatality rates to operation and maintenance functions, suggesting a need for “prompt” rescue planning in both camps.
BENEFITS OF THE ANSI Z-359, FALL PROTECTION CODE
The ANSI Z-359, Fall Protection Code is a collection of voluntary standards that provide guidance for both the Facility Management sector. The governing committee for ANSI Z-359 is comprised of some sixty technical experts that represent professional associations, manufacturers, and government agencies such as OSHA. The governing committee for ANSI Z-359 meets biannually to ensure a comprehensive approach to fall protection. The critical role of the proactive design of fall protection equipment is a principle influence for its’ prudent and safe usage. The proactive design of fall protection equipment will eliminate fall hazards through the application of a hierarchy of safety control and mitigation techniques such as the engineering of personal protective equipment.
The purpose of ANSI Z-359 is to implement standardization in the design of equipment that is being deployed in the rapidly growing field of fall protection (ANSI Z-359, 2007). ANSI Z359 facilitates design standards for fall protection equipment such as; (1) arrest systems that limit free fall acceleration forces; (2) positioning systems that limit free fall travel distance; and (3) travel restraint system that limit horizontal travel distance to an unprotected edge. These voluntary design standards provide facility managers with integrative solutions to minimize injuries that are often caused by misuse, poor selection, inadequate training, or worn equipment. Currently, ANSI Z-359 consists of eight areas of concentration containing more than 800 pages of information, as shown in Appendix A. The American Society of Safety Engineers (ASSE) expects ANSI Z-359 to be developed into eighteen areas of concentration over the next two years, which will then include up to 2000 pages of information.
Currently ANSI Z-359 recommends the proper design of fall protection equipment and assisted rescue applications. Major deficiencies in the design of fall protection equipment will often increase the risk of worker exposure to fall hazards, which may include a: (1) lack of handrail systems to prevent falls from machines, equipment, or structures; (2) failure to provide engineered anchorages where the use of a personal fall arrest system is anticipated; (3) failure of provisions to ensure safe access to elevated areas; (4) failure to preclude access to elevated work areas; and (5) failure to plan for the use of travel restriction or work positioning devices. Additionally, ANSI Z-359 recommends the proper design of fall arrest systems requires additional planning to effectively rescue workers who experience fall events. For example, ANSI Z-359 recommends contact with a rescue subject in less than six minutes (ANSI Z-359.2, 2007). Finally, ANSI Z-359 recommends identifying the equipment qualifications for those used in selfrescue and assisted rescue applications.
In addition to the proper design of fall protection equipment and assisted rescue applications, ANSI Z-359 enhances the ability of facility managers to assess and evaluate the expected risk hazards associated with working at heights within their organizations. ANSI Z359 contains a framework for developing a fall hazard survey (FHS) report, as illustrated by the fall protection risk assessment matrix and planning worksheet shown in Appendices B and C, respectively. The completion of the attached matrix and worksheet allow facility mangers to successfully mitigate adverse impacts from potential hazards identified in the FHS report. For example, this FHS report provides an effective means for allocate personnel among ranked fall hazards from highest to lowest priority. Finally, the FHS report contains pertinent information including: (1) type of fall hazard; (2) exposure rating (high, medium, low); (3) frequency of the job; (4) height of the potential fall; (5) suggested corrective solution(s); and (6) type of rescue equipment (ANSI Z359.2- 2007).
COMPREHENSIVE FALL PROTECTION PROGRAM
The FHS report contained within ANSI Z-359 provides a valuable risk management tool to assist facility managers with developing and implementing fall protection plans for identified fall hazards. The purpose of the FHS report is to cost-effectively mitigate the potential for fall injuries and fatalities. This capability to cost-effectively: (1) assess the design of fall protection equipment; (2) evaluate the adequacy of rescue plans relative to worker suspension intolerance; and (3) mitigate identified risk hazards is the basis for instituting a comprehensive fall protection program, as shown in Appendix D (ANSI Z359, 2007).
However, ANSI Z-359 is currently a voluntary fall protection standard. Given the confusion within the current environment of the fall protection regulations facility managers must use “due diligence” when assessing fall hazards, therefore, they must consider integrating the mandatory regulatory requirements contained within 29.CFR.1910 and 29.CFR.1926 along with the voluntary standards that are contained within ANSI Z-359. The integration of the voluntary standards with the mandatory regulations will provide facility managers with the essential elements to develop, implement, and report on fall injuries and fatalities within their organizations. The cost-effectiveness of this proposed comprehensive fall protection program can be measured through insurance premium reductions from decreased exposure to noncompliance fall fatality citations from OSHA as well as financial savings from reductions in lost worker hours from reductions in fall injury rates.
Facility managers need to recognize and understand all voluntary and mandatory fall protection requirements to protect workers exposed to fall hazards. Facility managers are also required to use their accumulated professional experience and tacit knowledge in conjunction with the mandatory regulatory requirements and voluntary standards to develop and implement cost-effective and comprehensive fall protection plans that mitigate the risk from injury and death. The outcome from cost-effective and comprehensive fall protection plans is an understanding of how to decrease fall fatality rates within the Facility Management sector.
CONCLUSIONS AND RECOMMENDATIONS
The Bureau of Labor Statistics’ fall fatality data was analyzed from 1992 through 2008. The analysis concluded that the current workplace fall protection regulations as contained within 29.CFR.1910 and 29.CFR.1926 are ineffective. This ineffectiveness is represented by a 2.50% annual increase in the fall fatality rates from 1992 through 2008. The enforcement efforts of OSHA have had a minimal effect on increasing fall fatality rates because they are reactive by nature. OSHA has done very little to update the current fall protection regulations because the bureaucratic process is arduous and cumbersome. In contrast, the ANSI Z-359, Fall Protection Code is a voluntary fall protection standard that is designed to be proactive within the ever changing workplace environment, especially pertaining to the development of new personal protection equipment standards. Therefore, it is recommended that in order to mitigate the frequency of fall injuries and fatalities facility managers must integrate the current fall protection regulations contained within 29.CFR.1926 and 29.CFR.1910 with the voluntary standards contained within the ANSI Z-359, Fall Protection Code. The impact of this proposed comprehensive fall protection program will be lower fall injury and fatality rates within the Facility Management sector.
To assist with the cost-effectiveness implementation of the proposed comprehensive fall protection program the additional recommendations are offered: (1) Institute a prequalification process to assess suspension intolerance among workers who are required to wear personal fall protection equipment. Specifically when assessing the use of personal fall arrest systems it is important to protect the health and safety of suspension intolerant employees by developing quick response and rescue plans. (2) Institute a prequalification process to assess heavier workers who need special considerations with regard to the ultimate design capacity of the personal protection equipment. When correctly used, personal protection equipment will mitigate a fall hazard by preventing a worker from hitting the ground or the next lower level.
The fall hazard assessment must consider adverse physical effects as well as adverse physiological conditions that may develop, while the suspended worker waits to be rescued. Therefore, it is paramount that facility managers thoroughly understand the importance of the critical components for managing a cost-effective and comprehensive fall protection program. Facility managers must provide more engineering controls to mitigate fall hazards rather than relying only on personal equipment for protection. Moreover, facility managers must prescribe minimum fall protection requirements that thoroughly comprehend the consequences associated with suspension trauma and the importance of prerescue planning when employees are subjected to fall hazards. As the workforce continues to increase in size and weight, the topic of obesity will continue to play a major role in minimizing suspension times. In fact, in some cases facility manager may need to disqualify a heavy worker due to the effects of obesity combined with the unpreventable circumstances that facilitate longer response times.
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