Column Personnel Safety Training

Keep Workers On Their Feet

EP Editorial Staff | May 1, 2021

When a fall can exceed 4 ft., have you installed and do you properly maintain the necessary safety devices to prevent that catastrophe?

By Ryan Dobbins, CSP, CHST, CIT, CUSP

Working from heights and the associated risk of falling are two of the most severe hazards to which industrial workers are routinely exposed during normal operations. The concerns with fall protection are often most notably discussed in a construction setting. In fact, fall hazards have been identified as one of OSHA’s “Focus Four” in the construction industry where falls, caught in-between, electrocutions, and struck-by events are the primary causes of construction-site fatalities. With so much emphasis placed on fall hazards, industry leaders often direct their attention to the OSHA Construction Standards (19 CFR 1926) since there is an entire Subpart dedicated to the subject (29 CFR 1926 Subpart M). However, in a production or manufacturing setting, attention should be focused on a broad subject that includes walking and working surfaces.

OSHA’s General Industry standards (29 CFR 1910) don’t provide a dedicated subpart for Fall Protection. In construction work, you have to plan ahead to work at heights. In general industry, fall protection is covered under the subpart for walking and working surfaces (29 CFR 1910 Subpart D). This is an important concept. Any walking and working surface can expose workers to an unprotected side or edge whenever they’re at risk of falling 4 ft. or more.

Consider the various catwalks, stairways, ladders, docking areas, manholes, assembly/service pits, or any designated walking path throughout your facility. These components are a routine part of moving about a facility. As a result, workers forget that they might be exposed to a fall. With this in mind, general-industry leaders must integrate prevention into the design to ensure all walking and working surfaces protect workers from falls while also protecting them from falling objects.

Providing effective fall and falling-object protection can be a daunting task. Here are eight steps to help you provide a safe environment in your plant:

Provide fall-protection training. Ensure all employees are trained to recognize and mitigate fall hazards and know how to properly use and maintain the fall-protection systems.

Evaluate all walking and working surfaces. Have a complete understanding of where and how workers are intended to work from routine and non-routine perspectives while also ensuring these surfaces are structurally sound.

Conduct a fall assessment in all work areas. Determine whether workers are exposed to falls of 4 ft. or greater during any work activities.

Eliminate the need for fall-protection devices. Eliminate fall hazards by installing and maintaining guardrail systems, hole covers, and other forms of prevention.

Select the best type of system based on your assessment. Focus on prevention techniques first if feasible, followed by personal fall-protection devices.

Develop rescue and retrieval methods. Anticipate potential falls and how to rescue or retrieve the fallen worker.

Develop an equipment inspection and maintenance program. When using fall-protection devices or equipment, make sure you have routine procedures for inspecting, storing, maintaining, and removing defective equipment from operation.

Monitor programs for effectiveness. Make sure your program is effective through observations and collect leading indicators for safe performance. EP

Ryan Dobbins is a Safety Services Manager responsible for developing, managing, and providing services in support of the Safety Management Group, Columbus, OH (, Ohio division. Dobbins supports large owner and contractor safety and health programs in industries such as manufacturing, construction, supply chain, automation, and electric power utilities. Contact him at


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