One of the most important elements of any job site is safety. Today, we're pleased to welcome Erich Smith to the blog for a Q&A on a critical component that can prevent serious injury and save lives: fall protection. Erich is a technical expert for the Division of Occupational Safety & Health at the Washington State Department of Labor & Industries (L&I). He is responsible for the department’s application and interpretation of the Washington Administrative Code as it relates to the construction industry. Previously, Erich represented King County as a safety compliance officer and safety compliance supervisor for the Division of Occupational Safety & Health in Region 2. Here's our Q&A with Erich.
Q: Why should people invest in fall protection?
The primary reason, honestly, is because it’s the right thing to do; people can and do get injured quite easily. The idea of fall protection is to prevent exposure to a fall hazard if possible. If a fall could occur, protect the worker with a fall restraint or fall arrest system.
Q: Aside from injury, what are the risks of not investing in fall protection? Are there fines or sanctions placed against businesses caught acting outside of regulations?
The relationship with [Washington State Department of] Labor and Industries is with the employer—citations are not issued to workers, and that’s by statute. A citation can be issued to an employer when a violation of the code has been established. Usually, people want to ask what the monetary fines will be, and it’s difficult to explain because it is based upon multiple factors. But employers can be—and regularly are—cited for violations of fall protection standards when there is no fall protection in place, the fall protection system is being used improperly, or not used at all.
Photo credit: SuperAnchor
Q: What does a first-time violation look like?
There are essentially two types of violations: serious and general. Serious violations are violations where there is a substantial probability that death or serious physical harm could result from a condition which exists in the workplace. General violations are violations which are specifically determined not to be of a serious nature. Fall protection violations would be considered serious, and by statute—serious violations come with a monetary penalty.
Monetary penalties are determined using a gravity based system. Gravity is the severity of the hazard, multiplied by the probability. (Severity being how serious the fall could be, such as eight feet to grass versus 20 feet to concrete, and probability being the likelihood of a fall—there’s a higher likelihood of falling from a wet, slippery cedar-shingle roof than from a dry low-slope composite roof.) Severity and probability are rated on a scale of one-to-three, three being highest. Further adjustments are made based upon employer size and history.
Q: What happens if an employer has a history of not responding to these citations?
We call those repeat violations. If the first-time violation of a hazard is found again within three years, the base violation fine is multiplied—it gets up to a pretty big number once you get into multiple repeat violations. Three or more repeat violations is when the department starts looking at a willful act—plain indifference or intentional disregard—because the employer has knowledge of the requirements, has been cited in the past, has been informed of our consultation services, and have been found in violation again.
Q: What’s the most common violation you encounter that leads to fines?
More often than not, they’re not using fall protection. There’s either no fall protection in place, or they’re wearing a harness but they are not attached to an anchor, or there are no anchors. That’s a high percentage of the violations we find.
Q: What are the requirements of an anchor?
The Washington Administrative Code provides specifications for fall protection anchors which includes strength requirements. In general, these are performance standards that state a minimum strength an anchor has to be capable of supporting based upon the system used—5,000 pounds, for example. Typically, we see workers on a roof with a harness and shock absorbing lanyard that restricts the forces on the body to 900 pounds or less; in these cases, the anchor’s strength requirement would be 3,000 pounds.
Photo credit: SuperAnchor
Q: What types of anchors are available?
If we’re talking about residential construction, there are many temporary anchors that can be purchased. These include single-use and multiple-use ridge anchors. Typically these anchors will attach at the ridge of the home and meet the strength requirements when installed per the manufacturer. Ridge anchors are very common. We’re starting to see more higher-end homes and apartments where anchors are being installed as part of the structure and left in place permanently, which is fantastic. Commercial construction has more flat roofs, so a different style of anchor is typically built into the roof in those situations.
Q: How accessible is fall protection? Is it expensive?
These days, fall protection is available at many home improvement stores [including Dunn Lumber]. There are a lot of options out there; some can be relatively inexpensive basic systems, and others can be quite expensive—into the thousands of dollars. Generally speaking, if we’re talking residential construction and basic roofing, I’ve seen it around $100-$150, which includes an anchor, a vertical lifeline, rope grab, harness, and lanyard—perfect for one person to perform their work on a roof while meeting all the safety requirements. Fall protection can be very inexpensive and easy to use.
Q: Any final thoughts?
I would really like to see an increased use of fall protection. If we look back any number of years, across the United States, we can see that falls are the leading cause of death in the construction industry. In many of those cases there was no fall protection in place. The act of using fall protection would not only reduce violations but injuries and fatalities as well.
Erich has previously appeared on the Dunn Solutions podcast, where he discussed important updates to L&I rules and regulations.
Photo credit: SuperAnchor
