FALL PROTECTION PROGRAM

University of Wisconsin-Platteville
Reviewed 4/2016

A fall hazard is anything in the workplace that could cause an unintended loss of balance, or bodily
support, and result in a fall. The purpose of this fall protection policy is to establish guidelines to protect
all University of Wisconsin-Platteville employees engaged in outdoor or indoor work activities that
expose them to potential falls from elevations.

This policy has been developed to aid in the prevention of falls of 4 feet or more. This goal will be
accomplished through effective education, engineering and administrative controls, use of fall
protection systems, and enforcement of the policy. This fall protection policy will be continually
improved upon to prevent falls from occurring.

This policy applies to all UW-Platteville employees at all UW-Platteville locations or at work locations
conducted by UW-Platteville employees in the field; wherever employees are engaged in work activities
that expose them to falls of 4 feet or more.

AUTHORITY
The Department of Safety and Professional Services (DSPS) requires state agencies to comply with OSHA
regulations on walking-working surfaces, personal protective equipment, and fall protection. These
regulations include 29 CFR 1926.501 for construction related activities, 29 CFR 1910.23 and other parts
of 1910 Subpart D, 1910.132 (a) and Section 5 (a) of the Occupational Safety and Health Act for general
maintenance activities (the OSHA General Duty Clause).

OSHA requires that all floors, platforms, runways, and wall and window openings where there is a drop
of 4 feet or more need to have some type of guarding. In these cases, usually a standard guardrail
system is adequate. This four-foot requirement also applies to equipment that raises workers above the
ground such as order pickers, scissors lifts, scaffolding, and powered platforms.

POLICY
There are separated fall protection requirements for general maintenance work activities versus
construction activities (as defined in OSHA 1926.501). At UWP, the vast majority of work by UWP
employees falls under maintenance fall protection requirements. However, some construction work
may be performed by UWP employees.

Construction activities are those that involved major renovations, remodeling, replacement of complete
systems, significant altering of structures, building, etc. “Maintenance “means keeping equipment or a
structure in proper condition through routine, scheduled, or anticipated measures without having to
significantly alter the structure or equipment in the process.

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Each employee on a walking-working surface (horizontal and vertical surface) with an unprotected side
or edge which is 4 feet or more above a lower level shall be protected from falling by the
implementation of proper fall protection measures such as guardrail systems, personal fall arrest
systems, or other approved method. Employees are allowed to work only on those surfaces that have
the requisite strength and structural integrity to support them and their workload. Surfaces not meeting
this requirement shall not be walked or worked on without proper means of protection.

Employees will not be required nor allowed to perform any duties which require the employee to get
closer than 6 feet to an unprotected edge, platform or walkway of any building or other work surface,
nor to utilize elevated equipment that present a potential to fall greater than 4 feet or more, unless the
employee is properly secure from falling by guard rails, personal fall protection equipment, or other
acceptable means.

Employees are also restricted from stepping across any floor opening greater than 12 inches when that
opening is elevated 4 feet or more above a walking/working surface unless proper fall protection
methods are implemented.

Note that normal working and walking surfaces at UWP including ladders (fixed or mobile scaffolding,
stairs, or stands) must comply with OSHA 1910 Subpart D standards 1910.21-1910.30.

GENERAL MAINTENANCE FALL PROTECTION REQUIREMENTS

Regular and normal working and walking surfaces must comply with OSHA 1910.23 (appendix A) which,
among other requirements, mandates that every open-sided floor or platform 4 feet or more above
adjacent floor or ground level to be guarded by a standard railing (or the equivalent) on all open sides
except where there is entrance to a ramp, stairway, or fixed ladder. Toe boards may also be required if
there is potential for individuals to be struck below or other hazards created by objects falling.

However, in those circumstances where UW-Platteville employees are not in a regular and normal work
area such as on a roof or potentially unprotected edge (i.e. does not have standard railing), additional
fall protection measures may be necessary. Therefore, when an employee is required to be exposed to
an unprotected edge (i.e. come within 6 feet of the unprotected edge) or other location that presents a
potential to free fall greater than 4 feet, proper fall protection measures must be implemented. These
measures may include, but are not limited to, engineering or administrative controls to eliminate the
hazard, guard rails that meet OSHA requirements (either permanent or temporary), personal fall
protection equipment, or other approved measures.

The following areas/situations are examples of situations that require a proper means of fall protection
whenever there is potential to fall more than 4 feet:
1. Each employee on a walking/working surface with an unprotected side or edge which is 4 feet or
more above a lower level shall be protected from falling by the use of guardrail systems, safety
net systems, personal fall arrest systems (fall protection equipment), or other approved
method. Performing maintenance work within 6 feet of any unprotected sides and edges
requires fall protection means to be implemented. Again, “ordinary” working/walking surfaces
are to have permanent railings or other protections.

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 2. Roofs: roof access at UW-Platteville is closely regulated. Access doors to roofs are locked in all
buildings. Only authorized individuals are allowed on roofs. Unauthorized entry to roofs is a
violation of Wisconsin Administrative Code UWS 18.06(9). For maintenance work on low sloped
roofs (4:12 pitch or less)-individuals must stay 6 feet away from the edge of the roof at all times
or be required to implement proper fall protection measures. Work on high sloped roofs
requires appropriate fall protection at all times
3. All unprotected exterior and interior equipment platforms, catwalks, antennas/towers, etc.
4. All unprotected mezzanine and balcony edges.
5. All unprotected open excavations or pits.
6. All tasks requiring use of the aerial man lifts (aerial boom lift, snorkel lift, articulating lift, aerial
platforms, etc.
7. All tasks requiring leaning, stepping, or climbing outside of the protected area. For example
climbing over the railing on a mezzanine, roof, catwalk, or scissors lift railings.
8. Unprotected scaffolding erections- 6 feet in height or greater.
9. Any other unprotected work- feet in height or greater.

ROOF INSPECTIONS
Roof Inspections may be carried out without full fall protection provided the SOP and JSA for UW-
Platteville Roof Inspections are followed.

FALL PROTECTION SYSTEMS AND GUIDANCE

The following provides a summary of potential types of fall protection systems that could be used to
comply with fall protection requirement for both maintenance and construction related activities. The
information below is not intended to provide full implementation guidance for specific jobs, rather an
overview of potential systems available. Fall protection system implementation requirements that are
to be followed at UWP are found in OSHA 1926.502 (Appendix C).

Appropriate fall protection will be determined by the task (job) to be performed and location of the
work. The type of work, location, and type of fall protection system utilized shall be documented and
filed in the affected department for future reference.

Engineering/ Administrative Controls

This should always be the first option for selection whenever possible (i.e., light bulb changing: use
telescoping arm, changing valve, relocate at ground level, etc.) or utilizing a compliant contractor for
jobs beyond our expertise.

Guardrails
All guardrail systems will comply with the current Department of Safety and Professional Services (DSPS)
OSHA/COMM standards. Permanent guardrails are a recommended means of fall protection whenever
feasible. Normal working and walking surfaces must comply with OSHA 1910.23 which requires every
open-sided floor or platform 4 feet or more above adjacent floor or ground level to be guarded by a
standard railing (or the equivalent) on all open sides except where there is entrance to a ramp, stairway,
or fixed ladder. Toe boards may also be required if there is potential for individuals to be struck below
or other hazards created by objects falling.
A guardrail is made up of the following elements:

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 • Top rail
o Must be 39-45” above the walking/working surface.
• Mid rail
o Must be located halfway between the top edge of the top rail and the walking/working
surface.
• Posts
o Must be placed no more than 8 feet apart. End joints must have no overhang that could
snag clothing or cause employees to trip.
• Toeboard
o Must be at least 3.5” in vertical height from their top edge to the heel of the
walking/working surface.

Personal Fall Arrest Protection Systems

Personal fall protection systems means a personal protection equipment system used to arrest an
employee in a fall from a working level. It consists of an anchorage, connectors, full body harness and
may include a lanyard, deceleration device, lifeline or suitable combination of these. The use of a body
belt for fall arrest is prohibited.

All employees on any project that are required to wear a personal fall arrest or positioning/ restraint
system will follow these requirements:
1. All individuals required to wear fall protection equipment must complete training on proper
use and maintenance.
2. A full body harness will be used at all times
3. Only shock absorbing lanyards or retractable lanyards are to be used alone or in conjunction
with a rope grab system so as to keep impact forces at a minimum on the body.
4. Only nylon rope with rope grab or nylon straps with locking snap hooks are to be used for
positioning restraints.
5. All lanyards will have double action, self-locking snap hooks rated to 5,000 pounds.
6. Connectors are engineered for specific purposes. Make sure you are using the correct
connector in the correct manor.
7. Fixed anchor points are determined and labeled where possible and are located on maps
8. The employee will inspect all personal fall arrest equipment before each use. Any
deteriorated, bent, damaged, impacted, and/or harness showing excessive wear will be
given to a Competent Person who will decide if the equipment needs to be taken out of
commission.
9. The maximum free fall distance is not to exceed 6 feet.
10. The employee will report all instances of falls or other stresses that occur during use to
his/her supervisor so the equipment can be inspected before the next use and/or taken out
of service.
11. Inclement weather, including but not limited to snow, ice, high winds or rain, pose even
greater hazards during work where a potential for a fall exists, i.e. roof work. Personnel
shall take additional precautions during such weather. Personnel should contact their
supervisor to review additional precautions before beginning affected work. Work should
not be conducted on roofs during lightning/ thunderstorms.

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Evaluate the total fall distance before utilizing fall protection systems
The following factors can affect total fall distance:
1. Length of connecting means (i.e., lanyard length, use of carabineers, snaphooks, etc.)
2. Position and height of anchorage relative to work platform/ area (always keep above the head
whenever possible)
3. Position of attachment and D-ring slide on the full body harness
4. Deployment of shock absorber (max. 42”)
5. Movement in the lifeline.
6. Initial position of worker before free fall occurs
7. Stretch and tightening of harness during a fall can add 12” or more to the fall distance

Calculating Total Fall Distance

T. Fall Distance = ft (lanyard) + ft (shock absorber) + ht of person +3 ft
The total fall distance is the total length of shock absorbing lanyard + deceleration distance + height of
the person + 3 foot safety factor above the ground, equipment, etc., at the end of the fall from the fall
arrest point.

A personal fall arrest system consists of the following components:

• Full body harness- A full body harness consists of nylon and /or polyester straps that encompass
the chest, chest and waist or full body. In the event of a fall, a full body harness distributes the
fall arrest force over the pelvis, thighs, waist and shoulders. The attachment point must be in
the center of the back or at the shoulder level of the wearer.
• Lanyard- A lanyard connects the body harness to the anchorage point. The lanyard should able
attached to a D-ring on the body harness between the shoulder blades and above the employee.
Lanyards may be equipped with deceleration or shock absorbing devices that limit up to 80% of
the arresting force placed on the wearer during a fall. The lanyard must be of sufficient strength
to withstand twice the impact energy of a person free falling 6 feet or the free-fall distance
permitted by the system if the free-fall distance is less than 6 feet.
• Lifeline-A lifeline consists of a flexible line that is connected to the anchorage point at one or
both ends which serves as means to connect other components of the personal fall arrest
system to the anchorage. Self-retracting lifelines provide mobility as well as worker protection.
The line retracts as the worker moves toward the unit and pulls out as the worker moves away
from the unit. IF the worker slips or falls, the sudden jerk on the cable activates the breaking
mechanism and the worker is brought to stop within 2 feet.

Rope Grab
Is a deceleration device which travels on a lifeline and automatically, by friction, engages the lifeline and
locks so as to arrest the fall of an employee. A rope grab usually employs the principle of inertia-locking,
cam/level locking, or both.

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Other Systems
In some situations, the installation and use of guardrails, safety nets or personal arrest systems may not
be feasible or creates a greater hazard. In these cases, additional and/or other methods and systems
can be used to provide fall protection (1926.501).
• Warning Line System: A warning line system uses ropes, wires or chains to keep employees out
of areas where there are fall hazards. Warning line systems are often used on low-sloping roofs
and around dangerous mechanical equipment.
• Each line shall be flagged or otherwise clearly marked at not more than 6 foot intervals
with high-visibility material
• Each line shall be rigged and supported such that its lowest point (including sag) is not
less than 39” from the walking surface and its highest point not more than 45” from
walking surface.
• After being erected, with the rope, wire or chain attached, stanchions shall be capable
of resisting, without tipping over, a force of at least 16 lbs applied horizontally against
the stanchion, 30” above the walking surface, perpendicular to the warning line, and in
the direction of the roof.
• The rope, wire or chain shall have a minimum tensile strength of 500 lbs.
• Each line shall be attached at each stanchion such that pulling on one section of the line
between stanchions will not result in slack being taken up in adjacent section before the
stanchion tips over.
• Controlled Access Zones: controlled access zones allow only employees working directly in an
area to enter the zone. The CAZ must be clearly indicated by a line made of rope, wire or some
other means that restricts access to the work area. When control lines are used to restrict
access to an unprotected or leading edge, the line must extend along the entire length of the
unprotected or leading edge. The control line must be connected on each side to a guardrail or
wall.
• Safety Monitoring System: A safety monitoring system uses competent employees to actively
observe work areas and warn other workers of any possible fall and other safety hazards. Safety
monitors must not be assigned other job duties which could distract their attention away from
observing the work of other employees.

INSPECTION OF FALL PROTECTION SYSTEMS

All fall protection equipment and systems must be inspected prior to each use on a regular and routine
basis following manufacturer’s recommendations to ensure proper working condition. A competent
person must inspect the equipment on an annual basis. This annual inspection must be documented. All
users of the equipment are to be trained in proper inspection techniques. If there is evidence of
excessive equipment wear or deterioration or if mechanical malfunction is detected, the item is to be
removed from service.

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Examples of equipment that is to be inspected include full body harnesses, lanyards, snap hooks, anchor
points, guard rails, any adaptors, etc.

PRE-WORK CHECK
Prior to beginning work in any area or on any device where fall hazards exist, a pre-work check must be
completed that includes the following items:
Stairs
• All required covers or guardrails must be in place
• All handrails or guardrails are in place on stairways
• All treads and risers on stairs are in good repair
• Non-slip surfaces are in place on stairs
• All stairs meet OSHA and ANSI specifications for design and safety
Ladders
• Gripping safety feet in place and secure on ladders
• All parts and fittings on ladders are secure
• Non-slip surfaces are in place on ladder rungs
• When setting ladder up, footing of ladder is secure on a firm, level, and non-skid surface and top
of ladder is placed against a solid, stationary object.
• All ladders meet OSHA specifications(1910.25, 1910.26 for portable ladders and 1910.27 for
fixed ladders) for design and safety
Loading Dock Areas
• Dock blocks are up and in place when dock is not in immediate use
• Only trained loaders and unloaders perform loading and unloading duties in that area
• Dock door is kept closed when a truck is not backed against it
Platforms
• Guardrails are in place and securely attached
• Toe boards are in place and secure
• All platforms meet OSHA specification for design and safety
Floor and Wall Openings
• All floor and wall openings are safely covered or blocked from access
• If not safely covered and blocked from access, the opening has someone assigned for constant
attendance to it

WORK PRACTICES
If any one of the conditions described in Pre-Work Check is not met for the area or piece of equipment
posing a potential fall hazard, then employees may not perform that work until the condition is met. If
the condition cannot be remedied immediately, your supervisor must be notified of the problem.

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If the situation calls for use of fall protection devices, such as harness, or positioning or restraining
devices then the employee must don such protective equipment before beginning the work and use as
intended throughout the duration of the work.
To prevent slipping, tripping, and falling, all places of employment, passageways, storerooms, and
service rooms must be kept clean and orderly and in a sanitary condition. The floor of every workroom
will be maintained in a clean and, so far as possible, dry condition. Where wet processes are used,
drainage will be maintained and false floors, platforms, mats, or other dry standing places are provided
where practicable.
To facilitate cleaning, every floor, working place, and passageway will be kept free from protruding nails,
splinters, holes or loose boards.

STORAGE AND MAINTENANCE OF PERSONAL FALL PROTECTION EQUIPMENT

Below are a few guidelines to follow regarding storage and maintenance of personal fall protection
equipment
1. Never store the personal fall arrest equipment in the bottom of a tool box, on the ground, or
outside exposed to the elements.
2. Hang equipment in a cool dry location in a manner that retains its shape.
3. Always follow manufacturer recommendations for inspection.
4. Clean with a mild, nonabrasive soap and hang to dry.
5. Never store equipment near excessive heat, chemicals, moisture, or sunlight.
6. Never store in an area with exposures to fumes or corrosive elements
7. Avoid dirt and build-up on equipment.
8. Never use this equipment for any purpose other than personal fall arrest.
9. Once exposed to a fall, remove equipment from service immediately.
10. Ensure equipment is inspected and replaced as required. Follow manufacturer’s instructions.
11. Document annual inspections by a competent person.

TRAINING
Employees exposed to potential fall greater than 4 feet must receive fall protection training. Training
will be coordinated by the Office of Safety and Risk Management and Supervisors.

The training policy shall enable each employee to recognize the hazards of falling and the procedures to
be followed in order to minimize these hazards. The training will outline the procedures to be followed
in order to minimize these hazards. The training will be conducted by a competent person qualified in
the following areas:

1. The nature of fall hazards in the work area

2. The correct procedures for erecting, maintaining, disassembling, and inspecting the fall
protection systems to be used;
3. The use, inspection, operation, and maintenance of guardrail systems, personal fall arrest
systems, safety net systems, warning line systems, safety monitoring systems, controlled access
zones, and other protection to be used;
4. The role of each employee in the safety monitoring systems when this system is used;
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 5. The limitations on the use of mechanical equipment during the performance of roofing work on
low-sloped roofs;
6. the correct procedures for the handling and storage of equipment and materials and the
erection of overhead protection;
7. the role of employees in fall protection plans; and
8. the applicable OSHA standards

RESCUE PROCEDURES
At the beginning of any work activity where fall protection is required, rescue plans must be identified
and discussed with all affected employees in case of a fall. The maintenance supervisor will develop the
rescue plans. A method of communication must be established which provides a means for the worker
to call for assistance as needed (i.e. radio communications, co-worker, phone, etc.). NOTE: If utilizing a
Fall Restraint System a rescue plan is not needed because the restraint system prevents a worker from
being exposed to any fall.

Rescue Methods/Operations of Fallen Personnel

In the event that a fall arrest occurs, individuals will initiate self-recue or immediate rescue will be
initiated by on-site personnel with the use of an articulating man lift, ladders, or other necessary means.
Whenever needed, 911 will be called and the Platteville Fire Department will be summoned to perform
emergency rescue.

Communications Issues
In the event of a fall, the following people will be notified as soon as possible:
1. Rescue personnel (i.e. maintenance personnel and Fire Department (911)
2. Maintenance supervisor and the Director of Facilities
3. Risk Management Officer

FALL INVESTIGATION
All fall investigations will be conducted by the employee’s supervisor, Risk Management Officer, and
others deemed necessary. Work will not proceed until proper controls are implemented to ensure the
job is safe to proceed.
The following documentation will be completed as part of the fall investigation:
1. Interviews with affected staff and witnesses
2. Employee injury/accident report
3. Supervisory injury/accident report
4. Safety coordinator review
The information will be tracked and recommendations submitted to prevent further incidents and
improve the policy.

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CONTRACTORS
All outside contractors working for UW-Platteville are required to follow the OSHA requirements for fall
protection and worker safety while performing work for UW-Platteville. UW-Platteville will provide
contractors with applicable procedure information and directives as needed.

Contractors are responsible for complying with all OSHA fall protections standards and ensuring their
employees follow the requirements.

POLICY REVIEW
This fall protection policy will be evaluated periodically to determine effectiveness. The following criteria
will be used to evaluate its performance;
1. Accident reports, number of accidents.
2. Management/staff compliance with policy components.
3. Periodic on-site audits.
4. Staff feedback, interviews
5. Otter such as schedule reviews

Necessary changes will be made to the policy with corresponding training as needed for affected
employees.

Record of Program Updates

• 4/2016
• 10/2010
• 9/26/11

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