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Loui McCurley

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Beschreibung

Enables workplace responders to prepare for and respond to falls from height How do you rescue someone suspended in midair or trapped above ground? Author Loui McCurley, an expert in technical rope rescue with more than twenty-five years of experience, has the answers. Following her tested and proven advice, readers will learn how to prepare for and safely rescue "at-height" workers and others from "falls from height." The book fully bridges the gap between planning and execution, steering readers toward simple workplace-specific solutions. Moreover, it explains how to develop and implement a comprehensive protection program, enabling all organizations and their employees to fully prepare themselves to respond to a fall from height. Falls from Height is divided into four parts: * Part I: Regulatory Considerations, Rescue Plans, and Developing a Rescue Capability underscores the need for a rescue program, explaining how to fully leverage available resources to optimize the program. * Part II: Equipment, Systems, and Skills details the skills that all rescuers should have and the equipment they need to perform a rescue at height. * Part III: Putting It All Together discusses principles of rigging, single-rescuer methods, and group-rescuer methods. * Part IV: Successful Workplace Planning examines the unique challenges of different workplace environments and then offers a step-by-step guide for implementing the book's recommendations. Based on the premise that a fallen worker must be rescued quickly and efficiently, without putting others in harm's way, Falls from Height is a must for all workplace responders, enabling them to prepare for and respond to fall victims like experienced rescuers.

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Table of Contents

Title page

Copyright page

Dedication

Foreword

Preface

How to Use this Book

Your Success

Acknowledgments

PART I: Regulatory Considerations, Rescue Plans, and Developing a Rescue Capability

CHAPTER 1: The Reason for Rescue

Regulatory Requirements

Protecting Employees at Height

State Plans

Standards

Fall-Protection Plan

Fall Protection Systems for Rescuers

Summary

CHAPTER 2: Developing a Post-Fall Rescue Plan

Sometimes Workers Fall

Suspension Intolerance

Creating a Preplan

Emergency Response Planning

Preparing for Post-Fall Rescue

Summary

CHAPTER 3: Program Development and Incident Management

Employees as Responders

Summary

PART II: Equipment, Systems, and Skills

CHAPTER 4: Equipment for Co-Worker Responders

Regulatory Requirements for PPE

Fall Protection PPE versus Rescue PPE

Clothing and Personal GEAR

Summary

CHAPTER 5: Rescue Equipment and Systems

Considerations in Selecting Equipment

Ropes for Rescue

Slings and Webbing

Edge Protection

Connectors

Braking/Descent Devices

Rope Grabs

Pulleys

Multi-Function Rescue Devices

Subject Holding Device

Litters

Pre-Engineered Rescue Systems

Care, Inspection, and Retirement of Rescue Gear

Summary

CHAPTER 6: Personal Skills for Rescuers

Rescuer Safety

Ropes and Terminations

Anchorages

Personal Safety

Personal Escape

PART III: Putting It All Together

CHAPTER 7: Principles of Rigging

Gravity

Friction

Angles

Exercising the Concepts

Rescue Systems for Lowering

Rescue Systems for Raising

Rescue System Belays

Safety Factors

Summary

CHAPTER 8: Single Rescuer Techniques

When a Worker Falls

Responding to a Fall

Methods for Workmate Retrieval: Entry Methods

Rescue from Rope Access

Summary

CHAPTER 9: Group Rescue Methods

Roles and Responsibilities

The Group Response

Belaying the Rescuer

Horizontal Movement

Summary

PART IV: Successful Workplace Planning

CHAPTER 10: Industry-Specific Considerations

Buildings and Structures

Confined Space

Tower Construction and Maintenance

Wind Turbines

Bridges and Support Structures

Construction Sites

Offshore Installations

Summary

CHAPTER 11: Practical Workplace Application: Your Step-by-Step Guide to Developing a Co-Worker Assisted Rescue Plan

Step 1: Identifying Responsible Persons

Step 2: Policy Statement

Step 3: Fall Hazard Survey

Step 4: Mitigating Fall Hazards

Step 5: Fall Protection Plan

Step 6: Post-Fall Rescue Plan

Step 7: Coordination with Local Agencies

Step 8: Record Keeping and Training

Incident Investigation

Summary

Index

Copyright © 2013 by John Wiley & Sons, Inc. All rights reserved

Published by John Wiley & Sons, Inc., Hoboken, New Jersey

Published simultaneously in Canada

No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, (978) 750-8400, fax (978) 750-4470, or on the web at www.copyright.com. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons, Inc., 111 River Street, Hoboken, NJ 07030, (201) 748-6011, fax (201) 748-6008, or online at http://www.wiley.com/go/permissions.

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Library of Congress Cataloging-in-Publication Data:

McCurley, Loui, 1965–

Falls from height : a guide to rescue planning / Loui McCurley.

pages cm

Includes index.

ISBN 978-1-118-09480-8 (hardback)

1. Industrial safety. 2. Falls (Accidents)–Prevention. 3. Rescue work. I. Title. T55.3.H45M35 2013

658.3'82–dc23

2012049880

Psalm 86:13

… for your love for me is very great.

You have rescued me from the depths of death.

Foreword

An accident happens. Someone's life is in danger and for most of us the immediate reaction is to dial 911 or another local rescue service call-out number. That is almost always the right thing to do but for many workplace accidents, whoever responds may not be prepared to solve the problem quickly and safely, if at all.

As a 40-year veteran of the rescue service, I know well that all responders want to help and will often risk their own lives to save the lives of people they do not even know. Even if they are prepared to help, the time it may take for responders to reach the accident site, much less access the victim, can be too long in many locations and environments.

Emergency services dispatchers can send fire departments, ambulances, and law enforcement most anywhere in the United States. Areas that have environments that are difficult to access often have plans for calling out specialty rescue teams that are trained and equipped for mountain, cliff, avalanche, cave, mine, tunnel, wilderness environment, river, surf, and a host of other specialty technical rescues. In addition there are military responders like the Coast Guard and Air Force pararescue jumpers, ready to respond. Even so, response to difficult locations is often too late for the victim.

Most of us might think that an industrial work site would not be one of the aforementioned situations. We might assume that a workplace can rely on local public emergency responder services, particularly in the case of a “simple” fall off a work surface that is caught by fall protection equipment. The truth is that the employer has a duty to provide rescue in a timely manner whenever an employee is injured or in a situation of threat to life. Not only are employers required to provide proper safety protection, they must also have an effective rescue plan. Just calling 911 is not an effective rescue plan. It may not be the fall that gets you, or the almost sudden stop as one's fall arrestor deploys, but simply the wait for someone to get you down.

Falls from Height: A Guide to Rescue Planning is about responding to a fall safely and quickly, be it by your own skills and training, a co-worker, an in-plant emergency team, or an offsite rescue service. This book covers the regulatory rules, planning, and training needed to prepare the employer to get the rescue job done.

Many have written about protecting workers from falls but Loui McCurley takes fall protection to the next step: How do you get the person hanging in a harness from a lanyard 50 feet in the air over a rack of steam pipes, the person caught in a net 150 feet in the air and below a stadium roof, the person unconscious 300 feet up a tower on a caged ladder climb, or the person hanging from a cell phone monopole tower's climbing pegs down quickly? More importantly, how do you do so without further injury, and with safe techniques for the rescuers?

Loui McCurley has been involved in technical rope rescue since 1985. It was her interest in mountaineering as a sport that has since led to a lifelong career interest in rescue from height. I first worked with Loui when she was testing (read: “breaking”) rescue equipment in simulated field situations in order to find the best pieces of gear for the job. From the outset, Loui had a passion for finding answers and sharing what she learned with other rescuers. Since the early 1990s she has been the moving force behind finding great presenters for the International Technical Rescue Symposium, which is dedicated to sharing information among rescuers.

Also in the 1990s, Loui and others began to discuss the formation of an organization to help promote safety among suspended workers at height. While the Industrial Rope Access Trade Association existed already, this was a trade association for Rope Access companies. A worker-oriented organization had yet to be founded. Loui quickly took off with that project and organized a small group of like-minded individuals to found the Society of Professional Ropes Access Technicians (SPRAT). SPRAT represents the interests of the individuals who work at height, and has certified thousands of rope access workers who are now performing work at height all over the world.

Through her commitment to safety, supported by her paying job as Senior Vice President of Pigeon Mountain Industries, Loui has become involved in educating regulators, equipment manufacturers, and employers of the safety advantages of utilizing rope access for work at height, and the value of certification as a means of skills verification. This path has led Loui through a tangled web of national and international fall protection regulations and standards, and directly back to the place where she started: a place of deep concern and passion for safety in work at height.

In this one-of-a-kind text, Loui shares her wealth of experience to provide the reader with a thorough treatise on the subject of preparing for rescue after a fall in the workplace. In it, she covers all the bases, from who is responsible for what, to hazard awareness and mitigation, review of existing response protocols, new preplans, and specific recommendations on how to get it done. This is a book you can really use.

Stephen E. Hudson, President

Pigeon Mountain Industries

Preface

Whenever fall protection methods are used, the employer has a moral, ethical, and sometimes legal obligation to provide for prompt rescue (including self-rescue) in case of a fall.

To effectively prepare for prompt rescue, an employer must evaluate and understand his or her specific rescue needs and make appropriate preparations in advance. This book is designed to assist safety professionals whose job it is to plan for the safety of at-height workers, and for those whose responsibility it is to prepare for and perform post-fall rescue. This is a multi-faceted book, and may be used in any number of ways, depending on the needs of the reader. Some will find it advantageous to read the text cover-to-cover. Others may find it more beneficial to customize the approach to the text, and perhaps even read it in a different order than it is presented.

How to Use this Book

This book is designed for simplicity of use, maximum versatility, and to facilitate understanding by a variety of users ranging from the most skilled of field practitioners to the corporate executive of health and safety. The text is organized into chapters, each of which addresses a specific aspect of rescue in the workplace. While each chapter stands alone on a given topic, concepts in some chapters do build upon concepts that may have been initially introduced in another.

The practitioner who might wish to gain a thorough understanding of all aspects of the rescue equation may benefit from reading the book in its entirety, from front to back, while the industry professional who wishes only to brush up on a few things might prefer to pick and choose chapters most applicable to his need.

For ease of reference, the 11 chapters are grouped into parts containing related topics. The parts and chapters are as follows:

Part I: Regulatory Considerations, Rescue Plans, and Developing a Rescue Capability

This part is a must-read for managers and supervisors. It validates the need for a rescue program and provides guidance toward achieving maximum results with minimal resources. It contains three chapters:

Chapter 1: The Reason for Rescue. This chapter provides an overview of fall hazards and reviews the types of falls that occur in industry. It also offers guidance toward employer responsibilities, explains the role of voluntary consensus standards in relation to regulatory requirements, and offers insights on the comprehensive managed fall protection plan.Chapter 2: Developing a Post-Fall Rescue Plan. This chapter provides guidance on how to approach the development of a rescue plan, including how to determine whether a rescue plan is required, what the rescue plan should contain, and consideration of other hazards. This chapter also offers guidance on evaluating a response team and coordination with external resources.Chapter 3: Program Development and Incident Management. In this chapter, the reader will begin to explore the mechanics of the rescue process and gain a clearer understanding of the differences between personal escape, co-worker assisted response, and professional rescue. Roles and responsibilities are defined to establish a framework for selecting personnel, training, and managing an incident.

Part II: Equipment, Systems, and Skills

This part is for the field practitioner who really wants to gain the skills and knowledge to perform rescue at height. It explores requirements for fall protection equipment as compared with rescue equipment, and describes basic skills that every rescuer should be able to perform.

Chapter 4: Equipment for Co-worker Responders. This chapter explores selection, care, and maintenance of equipment that is worn or used by the rescuer for safety and rescue.Chapter 5: Rescue Equipment and Systems. In this chapter, the reader gains a deeper understanding of equipment that is appropriate for life safety and rescue applications, specifically that which is used for rigging. Attention is given to pre-engineered systems as well as components.Chapter 6: Personal Skills for Rescuers. Here the reader is introduced to the basic skills that establish a foundation for rescue. Methods for anchoring, descending, ascending, and patient care are addressed.

Part III: Putting It All Together

This part is of interest to both safety managers and field practitioners. It introduces systems and techniques for rescue, offers guidance toward bringing the big picture into focus, and guides thought processes toward specific hazards and industry considerations.

Chapter 7: Principles of Rigging. This chapter offers a cursory understanding of the physics that affect rescue systems and how to use those concepts in harmony with the equipment introduced in Part II to achieve rescue-related tasks such as anchoring, lowering, raising, and re-directing a load.Chapter 8: Single Rescuer Techniques. Building on the concepts in Chapter 7, this chapter introduces specific methods and techniques that can be used by one co-worker to rescue another in almost any environment. Step-by-step guidance is provided to enhance training.Chapter 9: Group Rescue Methods. This chapter also expands the concepts found in Chapter 7, but this time with specific methods and techniques that are more conducive to a multi-person response. Again, step-by-step guidance is provided to enhance training.

Part IV: Successful Workplace Planning

This part is primarily of interest to safety managers, although experienced field practitioners will benefit from understanding and applying the information in this part as well. Some particular nuggets that are applicable to various industries may be found in Chapter 10.

Chapter 10: Industry-Specific Considerations. While rescue from fall protection shares some similarities (such as gravity) regardless of environment, each unique job involves its own distinctive challenges and hazards based upon the type of work being performed, the environment, and other factors. This chapter provides insight into assessing hazards in several common workplace environments.Chapter 11: Practical Workplace Application. This chapter is a step-by-step guide for implementing the contents of this book. It contains forms, checklists, and guidelines that both the manager and the practitioner can use to establish, perform, and maintain post-fall rescue capabilities in a workplace.

Again, it is important to note that while the chapters in this book attempt to offer a thorough treatise on their respective subjects, the information from beginning to end is intertwined and interrelated.

Your Success

It is my deep desire that this book aids you along the way toward greater safety in your workplace environment, whether you are a worker, a manager, a supervisor, an employee, or an employer. If you have suggestions or recommendations for future revisions of this book, or of companion works, I welcome you to share those with me as I seek to continue in my mission to equip workers at height with tools for safety.

Stay safe!

Loui McCurley

Acknowledgments

I would like to thank those who have, knowingly or unknowingly, contributed to the development of this text. First, my supportive husband Bob and sons William and Ian for their encouragement and respective votes of confidence, and to my mom for instilling a love of books. A special thanks to Bob, especially, for not being afraid to tell me when parts of the text were gobbledygook, and for assisting with moral support, encouragement, and editing.

I would also like to thank my talented team of content critics who so valiantly waded through reams of material to weed out extraneous information, correct errors, and recommend improvements: John Peleaux, for sharing decades of rigging and technical expertise; Barbara Bielaski, for her wealth of regulatory and industry knowledge related to fall protection; and Mike Roop, for his rescue management and industrial/confined space experience. Others, too, without whose specific knowledge and contribution the content would be lacking: Michael Stewart, who contributed safety management and engineering experience in the field of wind energy; Michael Seal, for lending safety management experience in bridge inspection and engineering; John Paul Jones, whose tower safety and rescue expertise was significant; Amos Yost, for sharing his unique expertise related to agricultural facilities and grain bin rescue; and Steve Hudson, for years of mentoring prior to this work, as well as for helping me to put some finishing touches on the text.

Finally, I would like to thank Robert McCurley and William Clem for the many hours of photography assistance they provided for this book, as well as those who facilitated the provision of photos, including Pigeon Mountain Industries; Vertical Rescue Solutions; Garin Wallace and Donald Enos of Seattle Manufacturing Co.; Keith Jones of Heightec, Ltd.; Dan Henn of Reliance Industries, LLC; Doug Knap of Tractel, Inc.; Michael Seal of Burgess & Niple; J.P. Jones of Safety LMS; Climb-Tech; Beal SA; Dawn Wilson; and John Peleaux of Innovative Access, Inc.

L.M.

PART I

Regulatory Considerations, Rescue Plans, and Developing a Rescue Capability

CHAPTER 1

The Reason for Rescue

By the end of this chapter, you should understand:

The role of regulatory requirements in fall protection.The role of voluntary consensus standards in relation to regulatory requirements.How to approach forming a comprehensive managed fall protection plan.The hierarchy of fall protection.Common types of fall protection.

Early one December morning, on a swing stage scaffold suspended 50 feet above an ore dock, two workers performed maintenance work. In preparing to move the scaffold from one location to another, they discovered that one of the cables was kinked. As one of the workers worked to remove the kink, a strap that secured the swing stage to the dock let loose, causing one end to swing out from the dock. The worker was launched from the scaffold, striking the base of the dock 50 feet below before falling into the water. His surprised co-worker reacted as quickly as possible, extracted himself from the scaffold, and rushed to the base of the dock, searching for some way to help his companion. Spotting an extension cord nearby, he used it to lasso his companion's arm as he called for help. He did his best to hold his co-worker's head above water with the makeshift rescue line until rescuers were finally able to retrieve the employee from the water, using a boat. But it was too late. The fallen employee was not breathing at the time of rescue, and was later pronounced dead.1

Organizations that employ workers at height have an obligation to protect those workers who are at risk from falling during the course of their work. This is true whether the employee is working in a manufacturing facility, construc­­tion, transportation, agriculture, or any other industry. Being protected from a catastrophic fall, however, is just the beginning. Post-fall rescue is imperative whether the worker has impacted the ground or a lower level, or remains suspended in his harness.

Anyone who might harbor even the slightest doubt as to the importance of post-fall rescue for a suspended worker should engage in this simple little exercise:

1. Don a harness of the type that you/your workers normally wear.
2. Connect a lanyard to the harness in the manner in which it is normally used.
3. Connect the lanyard to an anchor that will allow you be suspended with your feet just at floor level.
4. Lift your feet so that you are hanging in the harness, as shown in Figure 1.1.

Figure 1.1 What does it feel like to be suspended after a fall?

Within about 60 seconds, the importance of post-fall rescue will become crystal clear, without you even having suffered the effects of a fall!

Caution! This exercise should be attempted only under proper supervision by a qualified individual who is able to ensure immediate rescue. Always obtain your doctor's permission before engaging in this type of exercise.

Regulatory Requirements

In the United States, the obligation to protect employees stems from the Occupational Safety and Health (OSH) Act of 1970, which acceded regulatory authority for the workplace to the Occupational Safety and Health Administration (OSHA) and assigned them with a number of specific regulatory functions, among them:

1. Setting standards, and
2. Conducting inspections.

OSHA's specified purpose is “to assure … every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources.”2

As part of its mission, OSHA conducts inspections and issues citations to employers who do not provide adequate safety for their employees. Different types of violations can result in varying levels of financial penalties, with greater fines resulting from more serious violations. Violations deemed to be “willful” or “repeat” in nature can carry maximum fines up to ten times higher than serious violations. A willful violation is one committed intentionally, with foreknowledge or voluntary disregard for the law's requirements, or simply with indifference to worker safety and health. A citation for a repeat violation is issued when there have been previous citations for substantially similar violations at any work site owned by the same company.

The OSH Act was passed December 29, 1970, but OSHA did not come into existence until 1971. Since its inception, OSHA has developed numerous federal standards relevant to workplace safety and health. The standards cover four specific industries—construction, maritime, agriculture, and general industry—and are enforced throughout the United States. The term “standard” means something completely different when referring to OSHA standards as compared with voluntary consensus standards such as those developed by accredited standards-developing organizations. Because OSHA has enforcement authority, the standards (sometimes called rules or regulations) it sets have the force of law.

Employers who function under the laws of the United States are required to provide a safe and healthful workplace, as defined by these regulations, for their employees. OSHA monitors compliance to these regulations through inspections, whistle-blower programs, reporting requirements, and post-incident follow-ups.

Even in areas where OSHA has not identified a specific standard to address a particular hazard, employers are held responsible for employee safety under the Occupational Safety and Health Act's general duty clause. The general duty clause states that each employer “shall furnish … a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”3 Falls are a recognized hazard, ranking among the top 10 federal standards with the most repeat violations cited by OSHA.

Most other countries have some agency that serves a function similar to that of OSHA. In the United Kingdom it is the Health and Safety Executive (HSE); in Australia it is the National Occupational Health and Safety Commission (NOHSC); and in other countries there are other, similar agencies with other, similar acronyms. The regulations in each country differ from one another, so it is incumbent upon an employer working in a foreign country to become familiar with, and adhere to, the regulations of the country in which he is working.

Regulatory discussion is not a major focus of this book, but we will touch upon it to some degree as a foundation for the systems and methods discussed herein. Because this text is written in the United States, when the concept of governmental regulation of health and safety is referred to, it will be in context of OSHA. This is not to suggest that all readers from all countries should follow OSHA, it is only to serve as a point of reference. Readers from other countries are encouraged to further research their own regulatory authority (or authorities), with consideration to the concepts presented here.

Keeping workers safe is not just the law—it is also a good idea from a practical, economical standpoint. In 2009 alone, the Bureau of Labor Statistics logged more than 200,000 workplace falls. This, in turn, translates to billions of dollars in lost time, workers' compensation, litigation, medical costs, and so on. There is also the matter of worker morale to consider. No one wants to head off to work each day not knowing whether he or she will live to see another. Good employers know that safe, healthy workers are motivated, productive workers.

The category of potential workplace emergencies addressed by this text is that of fall-related incidents. Although we will briefly touch on some other specific hazards, employers with high risk exposure in these or other areas will want to consult industry-specific resources for solutions relevant to their particular application.

The majority of workplace falls are relatively simple slips and trips such as might occur on any walking surface. These types of falls are typically not catastrophic but are notable in that they may result in injury and/or time lost from work. These types of falls are important, but they are not the focus of this book.

Beyond the hazards of slips and trips on the horizontal dimension, many employers also employ individuals who work in or near the vertical dimension. This may include suspended work, scaffolds, elevated construction, large machinery, catwalks, container tanks, and other raised surfaces. Falls in these environments are much more likely to result in significant injury or even death. Falls that occur in this context, and more specifically, rescue of persons who fall while working in these types of environments, will be the focus of this book.

Protecting Employees at Height

OSHA regulations recognize that different employees may possess different levels of responsibility in the workplace. Workers may be held to different expectations, depending upon what level of responsibility the employer has bestowed upon them. Throughout the regulations, the designations of Authorized, Competent, and Qualified are used to describe the differences. Although not all users of this manual will adhere to OSHA standards, these designations will be used throughout, as they are particularly useful in discussing different levels of responsibility.

As a general rule, the term “Authorized Person” refers to an individual who is approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite. The term “Competent Person” is used in reference to one who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

The term “Qualified Person” is a bit more of a loaded term. In regulatory-speak, it means “one who, by possession of a recognized degree, certificate, or professional standing, and/or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.” At this writing, there is a slight but meaningful distinction between the construction rules and the general industry rules in the United States. The powered platform (general industry) section states “one who, by possession of a recognized degree, certificate, or professional standing, and who by extensive knowledge …” while the construction rule states “one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge …” (emphasis added by author).

Some OSHA standards present additional specific requirements that must be met by the Authorized, Competent, or Qualified Person(s), and the same or similar terms are also used by many standards throughout the world, usually in a similar manner. These concepts are foundational when planning any work at height, and any written documentation should specify what level of authority/responsibility the employer has designated to specific individuals for specific functions.

It is entirely possible—and even quite likely—for a person to be designated by their employer as an Authorized, Competent, or Qualified Person for one particular aspect of a job (such as fall protection, hazardous materials, or machinery operation), but not for other areas that pose different hazards or that require compliance to different regulations. On the other hand, it is possible that a given person might possess all of the experience and training necessary to allow him or her to be designated by the employer as an Authorized, Competent, or Qualified Person for every aspect of the entire jobsite. The more likely scenario is somewhere in between. A given person may be designated in one or more areas of the job as a Competent Person and as an Authorized Person in other aspects of the job.

In the United States, there is no single OSHA standard that establishes all of the specific responsibilities of Authorized, Competent, and Qualified Persons, but references to these appear throughout OSHA rules, standards, directives, and interpretations. Some of the OSHA standards list very specific requirements for qualification, tasks, and/or responsibilities, while others make only passing references. It is imperative that employers and safety professionals diligently research the regulation(s) that might apply to their type of work and environment to ensure that all requirements have been met for all levels of their employees.

Understanding employer and governmental regulation as it applies to fall protection for employees can be difficult, and this difficulty is compounded by the many different types of work and different kinds of fall hazards that may be present in the workplace. Additionally, OSHA has what it calls duty requirements that specify when an employer must have fall protection and other requirements that describe the criteria and practices that must be followed for each type of fall protection system used. However, it is simply not possible to organize fall protection, much less post-fall rescue, into a neat set of specific rules that fit all situations. OSHA acknowledges this difficulty when it separates its rules for fall-protection into one set of requirements for general industry, and another set of requirements for construction.

Federal rules for fall protection in the United States' construction industry are addressed primarily by OSHA in 29 CFR 1926.500 to .503, while fall-protection rules for general industry are found primarily in 29 CFR 1910.23 and 29 CFR 1910.132. It is important to note that it is the work being performed, not the job title, that determines which rules apply. Therefore, construction trade workers who are performing maintenance or general industry work would be held accountable to the applicable parts of the general industry standards found in 29 CFR 1910, and vice versa. In addition, 29 CFR 1910.66 has rules for fall protection when working on powered platforms, including both the duty to use fall protection and the criteria for personal fall arrest systems.

In accordance with U.S. federal regulations, as a general rule fall protection must be provided if an employee can free fall 4 feet or more onto a lower level in general industry or 6 feet or more onto a lower level in construction. This includes (but is not limited to) the following situations:

When an employee is on a walking/working surface that has an unprotected side or edge.When an employee is constructing a leading edge.When an employee may fall through a hole in the walking/working surface.When an employee is working on the face of formwork or reinforcing steel.When employees are on ramps, runways, and other walkways.When employees are working at the edge of an excavation, well, pit, or shaft.When employees are working above dangerous equipment (even employees working fewer than 4–6 feet over dangerous equipment must be protected).When an employee is performing overhand bricklaying and related work.When an employee is performing roofing work on low-sloped roofs.When an employee is working on steep roofs.When an employee is engaging in precast concrete erection (with certain exceptions).When an employee is engaged in residential construction (with certain exceptions).

Already you can see that the employer has a big job on his or her hands when it comes to figuring out which regulations apply to his or her workers, and when. The complexity is further compounded as fall protection within these categories is then divided into several different subparts, depending on the nature of work being undertaken. There are separate guidelines, for example, for fall protection during work on scaffolds, on certain cranes and derricks, in tunnels, on stairways and ladders, during steel erection, and so on. Some of these have slightly different height limitations, and there are even complete exclusions in some instances.

The logic behind these variations can seem elusive, until you understand the scope, breadth, and complexity of the OSHA mission. OSHA adopted many of its original fall protection standards (like the current subpart D) from national consensus standards. Let's use the “4 foot rule” as an example. OSHA's fall protection rule in general industry requires fall protection for employees whenever they are working at heights in excess of four feet. This rule, which differs from other corresponding rules in OSHA regulations, originally came from a 1932 American National Standards Institute (ANSI) standard, A12.1. ANSI A12.1 has since been updated (A1264), and much work has been done to substantiate the survivability of falls greater than 4 feet—yet OSHA's 4 foot rule remains.

This story illustrates the fact that although national consensus standards are reviewed periodically, and many have been updated, corresponding OSHA regulations have not necessarily followed suit at the same speed. It is much more difficult to change an OSHA rule than to change an industry standard. Revised or new OSHA standards are subject to a stringent rulemaking process (including public participation) which, along with active lobbying from special interest groups, can make updates a lengthy and tedious process. As a result, sometimes regulations are not updated at the same rate of progress as technology.

As this book goes to press, OSHA is revising its general industry fall protection rules to consolidate the rules in subparts D and I. It is hoped that this will simplify matters and help facilitate compliance.

State Plans

Employees who work for state and local governments in the United States are not covered by federal OSHA, but the Occupational Safety and Health Act does mandate protection for these workers in states that have an OSHA-approved state program, usually referred to as a state plan. A state plan is a job safety and health program that is similar to OSHA regulation, but operated on a state rather than federal level. OSHA approves and monitors state plans to ensure that they provide adequately for employee health and safety. State plans, by definition, may implement rules that differ from federal OSHA requirements, provided that those rules are (to use OSHA's words) “at least as effective” as the corresponding federal rules.

State plans may address one or more areas of safety that correspond with federal OSHA regulations, so it is important that the employer take all potentially applicable rules into consideration, and strive for compliance with whichever regulation(s) are most conservative—that is, those that are most protective of the worker. More information can be found at www.osha.gov.

At this writing, the regions listed in Table 1.1 have state plans. Four these states (Connecticut, Illinois, New Jersey, New York) and one U.S. territory (Virgin Islands) have OSHA-approved plans that cover public sector (state and local government) employees only. Private sector workers in these four states and the Virgin Islands are covered by federal OSHA.

TABLE 1.1 U.S. States and Related Regions with Approved State Plans

AlaskaMarylandPuerto RicoArizonaMichiganSouth CarolinaCaliforniaMinnesotaTennesseeConnecticutaNevadaUtahHawaiiNew JerseyaVermontIllinoisaNew MexicoVirgin IslandsaIndianaNew YorkaVirginiaIowaNorth CarolinaWashingtonKentuckyOregonWyoming

aPlans cover public sector (state and local government) employment only.

Where state plans exist, typically they adopt standards identical to the corresponding federal ones. Those that do vary will often also promulgate additional standards covering hazards not addressed by federal standards. State plan states must conduct inspections to enforce their standards, include public (state and local government) employees, and operate occupational safety and health training and education programs. In addition, most of these states provide free on-site consultation to help employers identify and correct workplace hazards.

OSHA requires federal employees to be protected by an effective and comprehensive safety and health program. Executive Order 12196, Section 1–201, and 29 CFR 1960.16 require federal agencies to adopt policies and procedures necessary to provide a level of protection equivalent to that provided by OSHA standards and regulations. Although OSHA does not fine federal agencies, it does monitor federal agencies and responds to workers' complaints. The United States Postal Service (USPS) operates under OSHA regulations.

At this writing, categories of workers not covered by the OSH Act include: those who are self-employed; immediate family members of farm employers who do not employ outside employees; and those who are regulated by another federal agency (for example, the Mine Safety and Health Administration, the Federal Aviation Administration, or the U.S. Coast Guard).

It is the responsibility of the employer to be aware which rules and regulations apply to a given workplace. Where multiple potentially applicable rules appear to be contradictory, it is always best to take the most conservative approach. The scope of this text will discuss only federal OSHA rules for general industry and construction in a very broad sense. State-specific variances from OSHA will not be addressed, nor will variations between countries. Do your homework and be very sure that your workplace health and safety program complies with the requirements of the country and jurisdiction in which you are working.

Standards

Although OSHA has the statutory authority to develop, promulgate, and enforce occupational safety and health standards, they do not do so in a vacuum. The federal government recognizes the value of the consensus process in safety and health standards. In fact, when OSHA first started, it was required (under Section 6a of the act) to adopt national consensus standards for the first 2 years of its existence without rulemaking. This contributed greatly to the body of knowledge that was adopted at that time.

Today, OSHA still tends to nurture cooperative working arrangements with private organizations that develop voluntary national consensus standards on topics related to occupational safety and health. In fact, the National Technology Transfer and Advancement Act (NTTAA)4 directs agencies to use national consensus standards instead of writing their own when possible. OSHA takes this even a step further: if the agency deviates from national consensus standards it is required under Section 6(b)(8) of the act to explain why.

OSHA's recognition of and cooperation with national consensus standards can be helpful to the employer because OSHA fall protection regulations tend to be very performance-oriented. That is, OSHA defines relatively broad, sweeping objectives for protecting employees from fall hazards. By necessity, methods for applying and achieving those objectives will vary depending on the environment and work-type, among other things, and OSHA appropriately leaves this topic to more narrowly focused industry-specific consensus standards such as those developed under the ANSI consensus procedures.

ANSI is an accrediting organization that oversees the development of standards by member organizations such as the American Society for Testing and Materials (ASTM) and the American Society of Safety Engineers (ASSE). These and other consensus standards-developing organizations bring industry professionals together to develop national consensus standards under the ANSI process, which helps to ensure representation from a variety of perspectives and interests. OSHA offers cooperation and assistance to these voluntary consensus standards efforts through technical assistance and resources, participation in selected standards development efforts, and sharing occupational safety and health research reports with ANSI to assist in its mission.

Some of the industry consensus standards that are used by employers to supplement OSHA Fall Protection Standards today include ANSI Z359 on fall protection equipment, ANSI A10 on safety requirements for construction and demolition operations, and ASTM E 2505 on rope access. These consensus standards are generally consistent with OSHA standards, but go into much greater technical detail regarding how to accomplish the requirements set forth by OSHA.

As an example, OSHA sets requirements for rescue after a fall. Specifically, OSHA's Occupational Safety and Health Standards in 29CFR 1910.66 App C Sect I (e) (8) Subpart: F, Personal Fall Arrest Systems states, “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure the self-rescue capability of employees.” To help employers achieve OSHA's mandate, ANSI Z359.2–2007 discusses the incorporation of rescue into the comprehensive managed fall protection program; ANSI Z359.4–2007 specifies performance requirements for assisted-rescue and self-rescue systems, subsystems and components; and ASTM E 2505–07 identifies partner rescue as a key part of a rope access program.

Employers must do research on current applicable regulations and standards to ensure compliance for their specific worker type and location. When in doubt it is best to err on the conservative side of interpretation. Employees must be protected not just from falling off a surface, but from falling through holes and from having objects fall onto them from above.

Fall-Protection Plan

Every employer who places workers at height should do so only under a written fall-protection plan. The fall-protection plan is a thorough treatment of fall hazards, and should not be confused with the job hazard analysis (JHA). A sample JHA form is shown in Figure 1.2.

Figure 1.2 Sample JHA Form. Credit: Vertical Rescue Solutions/PMI.

A JHA provides a general overview of hazards while the fall protection plan goes into a thorough, detailed process that is intended to address all aspects of the work to be performed at height. The JHA, then, is but one part of a good fall protection plan. ANSI Z359.2 provides minimum requirements for a comprehensive managed fall protection program and is an excellent resource that provides formal guidance for developing a fall protection program.

A well-written fall-protection plan begins with a policy statement that is specific to the company writing it. This statement provides an overview of general goals and guidance for the managed fall-protection program and emphasizes management's commitment to providing a safe workplace for employees who are exposed to fall hazards. A policy statement might read something like the following:

(COMPANY NAME) strives to protect the health and safety of all employees. As a part of this policy, (COMPANY NAME) will equip, train, and expect employees to use effective fall-protection systems whenever exposed to a foreseeable fall hazard. (COMPANY NAME) also maintains an active program to make available self-rescue, assisted rescue, and professional rescue in the event of a fall.

The fall-protection plan should go on to identify the employer's designated program administrator, as well as the person(s) involved in developing the fall-protection and rescue plans, respectively. The plan should be reviewed periodically, at a minimum whenever work practices, equipment, or other aspects of the program change.

Fall Protection Plan
A Fall-Protection Plan should include at least the following:
Policy statementName of program administratorName(s) of responsible person(s)Fall hazard surveyFall mitigation planPost-fall rescue plan.

The foundation of the plan is the fall hazard survey, which is a thorough, methodical identification of all fall hazards associated with an employer's workplace/practices. The fall hazards should be listed specifically and individually and described in as much detail as possible to facilitate safety and rescue planning. In some cases, a diagram or photograph of the location may be helpful.

In describing the location, be sure to consider how the location is typically accessed, the type of work that normally occurs in that location, persons potentially exposed (not just workers but also bystanders), height of potential fall, obstructions, and other potential hazards. It may also be helpful to consider any history of previous incidents in this (or similar) locations (if known), as this kind of information can provide insight toward prevention as well as provision of safety and rescue. Understanding how likely an incident might be to occur, and how severe the potential consequences might be, will also help drive the response.

The next step is to determine how to best protect employees from each hazard identified. Some people automatically equate the term fall protection with fall arrest, but this is not accurate. Fall arrest is but one of many possible fall protection solutions. Protecting a worker from a fall may be accomplished by any of a number of methods, and employers should always opt for the safest practical means available. The “hierarchy of fall protection,” illustrated in Figure 1.3, is a useful tool in determining order of preference. Using this approach, fall-protection methods are presented in an order that is presumed to preferentially provide the greatest safety, with the most desirable method forming the base of the pyramid and the least desirable method at the peak.

Figure 1.3 Hierarchy of protection.

As illustrated by the hierarchy diagram, the safest means of fall protection is, of course, to simply eliminate the hazard. Colloquially called “elimination or substitution,” in essence it simply means removing the hazard or hazardous work practices. In performing a given task, the employer should ask him- or herself, “Is there is another, safer, practical method that effectively accomplishes the task without placing an employee at risk of a fall?” If the answer is yes, the less risky method should be chosen.

Such elimination is arguably the most effective control measure for protecting employees from a fall in that this prevents the worker from ever being placed in the hazardous situation to begin with. Elimination of a fall hazard is usually achieved by changing a process, sequence, or procedure such that Authorized Persons are not exposed to the fall hazard. Lowering the work surface to ground level—as in lowering highway lights to the ground in order to change the light bulbs—is one example of substituting a work method in order to eliminate a fall hazard. In other words, fall prevention is a very effective method of fall protection.

Passive fall protection, the next preferred approach to fall protection, is another preferred method of fall prevention. The advantage of passive systems is that they generally do not require any special training or equipment on the part of the user. Passive fall protection involves isolating the worker from the hazard—for example, by means of a guardrail.

If a hazard cannot be mitigated through elimination or through passive methods, Administrative controls may be a good alternative. Administrative controls include processes that prevent a person’s exposure to a fall hazard. Such controls might include training, warning signs, lights or sounds, or other warning methods. American National Standard Z535.2, Environmental and Facility Safety Signs, contains standards for warning signs. One disadvantage of administrative controls is that they rely heavily on human behavior, management, and training. Once a person steps over the line in the example above, the immediate consequence is that he or she is exposed to the fall hazard. Under such a circumstance, if the worker does fall, fatal injury is likely.

The final approach to protection that should be considered involves use of Personal Protective Equipment (PPE). PPE may be the best solution available when a person must work at or near an edge, or in the vertical environment. Types of protection that utilize PPE include rope access, restraint/positioning, and fall arrest.

Rope access provides excellent protection, but requires specialized training and techniques for workers. Rope access methods utilize a redundant, two-rope system wherein one rope provides the “working surface” and the other provides “backup safety.” In effect, it is like a positioning system backed up by a unique, secondary fall protection system—essentially resulting in dual protection. As a result, rope access facilitates safer access to the most challenging of worksites. Using specialized descending and ascending equipment, the worker can move from place to place in suspension to perform a wide variety of work. Rope access workers offer additional advantages in that they are usually highly trained above and beyond work procedures to also effect a self-rescue or partner rescue should the need arise.

Fall restraint is a different method, and involves securing (or tethering) the Authorized Person to a suitable anchorage using a lanyard short enough to prevent the person’s center of gravity from reaching the fall hazard.

If rope access or fall restraint methods are not viable options, placing the worker at height and protecting him or her with a fall arrest system may be used. Fall arrest is a broad term encompassing a variety of systems designed to stop an Authorized Person after a fall has begun. Fall arrest systems range from fall arrest lanyards with force absorbers to self-retracting lifelines to vertical or horizontal lifelines.

The next few pages will discuss each of these types of fall protection in greater detail, with the goal of providing information that will improve the safety of the rescuer, as well as to his or her ability to render assistance to another.

Fall Protection Systems for Rescuers

Anyone who may find it necessary to rescue another from an industrial fall protection environment should first have a firm understanding of the various types of fall protection systems used by workers who may require rescue. Would-be rescuers should have a working knowledge of fall protection methods and equipment for their own safety, as well as for greater understanding of how best to achieve rescue in that environment.

The best method(s) of protection for the rescuer's safety in a given environment will most likely be the method(s) already in use there. A firm understanding of fall protection methods and systems will also enable the rescuer to be more effective when rescuing another. What type of fall protection a fallen worker was using will have some impact on how the rescuer(s) are able to locate, access, and extricate him or her.

Passive Fall Protection

Clearly we have determined that workers who are exposed to a potential fall from height while working on a raised surface must be protected from falling by some means. Elevated work surfaces where work is frequent or ongoing may have a permanent or temporary fixed barrier installed around the edges of the platform and surrounding any open holes. These methods of protection are less likely to result in a worker being suspended and in need of rescue than restraint or fall arrest systems. For example, if a worker is not stopped by a railing, chances are they will impact the ground below and rescue will be a relatively simple matter of picking them up from the floor or ground.

This book will endeavor to focus on those types of fall protection systems—both passive and active—which are most likely to stop the worker in a manner or location where the worker may then be in need of rescue. Because barriers and handrails really do not fit this description, this book offers little attention to those methods. However, a few points are notable for rescuers who may be working in environments where such protection is present.

Barriers consist of passive systems such as a guardrail, parapet wall, or fencing. These are intended to provide a barrier to stop a worker from proceeding past the edge of a work level or into a floor opening, and to protect the employee from falling. One type of barrier that is common in many workplaces is the guardrail, which consists of a top-rail, mid-rail, and toe-board secured between vertical posts. A compliant guard rail must rise 39–45 inches above the walking/working level and must be capable of resisting at least 200 pounds force at any point along the rails, or if a higher load is anticipated it must be able to withstand that load. There must also be some sort of protection from falling between the rails such as siderails, screens, mesh, or intermediate vertical members.

Stair rails, used as a physical barrier on open stairs and ramps, are built to similar specifications as guardrails. Useful guidance for installation of guardrails, covering holes, and otherwise isolating hazards in general industry may be found in American National Standard A1264.1, Safety Requirements for Workplace Floor and Wall Openings, Stairs and Railing Systems, while similar guidance for construction may be found in A10.18.

Rescuers should note that while most properly constructed guardrails and stair rails offer sufficient strength for their normal, intended use, utilization of a guardrail or stair rail to anchor restraint, positioning, or rescue lines may not be adequate; in fact, some rules specifically prohibit tying off to guardrails.

Rope Access

Rope access is a specialized mode of access and protection that may be employed by specially trained, certified technicians to access hard-to-reach places in a variety of industries. Rope access methods are often combined with conventional fall protection methods (restraint, positioning, arrest) to accomplish engineering inspections, maintenance work, installations, and other tasks in an efficient and comprehensive manner.

Rope access technicians rely on two ropes for access and protection: a primary line for ascending, descending, and traversing, and a backup line for safety. In this type of system, the fall protection offered by the second line is completely separate and independent from the primary means of support. The two rope systems are at once independent yet interchangeable, offering great versatility while maintaining continuous redundancy. Rope access methods are often, but should not be, confused with recreational pursuits such as climbing. This is an erroneous comparison in that recreational climbing is a sport whose focus is the personal challenge of the climbing endeavor, while in rope access, the focus is merely to safely reach a worksite for the purpose of performing a task.

Figure 1.4 shows a typical rope access system. Here you can see that the second line that is employed for backup safety in rope access differs from conventional fall arrest in several ways. First, in order for the secondary system to deploy, the very substantial primary system would somehow have to fail. With built-in fail safe mechanisms and extremely high safety factors, this is highly unlikely. Second, the backup safety system is rigged and managed in such a way as to preclude the extensive fall potential that is allowed in conventional fall arrest. Finally, the backup safety system is much more dynamic than a conventional fall arrest system, and softens any potential impact with ease.

Figure 1.4 Rope access system.

Rope access technicians are typically evaluated and certified by an independent third party organization such as the Society of Professional Rope Access Technicians (SPRAT). SPRAT is a consensus-driven membership organization that maintains industry-consensus standards on Safe Practices for Rope Access Work as well as on Certification Requirements for Rope Access Technicians.5 These useful guidance documents are available from the organization's website at no cost.

Certified entry level rope access technicians typically receive at least 40 hours of initial training, and advanced certification requires extensive experience and verification of greater skill levels. Such extensive training and skills help prevent incidents from occurring, and in the unlikely event of compromise the certified rope access technician is almost always capable of self-rescue and partner rescue.

Fall Restraint

Restraint systems consist primarily of a safety harness or belt, a lifeline and/or lanyard, and a 3,000 pound capacity anchor. These are frequently used where work is being performed in a temporary capacity and/or where a fall arrest system is neither justified nor necessary.

A restraint system performs a little like a leash, and is intended to prevent the worker from reaching an edge where there is a risk of falling. In order to perform effectively, restraint systems must be rigged so that the worker is not capable of reaching a position where a fall might occur.

If the worker misuses the restraint system—for example, if the system is rigged such that the worker can extend his or her body weight beyond a leading edge—it might be possible for a worker to fall into the system and become suspended and in need of rescue. This is clearly a misuse of a restraint system, but planning for such an event may nevertheless be quite justified.

Fall Arrest

Personal fall arrest systems, such as that shown in Figure 1.5, should meet appropriate OSHA guidelines for construction (1926.502(d)) or general industry (1910), depending on the type of use. Normally, a fall arrest system will consist of at least a 5,000 pound capacity anchorage, lanyard, connectors, and a full body harness. Additional components, such as a rope, a fall arrester, and other equipment, may be incorporated into some systems.

Figure 1.5 Personal fall arrest system. Credit: Tractel, Inc.

A well-designed personal fall arrest system will prevent the user from a free fall greater than 6 feet (1.8 meters) and from contacting any lower level, and will also limit maximum arresting force on the employee to no more than 1,800 pounds force (8 kilonewtons [kN]). At this writing, there is a general move toward reducing the allowable impact force by half, to 900 pounds force (4 kN).

Directly related to the concept of impact force is the matter of stopping distance. When a mass is in free fall and must be arrested, the energy generated by the falling mass has to go somewhere. That somewhere often involves force absorbers that extend in length when deployed, rope grabs that intentionally slip against a rope, and equipment that is designed to elongate under load. In fact, considering the allowable free fall distance, an allowable deceleration distance of 3.5 feet, and inherent elongation in the system, it is quite foreseeable that a person could easily end up well in excess of 12 feet beneath the original point from which they fell. This fact is of considerable importance to would-be rescuers.

Effective fall arrest guidelines may be found for general industry in ANSI Z359, or in ANSI A10.32 for construction.

Fall Arrest Using Self-Retracting Lifelines

A self-retracting lifeline (SRL) is a specific type of fall protection device that may also be referred to by the monikers “retractable lanyard,” “inertia reel,” or “fall arrest block.” Most SRLs consist of a lifeline (wire rope, webbing, or fiber rope) wrapped several times around a spring-loaded drum that is fitted with a centrifugal brake and encased inside a housing. Some SRLs are designed to be affixed to an anchorage above and in line with the worker, with the end of the lifeline attached to a fall arrest D-ring on his harness. Other SRLs (as shown in Fig. 1.6) feature the block fixed directly to the dorsal D-ring, with the line anchored above. In either case, as the person moves in a controlled fashion the tensioned reel pays out and retracts, allowing the cable to travel but always with a slight bit of tension.

Figure 1.6 One type of SRL. Credit: Reliance Industries, LLC.

As long as the user moves in a smooth and controlled manner, the drum allows the lanyard to feed out and/or retract, maintaining light tension on the user. In the event of a sudden load, however (greater than 4.5 feet/second), the system locks up with less than 900 pounds force and 24 inches stopping distance. When tension is relieved on the system, the drum once again allows the SRL to move freely.

Fall Arrest Using Vertical Lifelines

A vertical lifeline is a rope or cable that is suspended from an overhead anchorage point, as shown in Figure 1.7. Similar in function to the ladder safety system described above, it can be used in a free-hanging configuration, against a structure, on a ladder, with a suspended scaffold, or in any number of ways. A vertical lifeline is not just a device, but is a system, comprised not just of the vertical line itself but also a compatible fall arrest rope grab, connectors, lanyard, and harness.

Figure 1.7 Vertical lifeline system. Credit: Reliance Industries, LLC.

With the worker connected to the vertical lifeline by means of a rope grab, as shown, the rope grab travels up and down the vertical lifeline as the worker moves in a controlled manner. In the event of a sudden load, such as a fall, the rope grab locks up and catches the fall.