Chapter 30 – Fall Protection Program

Contents

Approved by Kevin Goodwin
Revised 1/24

30.1 Policy
30.2 Scope
30.3 Applicability
30.4 Exceptions
30.5 Roles and Responsibilities
30.6 Definitions
30.7 Required Work Processes

• Work Process A. General Requirements
• Work Process B. Fall Protection Equipment Procurement
• Work Process C. Authorization and Training
• Work Process D. Hazard Assessment 
• Work Process E. Work Control Requirements 
• Work Process F. Fall Protection Equipment 
• Work Process G. Passive Fall Protection Systems 
• Work Process H. Active Fall Protection Systems 
• Work Process I. Hazards Requiring Evaluation for Fall Protection 
• Work Process J. Off-Site Fall Protection 
• Work Process K. Covers 
• Work Process L. Protection from Falling Objects 
• Work Process M. Walking Working Surfaces
• Work Process N. Leading Edge Work 
• Work Process O. Hoist Areas 
• Work Process P. Working Near Holes 
• Work Process Q. Formwork and Reinforcing Steel 
• Work Process R. Ramps, Runways, and Walkways 
• Work Process S. Working Near Excavations 
• Work Process T. Working Near Dangerous Equipment 
• Work Process U. Overhead Bricklaying and Related Work 
• Work Process V. Low Sloped Roofs
• Work Process W. Steep Sloped Roofs 
• Work Process X. Precast Concrete Erection 
• Work Process Y. Residential Construction 
• Work Process Z. Wall Openings 

30.8 Source Requirements 
30.9 Reference Documents 
30.10 Related Documents 
30.11 Appendices 

• Appendix 1. LBNL Fall Protection Permit Acronyms 
• Appendix 2. Fall Calculation with 6 Ft Lanyard and SRL Models 
• Appendix 3. EHS OJT FP Safety Monitor Training 
• Appendix 4. LBNL Trigger Height Chart 
• Appendix 5. LBNL Active Fall Protection Infeasibility Plan 
• Appendix 6. Field Hazard Assessment Plan (Model)
• Appendix 7. LBNL Fall Protection Permit Acceptance Letter

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30.1 Policy

The Lawrence Berkeley National Laboratory (Berkeley Lab) Fall Protection Program applies to work on any walking or working surface having an unprotected side or edge that is 4 feet high or more for General Industry workers and 6 feet high or more for construction workers. 

• Surfaces include: leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 1.2:1 (horizontal to vertical), hillsides, roofs, and surfaces with open holes or skylights.
• The Working Alone Policy restricts work at Lawrence Berkeley National Laboratory (Berkeley Lab) in cases where a plausible failure of hazard controls could result in an injury or exposure that would render an individual unable to take appropriate emergency actions.
• An individual may fall for an elevation above 4ft for a General Industry employee and 6ft for a Construction employee.
• The Fall Protection Competent Person will design site specific controls on the fall protection permit which will determine if the worker is allowed to work alone, e.g. while working using a fall restraint system with radio communication.
• Workers using a fall arrest system will not be allowed to work alone.
• See Berkeley Lab’s Working Alone Policy.

30.2 Scope

Berkeley Lab’s Fall Protection Program manages the risk of falls while individuals are working at heights through planning, training, installation, use of fall protection and rescue systems, and implementation of fall protection and rescue procedures.

At Berkeley Lab, new work surfaces higher than 4 feet (6 feet for construction) must be designed to eliminate the need for fall protection. When feasible, existing work surfaces higher than 4 feet (6 feet for construction) must be modified to eliminate the need for fall protection. Eliminating the need for fall protection may be accomplished through the application of engineering controls (such as lowering the work surface or providing barriers, such as parapets, that prevent contact with the leading edge) or administrative controls (such as changing a process, sequence, or procedure so that workers do not need to work at heights). 

When it is not feasible to modify existing work surfaces higher than 6 feet, workers must use fall-protection systems when working in any situation that presents an exposure to a fall hazard. Fall-protection work controls include: guardrail systems, safety net systems, personal fall-arrest systems, and platform ladders. For fall-protection work-control requirements and exclusions, see Work Process E, Work Control Requirements.

30.3 Applicability

Berkeley Lab employees, construction contractors, non-construction subcontractors, vendors, and affiliates who work on any walking or working surface having an unprotected side or edge that is 4 feet for General Industry workers and 6 feet high or more for Construction workers must complete the appropriate fall hazard controls:

• LBNL employees will complete a fall hazard analysis utilizing the hazards and controls described in LBNL’s Activity Manager (Work Planning Control Process).
• Non-construction subcontractors, vendors, and affiliates must complete a SJHA Questionnaire.
• Construction contractors are required to complete the Site Specific Fall Protection Plan form found in the Subcontractor Construction Resource Page.

SJHA QUESTION:

• Fall Protection: Will you be working on a ladder with your feet more than 4 feet above the floor (6 feet above the floor for Construction), on a roof, near an open manhole, or on a steep slope or hillside?
• If yes, a LBNL Fall Protection Permit may be required.    
• The Fall Protection Subject Matter Expert (SME) is contacted by email upon a subcontractor “Yes” answer to the SJHA Question above
• The Fall Protection SME verifies the fall hazard by meeting the requestor at the work site to perform a fall hazard analysis, design a fall protection system and write a Fall Protection Permit for the scope of work.

30.4 Exceptions

• Berkeley Lab’s Exception to this policy applies when authorized employees are conducting an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction/maintenance work or after such work has been completed.
• See Work Process E.2 for information about roofer and non-roofer exceptions.

30.5 Roles and Responsibilities

Role	Responsibilities
Authorized Person	Has a working understanding of Berkeley Lab’s Fall Protection Program. Has the knowledge and training necessary to properly wear and care for fall-protection equipment. Follows all fall-protection hazard controls developed by a Competent Person. Has successfully completed course EHS0276, Fall Protection (or the equivalent for subcontractors). Is authorized by his or her supervisor through either an Employee Job Hazards Analysis or a Construction Job Hazards Analysis. Service contractors must be authorized by their supervisor through the Subcontractor Job Hazards Analysis (SJHA). Retraining may be required due to changes in LBNL policy, the fall protection industry, or changes to regulatory requirements. Fall Protection Refresher training course (EHS 376 or EHS 276) is required for all LBNL employees (working at heights greater-than or equal to 4ft.) every 2 years.
Competent Person	Is able to identify fall hazards of work tasks by conducting fall hazard surveys. Stops or limits work at the hazard site. Supervises selection and use of fall protection equipment. Verifies equipment is compliant. Verifies workers are trained. Participates in investigations. Conducts equipment inspections and removes damaged equipment from service. Is authorized to take prompt corrective measures to eliminate or mitigate fall hazards. Is knowledgeable in the application and use of fall-protection equipment. Has completed a training program approved by the Berkeley Lab Environment, Health, Safety (EHS) Division’s Fall Protection Program Administrator.
Qualified Person	At Berkeley Lab, the Qualified Person is the Facilities Division Structural Engineer and/or EHS Designated Qualified Person who: Supervises the design, selection, installation, and inspection of fall protection equipment that requires specialized expertise. Participates in incident investigations. Has specialized training (to fulfill requirements such as those for registered professional engineers), has extensive knowledge and experience in fall protection, and has successfully demonstrated an ability to solve problems related to fall protection. Is responsible for designing specialized fall-protection systems and equipment, and for evaluating and approving anchorage points.
Program Administrator	At Berkeley Lab, the Fall Protection Program Administrator is assigned by the EHS Division and: Is responsible for developing, implementing, maintaining, and evaluating the Fall Protection Program. Provides guidance to all others involved with the program. Establishes a procedure to identify fall hazards. Develops fall protection and rescue procedures. Ensures training is completed. Participates in incident investigations.
User	An LBNL Authorized Person who: Has completed EHS276 Is capable of donning a harness and inspecting fall gear before each use Authorized by supervisor through Activity Manager (Work Planning and Control process) Understands the provisions of the Fall Protection Permit and the Working Alone Policy.

30.6 Definitions

Term	Definition
Active Personal Fall Restraint System	An active personal fall restraint or personal fall-arrest system (PFAS) requires specialized fall-protection equipment that must be fitted to the user and worn to control fall hazards. The user is secured to an anchorage point at all times, even while moving from point to point.
Anchorage	An anchorage is a secure point of attachment for lifelines, lanyards, or deceleration devices. These points of attachment must be independent of any anchorage being used to support or suspend platforms, and must be capable of supporting the employee attached to the anchorage system and any forces that could be applied during a fall.
Body Belt	A body belt is a strap with means both for securing it about the waist and for attaching it to a lanyard, lifeline, or deceleration device. Body belts must be at least one and five-eighths (1-5/8″) inches wide. Body belts are only effective for fall restraint and work positioning in conjunction with a full body harness, but must never be used for fall arrest.
Body Harness	A body harness are straps that may be secured about the user in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders and with means for attaching it to other components of a personal fall-arrest system.
Building	Any structure built for support, shelter, housing or enclosure of persons, animals, chattels, equipment, or property of any kind, and also includes structures wherein things may be grown, made, produced, kept, handled, stored, or disposed of. All appendages, accessories, apparatus, appliances, and equipment installed as a part of a building or structure shall be deemed to be a part thereof, but “building” shall not include machinery, equipment, or appliances installed for manufacture or process purposes only, nor shall it include any construction installations which are not a part of a building, any tunnel, mine shaft, highway, or bridge, or include any house trailer or vehicle which conforms to the Vehicle Code.
Certified Anchorage	A certified anchorage is an anchorage for fall arrest, work positioning, restraint, or rescue systems that has been certified by a Qualified Person (a) to be capable of supporting forces that could be applied during a fall or (b) to have met the criteria per ANSI Z359.2-2017.
Compatible Components	All individual components of a fall-protection system must be manufacturer-approved as compatible components. Substitution with non-compatible component combinations or subsystems is not allowed unless authorized by the Berkeley Lab Fall Protection Program Administrator, LBNL Fall Protection Competent Person, or LBNL Fall Protection Qualified Person (Berkeley Lab Structural Engineer).
Connector	A connector is a device that is used to couple (connect) a part of a personal fall-arrest system with a part of a positioning device system. It may be an independent component of the system (such as a carabiner), or an integral component of the system (such as a buckle or D-ring sewn into a body harness or a snap hook spliced with or sewn to a lanyard). These items must be made of corrosion-resistant material, and the edges must be smooth to prevent damage to other parts of the system.
Control Access Zone	A control access zone is an area with limited access where certain work may take place without the use of guardrail systems, a personal fall-arrest system, or a safety-net system. A control line (erected not less than 6 feet nor more than 25 feet from a leading edge) defines the control access zone. The control line is approximately parallel to and extends the entire length of the unprotected leading edge.
Deceleration Device	Any mechanism, such as a specially woven lanyard, a tearing or deforming lanyard, or an automatic self-retracting lanyard, that serves to dissipate a substantial amount of energy during a fall arrest or that otherwise limits the energy imposed on a user during fall arrest.
Fall Hazard Analysis	Fall hazard analysis is a general term used to describe a qualitative hazard analysis identifying fall hazards and respective controls.
Fall Restraint System	A fall restraint system prevents a person from falling from an unprotected edge or opening by using a body holding device, a connecting means of suitable length (such as a restraint lanyard), and an anchorage.
Floor Hole	Any opening in a floor or platform which is smaller than a floor opening.
Floor Opening	An opening in any floor or platform, 12 inches or more in the least horizontal dimension. It includes stairway floor openings, ladderway floor openings, hatchways, and chute floor openings.
Free Fall Distance	The length from the fall arrest attachment point on a user’s body belt or harness to the point the system applies a force to arrest the fall. This is known as the free fall distance and does not include deceleration distance or lanyard expansion.
Guardrail System	A vertical barrier erected along the open edges of a floor opening, wall opening, ramp, platform, runway, or other elevated area to prevent falls of persons.
Lanyard	A lanyard is a flexible line of rope, wire rope, or strap that generally has a connector at each end for connecting a body harness to a deceleration device, lifeline, or anchorage. For situations in which a fall arrest may occur, Berkeley Lab requires lanyards with built-in shock absorbing mechanisms for added force distribution. For fall restraint systems, lanyards without shock absorbers may be used.
Lifeline	A lifeline is a component consisting of a flexible line that is connected to an anchorage at one end to hang vertically or that is connected to anchorages at both ends to stretch horizontally, and that serves as a means for connecting other components of a personal fall-arrest system to anchorages.
Lifeline Systems (Vertical and Horizontal)	Overhead attachments that allow horizontal movement, such as beam trolleys and slide wires on cables or suspended vertical cables along uncaged equipment ladders (Ladder Safety Systems) are known as lifeline systems.
Non-certified Anchorage	A non-certified anchorage is a fall arrest anchorage that a Competent Person judges is capable of supporting the predetermined anchorage forces.
Non-Conforming Guardrails (NCG)	Non-conforming guardrails safeguards workers from nearing the edge. Between 6 and 15 feet from the edge or hole (in the case of a hole, measured from the nearest edge of the hole), a warning line system, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge.
Passive Fall Protection System (PFPS)	A PFPS is used to control fall hazards by means other than wearing personal protective equipment (PPE). Examples are guardrails, safety nets, and a warning line system.
Personal Fall Arrest System (PFAS)	A PFAS is used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a full-body harness, and a shock absorbing connecting device that may include a lanyard, deceleration device, lifeline, or a suitable combination of these. Body belts must not be used as part of a personal fall-arrest system.
Personal Fall Protection System (PFPS)	A PFPS is any dynamic system used to protect an employee from fall injury. It could be a personal fall-arrest system, a positioning device system, a lifeline system, or a retrieval system.
Positioning Device System	A positioning device system holds a worker in place while allowing a hands-free work environment at heights or that restricts the worker’s movement to avoid reaching a location where a fall hazard exists. A typical positioning device system consists of an anchorage, a body support with either a full-body harness or a body belt, and a connecting device (positioning lanyard). Because these systems are not designed for fall arrest, a backup fall-arrest system should be used.
Retrieval System	A retrieval system is used primarily when work is being done in a confined space, such as a tank or a manhole, and may require retrieval from above in an emergency. A retrieval system typically consists of an anchorage and anchorage connector, such as a tripod, a full-body harness, and a lifeline/retrieval unit.
Rope Grab	A rope grab is a deceleration device that travels on a lifeline and, by friction, automatically engages the lifeline and locks to arrest the fall of a user.
Self-retracting Lifeline/Device	A self-retracting lifeline is a deceleration device containing a drum-wound line that can be slowly extracted from or retracted onto the drum under slight tension during normal employee movement, and that, after the onset of a fall, automatically locks the drum and arrests the fall.
Self-retracting Lifeline-LE Energy Absorber LE (Leading Edge)	A self-retracting lifeline-LE energy absorber is a self-retracting lanyard tested for horizontal use and falls over a steel edge without burrs. As a result, the device may be used in situations where a fall may occur over similar edges, such as found on steel shapes or metal sheeting.
Suspension Trauma	Suspension Trauma, also known as, Harness Hang Syndrome (HHS), or Orthostatic Intolerance, is an effect which occurs when the human body is held upright without any movement for a period of time. If the person is strapped into a harness or tied to an upright object they will eventually suffer the central ischemic response (commonly known as fainting). If one faints but remains vertical, one risks death due to one’s brain not receiving the oxygen it requires.
User (Authorized Person)	A person at Berkeley Lab who is currently trained in fall protection, has demonstrated appropriate skills in using fall-protection equipment, and has been approved by his/her supervisor to take part in activities that may involve fall hazards.
Warning Line System	An edge-proximity warning line system is used when working on a work surface higher than 6 feet and having an unprotected edge. The warning line physically denotes a boundary placed between 6 feet and 15 feet from the roof edge or open hole, inside of which workers can perform tasks without additional fall protection measures.
Work Surface	Work surfaces include: leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 1.2:1 (horizontal to vertical) hillsides, roofs, and surfaces with open holes or skylights.

30.7 Required Work Processes

Work Process A. General Requirements
Work Process B. Fall Protection Equipment Procurement
Work Process C. Authorization and Training
Work Process D. Hazard Assessment 
Work Process E. Work Control Requirements 
Work Process F. Fall Protection Equipment 
Work Process G. Passive Fall Protection Systems 
Work Process H. Active Fall Protection Systems 
Work Process I. Hazards Requiring Evaluation for Fall Protection 
Work Process J. Off-Site Fall Protection 
Work Process K. Covers 
Work Process L. Protection from Falling Objects 
Work Process M. Walking Working Surfaces
Work Process N. Leading Edge Work 
Work Process O. Hoist Areas 
Work Process P. Working Near Holes 
Work Process Q. Formwork and Reinforcing Steel 
Work Process R. Ramps, Runways, and Walkways 
Work Process S. Working Near Excavations 
Work Process T. Working Near Dangerous Equipment 
Work Process U. Overhead Bricklaying and Related Work 
Work Process V. Low Sloped Roofs
Work Process W. Steep Sloped Roofs 
Work Process X. Precast Concrete Erection 
Work Process Y. Residential Construction 
Work Process Z. Wall Openings

Work Process A. General Requirements

1. Written Fall Protection Permit.  A Written Fall Protection Permit is required for any task requiring fall protection. Table A-1 below provides a matrix of required Written Fall Protection permits and work authorizations.

Table A-1. Matrix of Required Written Fall Protection Permits

Worker Category	Required Fall Protection Authorization	Who Completes	Who Approves	ES&H Manual Reference
Berkeley Lab employee: Facilities Division personnel	Fall Protection Permit	Berkeley Lab Fall Protection Competent Person	Supervisor	This Work Process
Berkeley Lab employee: researcher, PI, others	Fall Protection Permit	Berkeley Lab Fall Protection Competent Person	Supervisor	This Work Process
Construction contractor (CFHA)	Construction Fall Protection Plan and Fall Protection Permit	Construction Contractor, Fall Protection Competent Person	Facilities Division responsible Project Manager	This Work Process
Directly supervised non-construction subcontractors, vendors, and affiliates	Fall Protection Plan and Fall Protection Permit	Berkeley Lab Fall Protection Competent Person	Berkeley Lab supervisor responsible for the work activity	This Work Process
Not directly supervised non-construction subcontractors, vendors, and affiliates	sJHA Form, a LBNL Fall Prevention Plan and Fall Protection Permit	Subcontractor, vendor, or affiliate who is a Competent Person	Berkeley Lab Requisitioner	Chapter 31 Chapter 31  This Work Process

2. Fall Protection Rescue

Rescue is an integral element of planning for work when exposed to a fall hazard or when using a personal fall-arrest system. Under most circumstances, Berkeley Lab relies primarily on Alameda County Fire Department (ACFD) as their designated rescue provider. The ACFD has a fire station located at the Laboratory, and the firefighters at this station are trained in technical rescue. A response time of four to six minutes is expected under normal circumstances. In addition, the Alameda County Fire Department maintains a heavy rescue company that can be called for both onsite standby (advance notice required) or emergency response when needed (approximately 40 minutes response time). Offsite and remote field work may need to designate alternate rescue providers on a case by case basis. That designation will be documented and formalized prior to any off site work or work in remote locations requiring the use of a Personal Fall Arrest System. 

Workers cannot stay suspended for long and are at risk of reduced blood flow, oxygen deprivation, brain damage, cardiac arrest and death. According to the American National Standards Institute (ANSI) Standard Z359, the recommended goal for rescue subject first contact should be less than six minutes. All workers using fall arrest systems must be monitored and promptly rescued in the event of a fall. What constitutes prompt rescue can vary depending on the circumstances. LBNL employees required to utilize a fall arrest system are required to wear suspension trauma rescue straps during work with fall hazards or any time a Personal Fall Arrest System is used.

Berkeley Lab uses the Fall Protection Permit to document rescue services and planning including contact with ACFD and any subsequent planning required. Fall Protection Rescue Planning requirements are detailed below in Table XX.  ACFD must be contacted in advance of any work requiring the use of a Personal Fall Arrest System and a written Fall Protection Rescue Plan developed. ACFD must be notified by email at ACFD@lbl.gov. The ACFD contract University Technical Representative (UTR) must submit training documentation meeting the requirements of ANSI Z359.4-2013 (R2022) for all rescue personnel, proof of periodic (at least annual) assessments of the effectiveness of rescuer training, and proof of inspection and maintenance of all rescue equipment to the LBNL Fall Protection Program Manager annually. In cases where contractors/vendors designate their own Rescue Service Provider, a written Fall Protection Rescue Plan meeting the requirements in ANSI Z359.4-2013 (R2022) must be submitted to the Fall Protection Competent Person in advance and must include at a minimum the following:

• Name and Contact information of the Designated Rescue Provider
• Fall Protection Rescue Competent Person and Qualified Person
• Rescue system components 
• Logistical Diagrams
• List of trained rescue personnel onsite during Personal Fall Arrest Systems use
• Training documentation meeting the requirements of ANSI Z359.4-2013 (R2022)
• Proof of periodic assessments (at least annually) of the effectiveness of rescuer training
• Any other documentation necessary to properly characterize the rescue requirements

Table A-2 Fall Protection Rescue Planning Requirements

Fall Protection Control	LBNL Employee/Affiliate  Rescue Planning Requirements	Construction Contractor or Non-construction Vendor Rescue Planning Requirements
Engineering Controls	Not Applicable	Not Applicable
Passive Fall Protection Systems	Not Applicable	Not Applicable
Personal Fall Restraint Systems	Fall Protection Permit with documented Personal Fall Restraint Systems	Project Specific Fall Protection Plan and Fall Protection Permit with documented Personal Fall Restraint Systems
Personal Fall Arrest Systems	Fall Protection Permit and documented ACFD (or alternate rescue provider) Rescue Plan	Project Specific Fall Protection Plan, Fall Protection Permit, and documented Rescue Plan (ACFD or contractor designated rescue provider)
Administrative Controls	Fall Protection Permit at a minimum. Fall Protection Rescue Plans may be required as determined on a case by case basis by the Fall Protection Competent Person	Fall Protection Permit at a minimum. Fall Protection Rescue Plans may be required as determined on a case by case basis by the Fall Protection Competent Person

Work Process B. Fall Protection Equipment Procurement

1. Identifying Required Fall Protection Equipment 
   1. Personal fall-protection systems (PFPSs) consist of three components:
      1. An anchorage with anchoarge connector, commonly referred to as a tie-off point
      2. Body support, usually a full-body harness
      3. A connecting device such as a shock-absorbing lanyard
         
         Individually, these components will not provide protection from a fall. However, when used properly in conjunction with each other, they form a personal fall-arrest system (PFAS), an important element of the overall Fall Protection Program.
         
         
   2. Five functional categories of PPE for fall protection are available:
      1. Fall-arrest systems
      2. Positioning/restraint systems
      3. Suspension systems
      4. Retrieval systems
      5. Passive systems e.g. warning lines, non-conforming guardrails, CAZ zones, and safety monitors.  Passive fall protection systems do not provide a secondary fall protection system, they are designed to warn and keep workers away from fall hazards, see Appendix 3 for Fall Protection Safety Monitor OJT Training Checklist, in conjunction with Appendix 4, the LBNL Active Fall Protection Infeasibility Plan.
   3. Only a fall-arrest system will protect a worker who has fallen from elevation.
   4. The Competent Person must ensure that an Authorized Person who uses fall-protection equipment is provided with appropriate equipment that fits properly. The specific type of fall protection required is determined by the Competent Person.
   5. Usage of horizontal life-lines and SRL-LE’s require approval by the LBNL Fall Protection Qualified Person or the LBNL Fall Protection Subject Matter Expert (SME).

2. Obtaining Fall Protection Equipment. Berkeley Lab organizations purchase their own personal fall arrest equipment. The Fall Protection Program administration assists these organizations in selecting the right equipment. An adequate supply of regularly used harnesses, lanyards, anchorage point connectors, and other equipment in appropriate sizes should be available near the work area. PFAS equipment is a controlled item for procurement purposes, and procurement personnel must ensure that the EHS Division approves all purchases.

Flowchart B-1. LBNL Fall Protection Equipment and Inventory Processes

Work Process C. Authorization and Training

1. Authorization. An approved Fall Protection Plan and a Fall Protection Permit is required for any task requiring fall protection. See Written Fall Protection Permit  of Work Process A, General Requirements.
2. Fall Protection Training Requirements. The table below lists required training for Authorized Persons (Berkeley Lab workers including employees, affiliates, and directly supervised subcontractors), Fall Protection Competent Persons, and Fall Protection Qualified Persons:

Who	Requirement
Authorized Person (LBNL or Subcontractor)	Only trained Authorized Persons may use fall protection equipment. Successfully complete Berkeley Lab training course EHS0276, Fall Protection and EHS0376, Fall Protection Refresher Course every 2 years thereafter or equivalent. Recognize fall hazards. Follow specific procedures to minimize these hazards. Properly select (under the direction of a Fall Protection Competent Person), use, and maintain the equipment. Be authorized by their supervisor or work leader.
Competent Persons (LBNL or Subcontractor)	Must be qualified to: Identify the fall hazards of work tasks. Conduct fall hazard surveys. Stop or limit work at the hazardous site. Supervise selection and use of fall protection equipment. Verify that equipment is compliant and workers are trained. Participate in investigations. Conduct equipment inspections. Remove damaged equipment from service. Must complete EHS377 Fall Protection Competent Person Training or equivalent. Must complete EHS378 Fall Protection Competent Person Refresher every 2 years and/or complete certification maintenance or equivalent as determined appropriate by the Fall Protection Program Administrator. The Fall Protection Competent Person Program is administered by the Fall Protection Program Administrator. Off-Site Users must complete EHS375 Fall Protection Competent Person for Researchers. Write Fall Protection Permit. Record Fall Protection Permit into the database.
Qualified Persons (LBNL or Subcontractor)	Through education, training, and/or professional certification shall have the knowledge and understanding of applicable fall protection regulations, standards, equipment/systems, engineering principles, and LBNL requirements. This must include a registered, California licensed engineer responsible for the design, selection, installation, and inspection of certified anchorages and horizontal lifelines and whose seal appears on the structural design documents. Understands and implement the Fall Protection Hierarchy of Controls Supervises the design, selection, installation, and inspection of certified anchorages and horizontal lifelines. When supervising the design, installation or selection of a fall arrest anchorage, the qualified person shall calculate the forces generated by an arrested fall, the total loading, and the deflection of the fall arrest anchorage; the impact on the structural members to which the fall arrest system is attached; and shall determine a safe location for the anchorage.
Subcontractors Using the SJHA System	All subcontractors are required to provide training documentation for each worker who might be exposed to a fall hazard. Training documents must be provided prior to work and must include documented “Certification of Training”.

Work Process D. Hazard Assessment

1. WPC based hazard analysis and Work Planning Controls. All Berkeley Lab employees are required to perform work according to their approved activities in the Work Planning Control Activity Manager (WPC). The Work Planning Control Activity Manager identifies the tasks, hazards, and controls of a worker’s normal work assignments performed on a regular basis. If the Work Planning Control Activity Manager identifies working at heights as a normal job assignment, fall protection training is required.
2. Scaffolding 
   1. The exposure hazard during erection and dismantling of a scaffold is many times greater than the exposure while working on a scaffold. LBNL requires the Competent Person develop a written LBNL Fall Protection Plan (FPPP) that can be found on the Subcontractors Resource Page. The written FPPP must be submitted for approval by the Berkeley Lab Construction Project Manager and Fall Protection Subject Matter expert (SME) for review prior to commencing the operation.
   2. The employer (i.e., LBNL or the subcontractors) must provide safe means of access for each employee erecting or dismantling a scaffold where the provision of safe access is feasible and does not create a greater hazard. The employer must have a Competent Person determine whether it is feasible or would pose a greater hazard to provide and have employees use a safe means of access. This determination will be based on site conditions and the type of scaffold being erected or dismantled. 
3. Steel Erection 
   1. The height allowances permitted for fall protection on Steel Erecrtion (29 CFR 1926.760) is not allowed to LBNL. Steel erection is a high fall hazard activity. Written and verbal Plans for steel erection are required prior to commencement of work, at ground level. Coordinate with the fabricator for the attachment of anchorages and cables for the majority of the erection sequence. Written and verbal plan of all routes of travel must occur before the start of work. Use quick-release methods for the release of rigging when possible.
   2. Free climbing is prohibited. Walking on beams that have a top flange of less than a 6-inch width is also prohibited.
   3. Installation or modification of decking material is the most dangerous phase of steel erection. A Controlled Decking Zone must be established and all affected workers must be trained. Perimeter guardrail must be erected as soon as decking is installed.
4. Tree Trimming 
   1. Landscaping personnel at Berkeley Lab must use fall arrest/restraint, positioning, or rope access systems when performing elevated tree work.  Landscaping personnel at Berkeley Lab must use fall restraint systems when performing elevated tree work from aerial lifts. Working at heights is also done from ladders, and workers must conform to Chapter 35 Elevated Work – Aerial Work Platforms, Ladders, and Scaffolds processes A-H.
   2. A professional tree service must complete a detailed LBNL Fall Prevention Plan (FPPP) and a SJHA (see Chapter32). The JHA and the FPPP must be submitted to a Berkeley Lab Construction Safety Specialist and the Fall Protection SUbject Matter Expert (SME) for review and approval prior to the start of work.
5. Roofing Installation and Repair 
   1. Roofers must:
      1. Complete an LBNL Fall Prevention Plan and a Fall Protection Permit to help evaluate the hazards of the job and select the most appropriate hazard control.
      2. Complete a JHA (see JHA for Roofers). The JHA is to be submitted to the Berkeley Lab EHS Division Construction Safety Specialist (who is a Competent Person) for the supervisor’s review and approval prior to the start of work.
      3. Have specified training.
      4. Always set up a warning line system at least 6 feet back from the edge on roofs greater-than 50 feet in width.  When using felt-laying machines or other equipment that is pulled by an operator who walks backwards or motorized equipment on which the operator rides, headers shall be placed no closer than 10 feet from the roof edge and a warning line no closer than 6 feet from the roof edge.
      5. Use Safety Monitoring System approved by the Fall Protection Subject Matter Expert (SME) on roofs less-than 50ft. in width.  Safety Monitor systems are not allowed if using felt-laying machines or other equipment that is pulled by an operator who walks backwards or motorized equipment on which the operator rides.
   2. Roofers may use a monitor system instead of other fall protection systems when working outside the warning line system only when other systems are determined to be infeasible.
   3. Non-roofers Performing Work on Roofs: Non-roofers performing work on roofs must complete a LBNL Fall Prevention Plan (FPP) and a Fall Protection Permit to help evaluate the hazards of the job and select the most appropriate hazard control. If a warning line is selected as the appropriate work control, the warning line system must be set up 6 feet from the edge of the roof and signs posted to warn unauthorized employees from accessing the controlled access zone.
6. Fixed Ladders 
   1. Any fixed ladder of more than 24 feet to a maximum unbroken length of 30 feet installed before November 19, 2018 must be equipped with a personal fall arrest system, ladder safety system, cage, or well; no landing platform is required in these cases.  All ladders and ladder safety devices must be maintained in a safe condition and be inspected at intervals determined by use and exposure. Inspection records must be maintained by the Facilities Division.
   2. Any fixed ladder of more than 24 feet to a maximum unbroken length of 30 feet installed on or after November 19, 2018, must be equipped with a personal fall arrest system or a ladder safety system;
   3. When a fixed ladder, cage, or well, or any portion of a section thereof, is replaced, a personal fall arrest system or ladder safety system must be installed in at least that section of the fixed ladder, cage, or well where the replacement is located;
   4. On or after November 18, 2036, all fixed ladders of more than 24 feet to a maximum unbroken length of 30 feet must be equipped with a personal fall arrest system or a ladder safety system.
   5. All new fixed ladder installations must be designed and installed in compliance with American National Standard A14.3-2018 American National Standard for Fixed Ladder Safety Requirements.
7. Maintenance at Elevated Locations. Maintenance personnel are often faced with repairs and service of roof-mounted or unguarded platform-mounted equipment. All fall protection requirements stated in this document are required for maintenance personnel, including the specified training and the use and care of equipment. In lieu of using personal fall-arrest systems, other systems are available for the protection of workers, at the discretion of the Competent Person, including: temporary guardrails, safety nets, fall restraints, warning line systems, controlled access zones, and fall protection plans, as discussed in this document. Contact your EHS Fall Protection SME for specific information on fall protection requirements.
8. Confined Space Considerations. In most confined space situations, the use of harnesses are for rescue and extraction purposes. However, due to the almost unlimited configurations of confined spaces, normal fall protection may also be considered.
9. Exceptions. These exceptions are applicable only after careful evaluation has determined that fall protection cannot be used.
   1. Provisions do not apply when employees are conducting:
      1. An inspection (no tools)
      2. An investigation
      3. An assessment of workplace conditions either prior to the start of work or after all work has been completed
   2. Work can be done on a flat or low-sloped roof without fall protection if it is performed at least 15 feet from an unprotected edge (NCG/Non-conforming Guardrails or Warning lines with a 15ft. setback) and a warning line has been established.
   3. All workers using a Warning-line, Controlled Access Zone, Safety Monitor, Non-Conforming Guardrail, or Control Zone system must successfully complete FALL PROTECTION SAFETY MONITOR ON-THE-JOB TRAINING and an Infeasibility Plan signed by the Fall Protection Program Manager/SME.

Work Process E. Work Control Requirements

1. Fall Protection Work Control Requirements
   1. The height triggers for fall protection are 4 feet for General Industry workers, and 6 feet for Construction workers. See the LBNL Trigger Height in Appendix 4 of this program.
   2. Fall protection work controls are required under the following conditions:
      1. Any work task on a walking/working surface with an unprotected side or edge that is above the height limitation.
      2. Any work task on an aerial lift or when working above the protection system near floor openings, and unprotected perimeters while operating the aerial lift.
      3. Any work task performed by steel erectors and sheet metal installers at heights greater than 6 feet.
      4. Any work on portable ladders when working above the protection system at floor openings, and unprotected perimeters.
      5. Any use of a portable ladder when working at a height greater than, or equal to 6 feet and below the third rung (from the top of the ladder), when the user cannot maintain three-point contact (consisting of two feet and one hand) at all times. See Chapter 35 Elevated Work – Aerial Work Platforms, Ladders and Scaffolds.
2. Exceptions. Fall protection work controls are not required under the following conditions:
   1. For non-roofers only. Work on a flat or low-sloped roof (slope of less than 4 in 12) when all of the following conditions are met:
      1. All work is conducted at least 15 feet from any unprotected edge.
      2. A warning line is used to denote the 15-foot distance.
      3. No work activities take place between the warning line and the unprotected edge.
      4. Workers follow the work rule of not going past the warning line.
      5. All workers have successfully completed LBNL Safety Monitor Training.
   2. For Scaffolding
      1. During scaffold erection and dismantling, when all of the following conditions are met:
         1. The designated Competent Person overseeing the operation has determined that active fall protection is infeasible.
         2. The Competent Person has drafted a written Fall Protection Plan that meets the Cal/OSHA requirements 8 CCR 1635.1-1667.
         3. The Competent Person has submitted the Written Fall Protection Plan to Berkeley Lab Project Management for review and approval prior to commencing the operation.
      2. Climbing up and down ladders less than 24 feet, while maintaining three points of contact.
      3. Work from ladders above 6 feet and below the third rung when the worker can maintain three-point contact (consisting of two feet and one hand) at all times.
      4. Work from platform ladders when the worker can demonstrate that work can be done safely inside the rails of the ladder.
   3. Fall Protection Plan. This option is available only to employees engaged in:
      1. Leading edge work, precast concrete erection work, or residential construction work.
      2. When the employer can demonstrate that it is infeasible or creates a greater hazard to use active fall protection systems.
      3. The employer shall develop and implement a fall protection plan, which meets the requirement of the (link to Appendix 5) LBNL Active Fall Protection Infeasibility Plan.
      4. The LBNL Active Fall Protection Infeasibility Plan must be reviewed and signed by the Fall Protection Program Manager, the Fall Protection Qualified Person, and the Responsible Individual for the project.
   4. All work can be performed from the platform or podium ladder under the following conditions:
      1. The worker(s) have completed an approved ladder training course.
      2. The ladder has been inspected before use by the worker(s).
      3. There are no additional hazards that affect the stability of the ladder, e.g. slopes, or unprotected edges (ladders near guard railed areas), or uneven surfaces, and or unprotected machinery in which a worker could be injured by a fall. 
      4. The worker can maintain stability as work is performed inside the safety envelope of the platform or podium ladder, e.g. by not over extending the worker’s center of gravity from the ladder’s center of gravity.  
3. Work Control Processes. Berkeley Lab’s Fall Protection Program is implemented through three work-control processes applicable to the three categories of workers who may perform work tasks requiring fall protection. These three worker categories are: (a) Berkeley Lab employees (See Work Control Process for Berkeley Lab Employees, Work Control Process for Berkeley Lab Facilities Division Employees, and Work Control Process for Other Employees); (b) construction contractors (SeeFall Protection Work Control Process for Construction Contractors);  and (c) non-construction subcontractors, vendors, and affiliates performing hands-on work (See Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, and Affiliates).
4. Work Control Process for Berkeley Lab Employees
   1. The fall-protection work-control process for Berkeley Lab employees performing work tasks at heights is managed through the Activity Manager Work Planning Control (WPC) process and the Maximo® work-request system, as illustrated in Flowchart E-1, below.
   2. Berkeley Lab employees who perform work at heights requiring fall protection work controls, which can be grouped into two broad categories:
      1. Facilities Division maintenance or construction employees
      2. Other employees, including researchers
5. Work Control Process for Berkeley Lab Facilities Division Employees
   1. Fall-protection work controls for Berkeley Lab Facilities Division employees are managed through the Maximo® work-request system and consist of:
      1. Identifying work activities in the Activity Manager to indicate job assignments that require working at heights.
      2. Determining that such work can be accomplished as a Work Planning Control, with the subsequent completion of the work by an employee having an appropriate WPC.
      3. Determining that such WPC activities developed in the Activity Manager, approve employees to acquire a Fall Protection Permit or perform work through the application of an Engineered Fall Protection Plan (e.g., for roofing and HVAC work) as applicable.
      4.  Berkeley Lab employees must use fall restraint systems (with adjustable 6ft. lanyards) when performing elevated work from aerial lifts, or performing work on hillsides using rope-grab systems (RGS) or Safety Monitor System for Hillside Work  when applicable.
   2. The Fall Protection Permit is developed by a Berkeley Lab Fall Protection Competent Person and approved by the employee’s supervisor or work lead.
   3. When required, an Engineered Fall Protection Plan is developed by the Qualified Person (Berkeley Lab Structural Engineer or equivalent) and implemented by a Berkeley Lab Fall Protection Competent Person.
6. Work Control Process for Other Employees. Fall protection work controls for other employees are managed through the Fall Protection Permit process and consist of:
   1. Using the Activity Manager WPC process to identify job assignments that require working at heights.
   2. Following the WPC by completing a Fall Protection Permit. The Fall Protection Permit is developed and implemented by a Berkeley Lab Fall Protection Competent Person and approved by the employee’s supervisor or work lead.
7. Fall Protection Work Control Process for Construction Contractors
   1. The fall protection work control process for construction contractors performing work tasks at heights is managed through the Berkeley Lab contractor bid, selection, and Construction Fall Prevention Plan (FPPP) approval process illustrated in Flowchart E-2, below.
   2. When a construction project requires working at heights, Berkeley Lab notifies project bidders of such tasks during the bid job walk. Requirements for fall protection work controls are then identified through the construction package documents and the Site Specific Safety Plan. A LBNL written Construction Fall Prevention Plan (FPP) is then developed by the contractor and submitted to the EHS Construction Safety Specialist who is also a Berkeley Lab Fall Protection Program Competent Person. Upon review and approval of the LBNL written Construction Fall Prevention Plan (FPP) , the contractor is issued a notice to proceed, and the LBNL written Construction Fall Prevention Plan (FPP) is implemented by the contractor Competent Person.
8. Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, and Affiliates. The fall protection work control process for non-construction subcontractors, vendors, or affiliates performing work tasks at heights is managed through the Work Control Process for Berkeley Lab Non-construction Subcontractors, Vendors, or Affiliates described in Flowchart E-3, below.
   1. While working at Berkeley Lab, non-construction subcontractors, vendors, or affiliates are either under the direct supervision of Laboratory personnel or work independently of such supervision.
   2. Fall protection work controls for non-construction subcontractors, vendors, or affiliates who are under the direct supervision of Lab personnel are managed through the Fall Protection Permit process, which consists of:
      1. Identifying job assignments, through the Individual Baseline JHA process, that require working at heights.
      2. Developing a Task-Based JHA through completion of a Fall Protection Permit. The Fall Protection Permit is developed and implemented by a Berkeley Lab Fall Protection Program Competent Person.
   3. Fall protection work controls for non-construction subcontractors, vendors, or affiliates who are not under the direct supervision of Lab personnel are managed through the Subcontractor Job Hazards Analysis and Work Authorization (SJHA) Form, which requires:
      1. Identifying job assignments that require working at heights by the requisitioner.
      2. Submitting the blank SJHA Form by the Berkeley Lab Buyer to the subcontractor or vendor.
      3. Completing the SJHA Form by the requisitioner.
      4. Determining low- or high-hazard tasks by the requisitioner.
      5. Develop a Fall Protection Permit for high-hazard tasks requiring the use of fall protection.
      6. Review and approval of the SJHA Form by:
         1. The SME and Program Manager if the work involves high hazard tasks.
         2. The SJHA Form by the Requestor, DSA and Program Manager if the work involves low-hazard tasks.

Flowchart E-1. Fall Protection Work Control Process for Berkeley Lab Employees

Flowchart E-2. Fall Protection Work Control Process for Construction Subcontractors 

Flowchart E-3. Fall Protection Work Control Process for Non-construction Subcontractors, Vendors, or Affiliates

Work Process F. Fall Protection Equipment

1. Control of Fall Protection Equipment: Any equipment found to be defective, damaged, or in need of maintenance must be immediately removed from use, marked as “UNUSABLE,” and immediately destroyed or repaired if possible according to manufacturer’s directions. Contact the Fall Protection SME.
2. Storage and Maintenance of Fall Protection Equipment: The Competent Person and Authorized Person must ensure that PFPS equipment is stored to avoid cutting, excessive bending, stress on components, excessive heat, and contact with water or chemicals. Maintenance, including cleaning, must be performed only as directed by the manufacturer.
3. Inspection of Fall Protection Equipment: Two types of inspections, formal and pre-use, are required:
   1. Formal inspections are performed by a Competent Person. The Competent Person performing the formal inspection must inspect each piece of in service personal fall-arrest system (PFAS) equipment not less than twice annually. The EHS Health and Safety Department maintains a PFAS equipment inventory that also serves as an inspection database. When equipment is inspected, a metal tag with the inspection expiration date is placed on equipment. Equipment should only be used if the inspection is current. The formal inspection procedure is specified below in Procedures for Formal Inspection of Fall Protection Equipment.
   2. Pre-use inspections. Prior to each use, users must inspect their own fall protection equipment for damage, wear, and other defects. CAUTION: Only the manufacturing company or parties with written authorization from the manufacturer may make repairs to the equipment.
4. Procedures for Formal Inspection of Fall Protection Equipment: The formal inspection procedure is similar to the pre-use inspection. However, it differs in three important respects:
   1. It is performed by a Competent Person who is trained and authorized to perform a formal inspection for the user’s organization.
      1. The equipment must be inspected by a Competent Person, other than the user, at least annually. The Competent Person should perform a methodical and thorough visual and tactile inspection by following the appropriate inspection procedure (see the paragraphs below in this section). If the equipment passes Formal Inspection, the Competent Person must attach an inspection tag to the equipment.
   2. It is more detailed and is methodically recorded annually in a Formal Inspection Form that is kept on file for future reference and is documented by the Competent Person on the Fall Protection Permit Form throughout the year.
      1. Inspection recordkeeping is needed to trace detected defects to their causes. An inspection log must be kept, and inspection forms must be maintained for one year after the date of inspection. The Formal Inspection Form has been developed following the guidelines set forth by and in compliance with the manufacturer’s instructions.
   3. It results in final disposition of the equipment as either “acceptable” or as “not acceptable” followed by destruction of the product.
5. Procedure for Pre-use Inspection of Fall Protection Equipment

Step 1: Inspect the labels to verify that they are present and legible. Check to be sure a Formal Inspection has been performed within 12 months. This can be indicated by colored tape on the item or inspection labels indicating the date inspected or date due. If the Formal Inspection has not been performed within 12 months or if any labels are missing or illegible, remove the equipment from use and mark it as “UNUSABLE” until a formal inspection is performed by a Competent Person.

Step 2: Inspect all webbing and stitching for cuts, fraying, pulled or broken threads, abrasion, excessive wear, altered or missing straps, burns, and heat or chemical exposures.

Step 3: Inspect all metallic parts (e.g., D-rings, oval rings, buckles, adjusters, and grommets) for deformation, fractures, cracks, corrosion, deep pitting, burrs, sharp edges, cuts, deep nicks, missing or loose parts, improper function, and evidence of excessive heat or chemical exposure.

Step 4: Inspect all plastic parts (e.g., strap collars, labels, tool belt support clips) for cut, broken, excessively worn, missing, and loose parts. Inspect for evidence of burns and excessive heat or chemical exposures.

Step 5: Inspect each component and subsystem of the complete system in accordance with the associated manufacturer’s instructions.

CORRECTIVE ACTION: Defects, damage, excessive wear, and/or aging are generally not repairable. If detected, immediately remove the equipment from use, and mark it as “UNUSABLE” until destroyed. For final disposition, submit the equipment to a Competent Person who is authorized to perform a Formal Inspection.

Work Process G. Passive Fall Protection Systems

Using a passive fall-protection system (PFPS) indicates the fall hazard is controlled by means other than the wearing of personal protective equipment (PPE). Examples of a PFPS are: guardrails, safety nets, and warning lines.

All passive fall-protection systems require vigilance, whether through pre-work inspections, group instructions, or other means of communication.

1. Guardrails 

The most common passive fall-protection system is a guardrail.  A standard guardrail shall consist of top rail, midrail or equivalent protection, and posts, and shall have a vertical height within the range of 42 inches to 45 inches from the upper surface of the top rail to the floor, platform, runway, or ramp level. (Note: the permissible tolerance on height dimensions is one inch). The top rail shall be smooth-surfaced throughout the length of the railing. The midrail shall be approximately halfway between the top rail and the floor, platform, runway, or ramp. The ends of the rails shall not overhang the terminal posts, except where such overhang does not constitute a projection hazard. All guardrails and other permissible types, including their connections and anchorage, shall be designed for a live load of 200 pounds per linear foot applied either horizontally or vertically downward at the top rail unless the minimum value of railing strength specified is inadequate for safety under operating conditions. Where toeboards are required, the top of the toeboard shall be not less than 3 1/2 inches above the platform, walkway, or other working level and the bottom clearance shall not exceed 1/4-inch.

Buildings.  Guardrails shall be provided on all open sides of unenclosed elevated work locations, such as: roof openings, open and glazed sides of landings, balconies or porches, platforms, runways, ramps, or working levels more than 30 inches above the floor, ground, or other working areas of a building Where overhead clearance prohibits installation of a 42-inch guardrail, a lower rail or rails shall be installed. The railing shall be provided with a toeboard where the platform, runway, or ramp is 6 feet or more above places where employees normally work or pass and the lack of a toeboard could create a hazard from falling tools, material, or equipment.

EXCEPTIONS:

1. Stationary elevated platforms secured to buildings or structures used exclusively for the service and maintenance of overhead bridge cranes and similar mobile equipment may be equipped with removable railings in lieu of guardrails on the side adjacent to the machinery provided such railings are secured against falling when they are not serving as a protective railing. In existing installations where clearance prohibits railings on the outside of the platform, railings will be permitted on the building side to serve as handholds.
2. Portions of loading or storage platforms which are used primarily for loading or unloading trucks and/or cargo handling.
3. Open-sided platforms or floors used for storage of lumber or other materials may be guarded with movable single rails, sliding panels, gates or other barriers provided they are of strength and design equivalent to guardrails.
4. Open sides of storage platforms less than four feet wide, or portions thereof which are loaded and unloaded exclusively by means of stackers or lift trucks handling pallet supported loads.
5. Platforms, runways, ramps, or other working levels less than 4 feet above floor, ground, or other working level constructed prior to January 1, 1967.
6. On outside plaza, patio, and garden areas, alternate means of protection are acceptable if the same degree of safety is provided.
7. Elevated locations used infrequently by employees if the employees using them are protected by a fall restraint/fall arrest system.
8. On the auditorium side of a stage, raised platforms and other raised floor areas such as runways, ramps and side stages used for entertainment or presentation. At vertical openings in the performance area of stages.

Other Elevated Locations. The unprotected sides of elevated work locations that are not buildings or building structures where an employee is exposed to a fall of 4 feet or more shall be provided with guardrails. Where overhead clearance prohibits installation of a 42-inch guardrail, a lower rail or rails shall be installed. The railing shall be provided with a toeboard where the platform, runway, or ramp is 6 feet or more above places where employees normally work or pass and the lack of a toeboard could create a hazard from falling tools, material, or equipment.

EXCEPTIONS:

1. Portions of loading or storage platforms which are placed or located next to trucks and used primarily for loading or unloading trucks.
2. Open sides of storage platforms less than four feet wide, or portions thereof which are loaded and unloaded exclusively by means of stackers or lift trucks handling pallet supported loads.
3. Portable platforms, portable or fixed work stands, where used in close quarters which would make the installation of guardrails impracticable, may be provided with removable or hinged railings which can be either removed or swung out of the way during such work. Toeboards may not be required on portable or fixed platforms where the nature of the work requires the employees to sit on the edge of the platform.
4. Elevated locations used infrequently by employees if the employees using them are protected by a fall restraint/fall arrest system.
5. On mobile vehicles/equipment, where the design or work processes make guardrails impracticable, the use of sufficient steps and attached handholds or structural members which allow the user to have a secure hand grasp shall be permitted. Work from the decks, permanent/stationary platforms, runways, or walkways of mobile vehicles/equipment shall be excluded from the requirements of subsection (b) where it can be shown that guardrails or handholds are impracticable by the design or work processes.
6. Where design or erection, dismantling, inspection, repair, maintenance and adjustment processes make installation of guardrails impracticable on portable amusement rides, employees shall be provided and shall install and use personal fall protection equipment.
7. Where the guardrail requirements of subsections (a) and (b) are impracticable due to machinery requirements or work processes, an alternate means of protecting employees from falling, such as personal fall protection systems, shall be used.
8. Every ladderway floor opening or platform with access provided by ladderway, including ship stairs (ship ladders), shall be protected by guardrails with toeboards meeting the requirements of General Industry Safety Orders, Section 3209, on all exposed sides except at entrance to the opening. The opening through the railing shall have either a swinging gate or equivalent protection, or the passageway to the opening shall be so offset that a person cannot walk directly into the opening. EXCEPTION: Ladder openings for entrance/access at perimeter roof edges where guardrail protection is not required at locations where there is a routine need for any employee to approach within 6 feet of the edge of the roof. When intermittent work is being done safety belts and lanyards, or an approved fall protection system may be provided in lieu of guardrails.

For the purpose of this requirement, routine need means more than four times a year and intermittent work means work not exceeding four times a year.

Guardrails required by subsection (d)(1) shall be provided along the roof edge extending at least 6 feet beyond the areas occupied by persons accessing, servicing or repairing permanently-mounted machinery and/or equipment.

Where fall protection systems are used, safety lines and/or lanyards shall be attached to a sufficient anchorage. A safe and unobstructed access shall be provided to all work locations. 

2. Safety Nets 

Safety nets are an option in certain cases. Where the elevation is 25 feet or more above the ground, water surface, or continuous floor level below, and when the use of personal fall arrest systems, personal fall restraint systems, positioning device systems or more conventional types of protection are clearly impractical, the exterior and/or interior perimeter of the structure shall be provided with an approved safety net extending at least 8 feet horizontally from such perimeter and being positioned at a distance not to exceed 10 feet vertically below where such hazards exist, or equivalent protection provided safety nets shall extend outward from the outermost projection of the work surface as follows:

Vertical distance from working level to horizontal plane of net	Minimum required horizontal distance of outer edge of net from work surface edge
Up to 5 feet	8 feet
More than 5 feet up to 10 feet	10 feet
More than 10 feet but not to exceed 30 feet	13 feet

Nets shall be hung with sufficient clearance to prevent user’s contact with the surfaces or structures below. Such clearances shall be determined by impact load testing.

3. Warning Line Systems
   1. Roofers
      1. A warning line must be erected not less than 6 feet from the roof edge.
      2. No worker is allowed in the area between the warning line and the roof edge without active fall protection or a safety monitor (see Work Process H, Active Fall Protection Systems).
      3. The warning line must meet or exceed the requirements in 1926.502(f)(2), which requires that the warning line: (1) be constructed of rope, wire, or chain and flagged at intervals no greater than 6 feet; (2) be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches above the walking/working surface and its highest point is no more than 39 inches above the walking/working surface; (3) be capable of resisting a knock-over force of at least 16 pounds applied horizontally against the stanchion at 30 inches above the walking/working surface perpendicular to the warning line and in the direction of the floor, roof, or platform edge; (4) have a minimum tensile strength of 500 pounds; and (5) be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.
   2. Non-roofers
      1. The warning line must be erected not less than 15 feet from the roof edge.
      2. No employee is allowed in the area between the warning line and the roof edge without active fall protection. There are no exceptions.
      3. The warning line must meet or exceed the requirements in 1926.502(f)(2), which requires warning line (1) constructed of rope, wire, or chain and flagged at intervals no greater than 6 feet; (2) rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches above the walking/working surface and its highest point is no more than 39 inches above the walking/working surface; (3) capable of resisting a knock-over force of at least 16 pounds applied horizontally against the stanchion at 30 inches above the walking/working surface, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge; (4) having a minimum tensile strength of 500 pounds; and (5) attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.
   3. Hole Opening Covers
      1. The following must be covered: an opening in any floor or platform, 12 inches or more in the least horizontal dimension. It includes, but is not limited to, floor openings, stairway floor openings, ladderway floor openings, hatchways, and chute floor openings.
      2. Floor and roof opening covers shall be designed by a qualified person and be capable of safely supporting the greater of 400 pounds or twice the weight of the employees, equipment and materials that may be imposed on any one square foot area of the cover at any time. Covers shall be secured in place to prevent accidental removal or displacement, and shall bear a pressure sensitized, painted, or stenciled sign with legible letters not less than one inch high, stating: “Opening -Do Not Remove.” Markings of chalk or keel shall not be used. Covers shall not project more than one inch above the floor level and all edges shall be chamfered to an angle with the horizontal of not over 30 degrees. All hinges, handles, bolts, or other parts shall set flush with the floor or cover surface.
      3. Temporary covers for roadway holes are to be steel street plates capable of supporting twice the axle weight of the heaviest vehicle expected to cross the cover.
   4. Ladder Wells/Cages
      1. Any fixed ladder of more than 24 feet to a maximum unbroken length of 30 feet installed before November 19, 2018 may use a personal fall arrest system, ladder safety system, cage, or well; Any fixed ladder of more than 24 feet to a maximum unbroken length of 30 feet installed on or after November 19, 2018, must be equipped with a personal fall arrest system or a ladder safety system. Cages or Wells will not be used as fall protection on these ladders; When a fixed ladder, cage, or well, or any portion of a section thereof, is replaced, a personal fall arrest system or ladder safety system must be installed in at least that section of the fixed ladder, cage, or well where the replacement is located; On or after November 18, 2036, all fixed ladders must be equipped with a personal fall arrest system or a ladder safety system. All new fixed ladder installations must be designed and installed in compliance with American National Standard A14.3-2014 American National Standard for Fixed Ladder Safety Requirements.
   5. Safety Monitors
      1. A safety monitor is a trained and authorized worker who must be competent in recognizing fall hazards. A safety monitor’s only job on a roof is to ensure that previously trained roofers are warned when moving too close (within 6 feet) to a dangerous edge. He or she must be positioned on the same level of all workers being monitored, and must be within vocal distance of them. Constant vigilance is required, because lateral and backward movement of 4 to 5 feet per second is not uncommon.
      2. Safety monitors are not permitted to work on roofs of a pitch greater than 4 in 12 or that have equipment that obstructs vision or has a noise level that prevents any worker from immediately hearing a verbal warning of danger. Duties of the safety monitor include:
         1. Warning the worker when it appears that the worker is unaware of a fall hazard or is acting in an unsafe manner.
         2. Remaining on the same walking/working surface and within sighting distance of the worker being monitored.
         3. Remaining close enough to communicate verbally with the worker.
         4. Having no other responsibilities other than serving as a safety monitor.
         5. Monitoring not more than six employees in a controlled area (area between the warning line and the roof edge).
         6. An LBNL Safety Monitor OJT form must be filled out and submitted before work can begin.

Work Process H. Active Fall Protection Systems

An active fall-protection system or personal fall-arrest system (PFAS) requires the use of specialized fall protection equipment that must be fitted to the user and worn to control fall hazards. In other words, a user is secured to an anchorage point at all times, even while moving from point to point. Fall-protection systems and equipment are used for personnel protection only.

1. Active Systems. Active systems may include the following:
   1. Positioning devices
   2. Lifeline systems (standard and self-retracting)
   3. Rope grabs
   4. Retrieval systems
   5. Full body harnesses
   6. Body belts (note: body belts are not to be used for fall arrest at Berkeley Lab)
   7. Connectors
   8. Lanyards
   9. Snap hooks
   10. Ladder safety devices
   11. Anchorages
2. Fall Dynamics. The following elements combine to make a fall hazardous:
   1. Lanyard length
   2. Free-fall distance
   3. Shock absorption at impact
   4. Body weight
   5. Swing
   6. Suspension Trauma
      1. Lanyard Length. The lanyard length must be selected to allow freedom of movement to do the work, yet be short enough to minimize the fall distance. The maximum length of the lanyard and shock absorber combination is 6 feet. The minimum total vertical distance from the anchor point with a 6 foot lanyard is 18.5 feet, allowing a 3 foot safety factor.
      2. Free Fall Distance
         1. If the trigger height for fall protection is 6 feet above the walking/working surface, a 6-foot lanyard does not offer adequate protection if the anchor point of the lanyard is connected at head height. To be effective, the anchor point is required to be as high as practicably possible above the user’s head without interfering with the work being done.
         2. The D-ring on the harness moves from the back at shoulder blade height to a position at the head when supporting full body weight. A 6-foot fall can result in forces exceeding 10 times body weight. A worker weighing 200 pounds can experience more than 2,000 pounds of arresting force from the harness unless the user has a shock-absorbing lanyard. A 2,000 pound force is capable of causing severe or fatal injury.
         3. Serious consideration must be given to the equipment being approved for each situation evaluated based on the total fall distance and impact forces that could be encountered. A good rule of thumb is to limit the free-fall to 2 feet whenever possible, by using a minimum lanyard length and/or raising the anchor point. Consider using self-retracting lanyards, some of which can activate within 1-2 feet.
         4. Use the following formula as a guide for Minimum Anchorage Point Height (MAPH):
            
            MAPH = (6′ + L) – H + D + S + C
            6′ = Harness D-ring height
            L = Lanyard length (typically is 6 feet)
            H = Anchorage point height (positive if below D-ring)
            D = Deceleration or shock absorbing distance (typically is 3.5 feet)
            S = Harness stretch (typically 1 foot)
            C = Min. required clearance to lower level (3 feet)
            
            
      3. Shock Absorption at Impact. Even a relatively short free-fall distance of 6 feet on a solid lanyard, or cable can create serious impact problems, as described above. Shock absorption devices stretch by more than 3 feet 6 inches depending on the type of unit. The use of shock-absorbing lanyards is required at Berkeley Lab.
      4. Body Weight. Body weight adds to the impact load on the body of a worker and on the fall-arrest system. How the harness is worn and the tightness of the straps, if adjusted for comfort, can create harmful stress and abrasions on the body during a fall arrest. The correct size harness must be worn and all harness straps are to be adjusted for a snug fit.
      5. Swing. If a fall is not a direct drop, pendulum action will come into play. The worker may be relatively uninjured from the fall due to the fall-protection system, but then could swing into another object and become impaled or forcibly strike a solid object. Use the shortest lanyard practical for the task to minimize swing effect.
      6. Suspension Trauma
         1. A person suspended immobile in a harness may experience suspension trauma leading to death in as little as 5 minutes. Whenever a worker is suspended for longer than 5 minutes in an upright posture with legs relaxed straight beneath the body, gravity pulls blood into the lower legs, which have a very large storage capacity. Enough blood eventually accumulates so that return blood flow to the right chamber of the heart is reduced and the heart’s output begins to fall. The harness leg straps compound the problem by restricting the flow of blood up to the heart. To minimize the effects of Suspension Trauma, the worker should be trained to try to move the legs in the harness, push against any object, and, if possible, raise the legs to a horizontal position.
         2. For prolonged suspension, a harness with a seat rather than straps alone should be used to help position the upper legs (and lower legs if conscious) horizontally.
         3. Workers using fall arrest systems are required to be fitted with trauma suspension straps as part of a self-rescue system.  Use of trauma suspension straps can increase a fallen worker’s survival time from 15 minutes to more than an hour if the fallen worker is alert.
3. Work Planning. A written permit (Fall Protection Permit) is required when a Personal Fall Protection System (PFPS) is to be used. A Competent Person selects the appropriate PFPS equipment for the fall scenario and ensures that it properly fits each user. General work planning guidelines are as follows and are carried out by the Competent Person:
   1. Determine whether an engineered fall-protection system is required. In collaboration with the Qualified Person (Berkeley Lab Structural Engineer), ensure it is satisfactory (for example, determine whether guardrails or cages are necessary). If an engineered fall-protection system is not required, list each fall scenario that workers will be exposed to.
   2. For each fall scenario, analyze the fall hazards and determine the PFPS components that will be needed.
   3. Maintain and inspect the PFPS components needed to ensure that equipment is available when needed. This inspection by the competent person will act as an additional competent person inspection and is separate from the authorized user pre-use inspection.
   4. Determine the worker’s vertical and horizontal movement requirements in each scenario.
   5. Plan the anchoring system. Identify and evaluate the strength of all anchor points.
   6. Select and obtain the appropriate equipment (e.g., harness, lanyard, or self-retracting lifeline).
   7. Confirm training status of all users. The requirements are Berkeley Lab fall protection training (EHS 276) and written training documentation by the subcontractor.
   8. Review the planned work with workers to ensure their understanding of the requirements and approach to the job.
   9. Review the planned method of self rescue, anticipated time of hanging in the harness, and personal actions to minimize Suspension Trauma.
4. Limits on Use of Personal Fall Protection Systems Equipment
   1. Competent Persons must ensure that PFPS equipment is used only for worker safeguarding.
   2. Competent Persons and/or Supervisors must ensure that any device that has been subjected to a fall load (i.e., a device that has protected a worker in an actual fall) has all components immediately removed from service, destroyed, and not used again for worker safeguarding.
5. Active Fall Protection System Components
   
   Note: All components must be from one manufacturer unless the Qualified Person/Competent Person determines otherwise.
   
   
   1. Full Body Harness
      1. The full body harness has been designed to distribute arresting forces over the buttocks and shoulders. The chest strap serves a retainer function and should be worn high on the chest, but under the collarbone.
      2. D-ring locations may vary, so make sure the harness is the correct one for your task. Most harnesses have the D-ring on the upper back, but for ladder climbing systems the D-ring is located on the chest or rib area. D-rings on the hips are for work positioning and on the shoulders are for retrieval. Long hair may be caught in the D-ring, so the hair must be worn under the hardhat.
      3. The most common misuse of the harness involves failure to connect the leg straps. This is also the most dangerous practice, as slipping through and out of the harness when the actual arresting action takes place is a very real possibility if the leg straps are not connected. The common practice of having loose leg straps is also dangerous, as it can lead to severe contusions to the upper thighs and groin area.
      4. Note: Body belts are not to be used for fall arrest or restraint at Berkeley Lab.
      5. Body belts are NOT fall protection devices! Body belts, waist belts, or safety belts, as they are sometimes called, are only to be used as work positioning supports in conjunction with a full body harness, that is, when the worker is standing, leaning out, and needs support to hold a position—thus the term “work positioning.”
      6. A single D-ring on the body belt should be positioned in the middle of the waist in front of the body. More commonly, the body belt will have two D-rings to be connected to two lanyards, one from each side, similar to that used for a window washer. Body belts have either a tongue buckle or a friction buckle, both, if worn properly, will support the weight of a worker.
   2. Connectors. Two shock-absorbing lanyards, at least one of which is always attached to a secure anchorage, are required for foot travel beyond the limits of a single lanyard when exposed to a fall greater than 6 feet. The use of a positioning device and an additional shock-absorbing lanyard while climbing is also acceptable.
   3. Lanyards
      1. A lanyard is a short, flexible rope or strap webbing that connects a worker’s body harness to an anchorage point or the grabbing device on a lifeline. There is no limit to the length of a lanyard, but lengths of 2, 4 and 6 feet are common to help limit falling beyond a maximum free-fall of 6 feet. The lanyard should be as short as possible, without restricting movement. An adjustable lanyard provides workers with the flexibility to adjust the length of their lanyard to suit any fall arrest application.
      2. The minimum attachment height should be at or above the D-ring height to ensure the free-fall distance will be less than 6 feet when using a 6ft free fall lanyard.
      3. If a worker is in a situation and must anchor the lanyard below the dorsal D-ring a 12ft free fall lanyard must be used. Greater fall clearances and higher arresting forces must be accounted for when using a 12ft free fall lanyard. 
      4. Unlike basic cable, web, or rope lanyards, shock-absorbing lanyards not only significantly reduce arresting forces on the body, but also provide a means to determine in-service use. Obvious deformation makes it evident that they have been stressed. All lanyards are to be destroyed and replaced after having been shock loaded.
   4. Y-Lanyards
      1. A Y-lanyard is two or three lanyards, generally shock-absorption types, connected to a center ring or snap hook that allows workers to move horizontally from one anchorage point to another.
      2. The user must be trained in the use of the Y-lanyard and constantly be aware of the location of both lanyards. There have been several instances of the lanyards becoming entangled or actually causing a fall when they have snagged on an obstruction and thrown a worker off balance.
      3. Do not connect the lanyard to an unauthorized anchorage as travel progresses. Consider a horizontal lifeline system as an alternate solution.
   5. Snap Hooks
      1. Snap hooks must be of a self-closing and self-locking type. The self-locking gate meets the 3600-pound breakage strength requirements and must not be directly connected to: webbing, rope, or wire rope; horizontal lifelines (a separate ring or carabineer should ride on the horizontal lifeline); or to any object whose shape or dimensions are incompatible with the snap hook such that unintentional disengagement (e.g., roll-out) could occur. A snap hook must not be connected directly to another snap hook.
      2. Snap hooks may only be used with compatible components. Snap hooks are not to be attached directly to cables, ropes, chains, or the lanyard itself—as in looping the lanyard over a pipe and hooking the snap hook on the lanyard—unless approved by the manufacturer. Only approved anchor points must be used to connect to the lanyard snap hook.
   6. Retractable Lifelines. Self-retracting Devices (Locking): Self-retracting lanyards with locking devices are designed to arrest free falls within inches by eliminating the slack inherent in fixed-length lanyards. The Competent Person will determine the free fall distance. One main consideration is that for self-retracting lanyards to be effective overhead installation is required. A major advantage is that arresting forces can be kept to almost one-third of that associated with a 6-foot free fall.
   7. Lifeline Systems
      1. Lifeline systems provide a means for connecting components of a personal fall-arrest system to an anchorage. They consist of either:
         1. A flexible line to hang vertically (vertical lifeline) for connecting to an anchorage at one end
         2. A flexible line to stretch horizontally (horizontal lifeline) for connecting to anchorages at both ends.
      2. For all vertical lifeline systems, a Competent Person or Qualified Person must approve the anchorages and the selection of the type of lifeline to ensure proper design of the system. For horizontal lifelines, a Qualified Person must approve the anchorages and the selection of the type of lifeline to ensure proper design of the system.
         1. Vertical Lifeline Systems
            • A vertical lifeline allows the worker to move up and down the entire height of the line rather than having to disconnect and find a new tie-off point on the tower or ladder being climbed. Workers connect to the lifeline by a “rope grab” deceleration device that travels along with the worker as he or she moves higher or lower.
            • The diameter and composition of the line may vary, but it must have a 5,000-pound breaking strength. Although polypropylene rope is a popular tool, its stretch factor must be taken into account.
            • The rope grab is a deceleration device that travels on a lifeline and automatically, by friction, engages and locks the lifeline to arrest the fall of the user. A rope grab usually employs the principle of inertial locking, cam/level locking, or both. Rope grabs can be either manual or mobile and must be suited to the lifeline fabric. Squeezing and releasing a locking cam operates the manual grabs. The grab should be located above shoulder height and a short (3-foot) lanyard is recommended to prevent exceeding the 6-foot free fall requirement.
         2. Ladder Safety Devices. Ladder safety devices are similar to vertical lifeline systems with the exception that they attach to the front harness D-ring with a 9-inch maximum connector and are limited to 2-foot free falls.
         3. Horizontal Lifeline Systems
            • A horizontal lifeline is a flexible line rigged in a horizontal plane and secured at each end to an anchorage. It provides fall protection for work requiring horizontal mobility along elevated surfaces. A worker connects to the line using a personal fall-arrest system that moves with the worker between the two anchorages. By providing a sliding connection along the entire walkway, the anchorage is kept overhead, reducing the hazard of dangerous swing falls that can occur if the worker moves to a location where the anchorage is no longer directly overhead.
            • Horizontal lifeline systems are common in work areas lacking overhead anchor points available for personnel tie-off. In its simplest form, the horizontal lifeline consists of a cable attached to two or more anchor points on a rooftop, crane runway, bridge, outdoor construction site, or any other elevated work area that poses a fall risk to personnel. When used in combination with personal protective equipment, a horizontal lifeline can arrest a fall, limiting the amount of force that is transferred to both the worker and the fall-arrest system.
            • Horizontal lifelines must be designed, installed, and used under the supervision of a Qualified Person, and be part of a complete personal fall-arrest system that maintains a safety factor of at least two. Although installing a horizontal lifeline may appear to be as simple as stringing a line between two supports, determining the loads applied to the anchorages and the clearance required below the working surface in the event of a fall can be extremely complicated. In this respect, horizontal lifelines are among the most complex types of fall protection equipment.
         4. Anchorages
            • Personal fall-protection systems are dependent on an adequate anchor point. Without it, Personal Fall Arrest Systems are useless.
            • ONLY ANCHORAGE POINTS IDENTIFIED BY A QUALIFIED OR COMPETENT PERSON ARE TO BE USED.
            • Guardrails, handrails, fire sprinkler piping, and roof ducting are NOT acceptable anchorage points unless designed to support arrest forces as determined by a Qualified Person. Questions on anchorages should be directed to a Fall Protection Competent Person.
            • Anchorages are to be:
              • Independent from the work object whenever possible.
              • Clearly marked if permanent, and serves as a certified anchor approved by a Qualified Person.
              • Located at suitable attachment heights.
              • Of sufficient strength for its intended purpose.
              • Inspected regularly and before each use.
            • Connecting devices (e.g., shock absorbing lanyards) should be secured above the point of operation to an anchorage or structural member capable of supporting a minimum dead weight of 5,000 pounds per worker and limiting the fall distance to 6 feet or less and/or arrest forces below 900 pounds Average Arresting Force (AAF) and 1800 pounds Maximum Arresting Force (MAF).

Work Process I. Hazards Requiring Evaluation for Fall Protection

Additional fall protection hazard controls may be required under the following fall hazard conditions:

• Before work begins on or near floors, windows, skylights, ceilings, roofs and other load bearing surfaces with unknown structural capacities, the Fall Protection SME, and Facilities Division Fall Protection Qualified Person must evaluate the fall protection requirements and design. 
• When working  on elevated work surfaces that are near protected (e.g. Guardrail Systems, or unrated windows) edges, a fall protection competent person must determine the necessary setback and controls for scaffolds, ladders, and aerial lifts used to elevate workers tasked to perform work near the fall hazard zone.  
• A hazard evaluation may determine that a personal fall-protection system or other protective means may be required for the worker’s protection even though working from a ladder or scaffold does not normally require fall protection. For example, if the task requires working from a step stool, or a level above the working surface next to the guardrail, the guardrail is no longer 42 inches above the “new” working surface.
• Working on hillside with unstable walking/working surfaces, slopes greater than 1.2 to 1 slopes (40 degrees) or sloping into hazardous conditions, e.g traffic, construction, etc.
• Qualified Climbers implementing secondary positioning fall protection devices while working during the following work task:
  • Tree Work, Maintenance, or Removal according to Cal OSHA General Safety Order Article 12 (3420-3428).
  • Elevator Work, Maintenance, or Removal according to Subchapter 6, Elevator Safety Orders.
  • Window Washing Work, Maintenance, or Removal according to SubChapter 7. General Industry Safety Orders Group 1. General Physical Conditions and Structures (Article 5. Window Cleaning).
  • Structural Climbing on Rebar Assemblies according to Article 29, Erection and Construction. 
• Cranes and Derricks: The use of a crane or derrick to hoist employees on a personnel platform is prohibited, except when the erection, use and dismantling of conventional means of reaching the worksite, such as a personnel hoist, ladder, stairway, aerial lift, elevating work platform, or scaffold would be more hazardous, or is not possible because of structural design or worksite conditions.  The Hoisting and Rigging SME and Fall Protection SME must approve the written plan for the use of personnel platforms hoisted by cranes or derricks.         

Work Process J. Off-Site Fall Protection

1. Employees tasked to perform elevated work at off-site field locations are required to follow all LBNL fall protection policy and work processes regardless of the host institution’s fall protection policy or procedures. Contact your Division Safety Coordinator and EHS Liaison for assistance with submitting a “Field Hazard Assessment”.
2. Each division must submit a LBNL Fieldwork Fall Protection Plan (FPP) to EHS which describes the following:    
   1. A full description of the work hazard(s).                        
   2. A full description of the work process.                         
   3. A full description of all work controls.                             
   4. Emergency Rescue provisions, first responders, and nearest medical facilities.                                                      
   5. Permit work process, e.g. Fall Protection Permit.
3. EHS375 Off-site Fall Protection Competent Person training is available for researchers tasked with writing fall protection permits at off-site research facilities    
   1. Fall protection permits can be submitted electronically.     
   2. EHS support is available via smart technology e.g., FaceTime on iPhones or Skype.

Work Process K. Covers

Requirements for covers of holes in floors, roof and other walking working surfaces include the following:

• Floor and roof opening covers shall be designed by a qualified person and be capable of safely supporting the greater of 400 pounds or twice the weight of the employees, equipment and materials that may be imposed on any one square foot area of the cover at any time.
• Covers shall be secured in place to prevent accidental removal or displacement.
• Shall bear a pressure sensitized, painted, or stenciled sign with legible letters not less than one inch high, stating: “Opening -Do Not Remove.” Markings of chalk or keel shall not be used.

Work Process L. Protection from Falling Objects

When using toe boards as falling object protection:

• Erected in places where employees normally work or pass and the lack of a toeboard could create a hazard from falling tools, material, or equipment for a distance sufficient to protect employees below.
• Capable of withstanding, without failure, a force of at least 50 pounds applied in any downward or outward direction at any point along the toe board.                                                 
• A minimum of 3.5 inches in vertical height from their top edge to the level of the walking/working surface, not more than ¼ inch clearance above the walking/working surface, be solid or have openings not over 1 inch in greatest dimension.                                                            
• Erect paneling or screening to the top edge of the toe board to the top or midrail where tools, equipment, or materials are piled higher than the top edge of a toe board.
• When using canopies, as falling object protection, ensure they are strong enough to prevent collapse and to prevent penetration by any object that may fall onto the canopy.

Work Process M. Walking/Working Surfaces

The Facilities Division Structural Engineer must determine if the walking/working surfaces on which employees walk or work have the strength and structural integrity to support employees safely.  Employees are only allowed to work on those surfaces when the surfaces have the requisite strength and structural integrity.

Fall protection is required for each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 4 feet for General Industry workers or 6 feet for Construction workers.

Guard ladder ways floor opening or platforms with standard railing with standard toe board  on all exposed sides (except at the entrance to opening), with the passage through the railing either provided with a self-closing swinging gate or so offset that a person cannot walk directly into the opening.

Prevent material from falling through a wall hole less than four inches above the floor, and the hole is more than five feet above the next lower level, with a standard toe board or other effective means.

Guard every open-sided floor or platform 4 feet or more above adjacent floor or ground by a standard railing or equivalent, on all open sides except where there is entrance to a ramp, stairway, or fixed ladder.  

Where walkways, platforms, or runways are adjacent to dangerous equipment, tanks or similar hazards, regardless of height, guard open-sides with standard railing and toe board.

Cover floor holes to leave no opening greater than one inch in width. Guard wall openings where there is a drop of more than four feet to a lower level. 

Work Process N. Leading Edge Work

Protect employees who are constructing a leading edge 4 feet for General Industry workers or 6 feet for Construction workers or more above a lower level from falling by the use of guardrail systems, safety net systems, or personal fall protection systems.  Exception: when it is demonstrated with an LBNL Active Fall Protection Infeasibility Plan that it is infeasible or creates a greater hazard to use these systems.

There is a presumption that it is feasible and will not create a greater hazard to implement; use at least one of the fall protection systems listed in Work Process H. Active Fall Protection Systems.

Protect employees on walking/working surfaces, 4 feet for General Industry workers or 6 feet for construction workers, above a lower level where leading edges are under Construction, but who is not engaged in the leading edge work, by the use of guardrail systems, safety net systems, or personal fall protection systems. If a guardrail system is chosen to provide fall protection, and a controlled access zone has already been established for leading edge work, the control line may be used in lieu of a guardrail along the edge that parallels the leading edge.

Work Process O. Hoist Areas

Protect employees in a hoist area from falling 4 feet for General Industry workers or 6 feet for Construction workers or more to lower levels by guardrail systems or personal fall arrest systems. Protect employees with a personal fall arrest or personal fall restraint system when guardrail systems, [or chain, gate, or guardrail] or portions thereof, are removed to facilitate the hoisting operation (e.g. during landing of materials), and the employee must lean through the access opening or out over the edge of the access opening (to receive or guide equipment and materials, for example).

Work Process P.  Working Near Holes

Protect employees on walking/working from falling through holes (including skylights) more than 6 feet above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.

Protect employees on a walking/working surface from objects falling through hole (including skylights) by covers.  Any employee approaching any skylight shall be protected from falling through the skylight or skylight opening by any one of the following methods:

1. Skylight screens installed above the skylight. The design, construction, and installation of skylight screens shall meet the strength requirements equivalent to that of covers specified in subsection (b) above. They shall also be of such design, construction and mounting that under design loads or impacts, they will not deflect downward sufficiently to break the glass below them. The construction shall be of grillwork, with openings not more than 4 inches by 4 inches or of slatwork with openings not more than 2 inches wide with length unrestricted, or of other material of equal strength and similar configuration.
2. Skylight screens installed below the skylight. Existing screens (i.e. burglar bars) shall meet the following requirements if they will be relied upon for fall protection:
   1. Screens installed at the same level or higher than the walking/working surface shall meet the strength requirements of subsection (b).
   2. Screens installed within 2 feet of the walking/working surface shall meet the strength requirements of subsection (b) with increased strength based on the fall distance below the walking/working surface as determined by a qualified person. In no case shall the strength of the screen below the skylight be less than the strength requirements of subsection (b). A screen more than 2 feet below the walking/working surface shall not serve as fall protection.
   3. A screen shall not be used for fall protection in accordance with subsection (e)(2)(A) or (e)(2)(B) if the broken skylight glazing will pose an impalement hazard to a worker who has fallen through the skylight and is lying on top of the screen. Skylights containing tempered, laminated, or plastic glazing, or similar materials shall not be considered to impose an impalement hazard.
   4. The screen construction shall be of grillwork, with openings less than 12 inches in the least horizontal dimension.
3. Guardrails meeting the requirements of Section 3209.
4. The use of a personal fall protection system meeting the requirements of Work Process H. Active Fall Protection Systems.
5. Covers, including the skylight itself, meeting the requirements of subsection (b) installed over the skylights, or skylight openings. Where the skylight itself serves as a cover, the skylight shall be required to meet only the strength requirements of subsection (b). Further, for skylights serving as covers, the employer shall obtain documentation from the manufacturer that the skylight will meet the strength requirements of subsection (b) for the dates that work will be performed in the vicinity of the skylight. Such documentation shall be obtained prior to the start of work and shall be made available upon request.

Work Process Q. Formwork and Reinforcing Steel

Protect employees on the face of formwork or reinforcing steel from falling 6 feet or more to lower levels by personal fall arrest systems, safety nets systems, or positioning device systems.

The duties of the controlling contractors under Work Process Q will protect workers from the hazards associated with steel erection activities following the regulatory requirements covered by OSHA 29 CFR 1926.750 Subpart R- Steel Erection.

Work Process R.  Ramps, Runways, and Walkways                 

Protect employees on ramps, runways, and other walkways from falling, 4 feet for General Industry workers or 6 feet for Construction workers, 6 feet or more to lower levels by guardrail systems.

Work Process S.  Working Near Excavations

Protect employees at the edge of an excavation 6 feet or more in depth from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barriers.  

Protect employees at the edge of a well, pit, shaft, and similar excavation 6 feet or more in depth from falling by guardrail systems, fences, barricades, or covers.

Where employees or equipment are required or permitted to cross over excavations over 6-feet in depth and wider than 30 inches, walkways or bridges with standard guardrails shall be provided.

Work Process T. Working Near Dangerous Equipment

Protect employees from falling when working above dangerous equipment shall from falling into or onto the dangerous equipment by guardrail systems, equipment guards, personal fall arrest systems, or safety net systems.

Work Process U. Overhead Bricklaying and Related Work

Except as otherwise provided in Work Process N, Leading Edge Work, protect employees performing bricklaying and related work 4 feet for general industry workers or 6 feet for construction workers or more above lower levels from falling by guardrail systems, safety net systems, personal fall arrest systems or shall work in a controlled access zone.

Work Process V. Low Sloped Roofs

Protect employees engaged in roofing activities on low-slope roofs (slopes 0:12 to 4:12 – Single-Unit Roof Coverings), with unprotected sides and edges 4 feet or more for General Industry or 6 feet or more for construction workers above lower levels from falling by guardrails, safety net systems, personal fall arrest systems, or a combinations of warning line system and guardrail system, warning line and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring.

Work Process W. Steep Sloped Roofs

Protect employees on a steep roof (slopes 0:12 through 4:12 – Multiple-Unit Roof Coverings or slopes greater than 4:12) with unprotected sides and edges 4 feet for general industry workers or 6 feet for construction workers, above lower levels from falling by guardrail systems with toe boards, safety net systems, or personal fall arrest systems.

Work Process X. Precast Concrete Erection

Fall protection systems such as guardrails, safety net systems, and personal fall arrest systems must be used to protect employees engaged in the erection of precast concrete members (including but not limited to the erections of walls, panels, columns, beams, and floor and roof “tees”) and related operations, such as grouting of precast concrete members, that are 4 feet or more above lower levels for general industry workers, or 6 feet or more above lower levels for construction workers.

Work Process Y. Residential Construction 

Protect employees engaged in residential construction activities more than 6 feet above lower level by guardrails, safety net, or personal fall arrest system unless another provision e.g. Work Process E.2.c, Exceptions: Fall Protection Plan, has been demonstrated by the employer that the work creates an additional hazard or that active fall protection systems are infeasible.

Work Process Z. Wall Openings

Use a guardrail system, safety net system, or a personal fall arrest system to protect employees working on, at, or near wall openings. Wall openings, from which there is a drop of more than 4 feet for general industry workers or 6 feet or more above lower levels for construction workers, and the bottom of the opening is less than 3 feet above the working surface, shall be guarded when the height and placement of the opening in relation to the working surface is such that either a standard rail or intermediate rail will effectively reduce the danger of falling, one or both shall be provided. The bottom of a wall opening, which is less than 4 inches above the working surface, regardless of width, shall be protected by a standard toeboard or an enclosing screen either of solid construction or as specified in this section.

Wall opening protection shall meet the following requirements:

1. Barriers shall be of such construction and mounting that, when in place at the opening, the barrier is capable of withstanding a load of at least 200 pounds applied in any direction (except upward).
2. Screens shall be of such construction and mounting that they are capable of withstanding a load of at least 200 pounds applied horizontally at any point on the near side of the screen. They may be of solid construction, of grill work with openings not more than 8 inches long, or of slat work with openings not more than 4 inches wide with length unrestricted.

30.8 Source Requirements

• 10 CFR 851, Worker Safety and Health Program
• Title 8 CCR, Division 1, Chapter 4, Subchapter 4, Construction Safety Orders (for all construction safety unless 29 CFR 1926 Safety and Health Regulations for Construction is more strict) (Cal/OSHA Standard)
  • Article 6. Excavations (Sections 1539 – 1547)
  • Article 16. Standard Railings (Sections 1620 – 1621)
  • Article 17. Ramps, Runways, Stairwells, and Stairs (Sections 1623 – 1626)
  • Article 18. Access and Egress (Sections 1629 – 1631)
  • Article 19. Floor, Roof, and Wall Openings (Sections 1632 – 1633)
  • Article 20. Temporary Floors (Section 1635)
  • Article 21, Scaffold – General Requirements (Sections 1635.1–1637)
  • Article 22, Scaffolds – Various Types (Sections 1640–1655)
  • Article 23, Suspended Scaffolds (Sections 1658–1667)
  • Article 24, Fall Protection (Sections 1669–1672)
  • Article 25, Ladders (Sections 1675–1678)
  • Article 29. Erection and Construction (Sections 1709 – 1722.1)
  • Article 30. Roofing Operations and Equipment (Sections 1723 – 1731)
  • Article 31. Demolition (Sections 1733 – 1737)
• Title 8 CCR, Division 1, Chapter 4, Subchapter 7. General Industry Safety Orders (for all General Industry safety unless 29 CFR 1910, Occupational Safety and Health Standards for General Industry is more strict) (Cal/OSHA Standard)
  • Group 1. General Physical Conditions and Structures (Sections 3207 – 3299)
  • Group 2. Safe Practices and Personal Protection (Sections 3300 – 3416)
  • Group 3. General Plant Equipment and Special Operations (Sections 3420 – 3583)
  • Group 4. General Mobile Equipment and Auxiliaries (Sections 3620 – 3920) 

30.9 Reference Documents

Document Number	EH&S Reference	Title	Type
	Chapter 10 Construction Safety, Appendix A, Section A.13	Ladders	Procedure
	Chapter 10 Construction Safety, Appendix A, Section A.21	Protection of Openings and Open Side Floors and Decks	Procedure
	Chapter 10 Construction Safety, Appendix A, Section A.22	Scaffolding	Procedure
	Chapter 10 Construction Safety, Appendix A, Section A.6	Fall Protection	Procedure
	Chapter 34 Confined Spaces	Confined Spaces	Program
	Chapter 35	Elevated Work – Aerial Work Platforms, Ladders, and Scaffolds	Program
		ANSI A14.3, Ladders – Fixed – Safety Requirements	Consensus Standard
		ANSI A14.4, American National Standard for Job Made Wooden Ladders	Consensus Standard
		ANSI A92.2, Vehicle-Mounted Elevating and Rotating Aerial Devices	Consensus Standard
		ANSI A92.3, Manually Propelled Elevating Aerial Platforms	Consensus Standard
		ANSI A92.6, Self-Propelled Elevating Work Platforms	Consensus Standard

30.10 Related Documents

• American National Standards Institute (ANSI) A10.11, Safety Requirements for Personnel and Debris Nets
• ANSI A10.8, Safety Requirements for Scaffolding
• ANSI A10.13, Safety requirements for Steel Erection
• ANSI A14.1, American National Standard for Ladders – Wood
• ANSI A14.2, American National Standard for Ladders – Portable Metal
• ANSI A14.3, Safety Requirements for Fixed Ladders
• ANSI A14.4, American National Standard for Job Made Wooden Ladders
• ANSI A92.2, Vehicle Mounted Elevating and Rotating Work Platforms
• ANSI A92.3, Manually Propelled Elevation Aerial Platforms
• ANSI A92.6, Self-Propelled Elevating Work Platforms
• ANSI Z359-2019, Fall Protection Code
• ANSI Z359.0–2018, Definitions and Nomenclature Used for Fall Protection and Fall Arrest
• ANSI Z359.1–2016, Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components
• ANSI Z359.2–2017, Minimum Requirements for a Comprehensive Managed Fall Protection Program
• ANSI Z359.3–2019, Safety Requirements for Positioning and Travel Restraint Systems
• ANSI Z359.4–2013, Safety Requirements for Assisted Rescue and Self-Rescue Systems, Subsystems and Components
• ANSI Z359.6-2016, Specifications and Design Requirements for Fall Protection Systems
• ANSI Z359.12-2019, Connecting Components for Personal Fall Arrest Systems
• ANSI Z359.13-2013, Personal Energy Absorbers and Energy Absorbing Lanyards
• Subchapter 7. General Industry Safety Orders Group 1. General Physical Conditions and Structures Article 5. Window Cleaning
• ANSI Z535.1-2006 American National Standard Criteria for Safety Colors
• ANSI Z535.3-2007 American National Standard Criteria for Safety Symbols
• ANSI Z535.5-2007 American National Standard Safety Tags and Barricade Tapes (for Temporary Hazards)

30.11 Appendices

Appendix 1. Fall Protection Permit Acronym Index
Appendix 2. Fall Calculation with 6 Ft Lanyard and SRL Models 
Appendix 3. EHS On-the-Job Fall Protection Safety Monitor Training 
Appendix 4. LBNL Trigger Height Chart 
Appendix 5. LBNL Active Fall Protection Infeasibility Plan 
Appendix 6. Field Hazard Assessment Plan (Model) 
Appendix 7. LBNL Fall Protection Permit Acceptance Letter

 Appendix 1. Fall Protection Permit Acronym Index

Appendix 2: Fall Calculation with 6 ft Lanyard Model and SRL Models

Appendix 3. EHS On-the-Job Fall Protection Safety Monitor Training

Appendix 4. LBNL Trigger Height Chart

Appendix 5. LBNL Active Fall Protection Infeasibility Plan

Appendix 6. Field Hazard Assessment Plan (Model)

Appendix 7. LBNL Fall Protection Permit Acceptance Letter

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