Chapter 9: Fall Protection Program (Section II)

This document provides an overview of established fall protection guidelines.


1.0  Purpose

2.0  Scope 

3.0  Definitions 

4.0  Program/Policy Statement

5.0  Related Documents

6.0  Scheduled Review 



The purpose of this fall protection program is to establish guidelines to protect all staff, faculty and students engaged in outdoor or indoor work activities that expose them to potential falls from elevations of four feet or greater. 


2.0  SCOPE

The scope of this program includes all staff, faculty and students who are exposed to conditions that present a fall hazard of four feet or more to another level.



Authorized Person - A person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or job site.

Competent Person: A person capable of identifying existing and predictable hazards in the surroundings or working conditions, which are hazardous or dangerous to employees. A person who has the authorization to take prompt corrective action to eliminate such hazards.

Controlled Access Zone - An area in which certain work may take place without the use of a guardrail system, or personal fall arrest system and access to that specified zone is controlled. 

Fall Hazard - Fall hazards from elevations include, but are not limited to, unprotected sides and edges of roofs, excavations, skylights, floor holes, wall openings, and all other walking or working surfaces where personnel can possibly fall 4 feet or more to a lower level

Free Fall - The act of falling before a personal fall arrest system begins to apply force to arrest the fall.  

Free Fall Distance - The vertical displacement of the fall arrest attachment point on the employee’s body harness between the onset of the fall and just before the system begins to apply force to arrest the fall. Free fall distance must not exceed 6 feet. 

Full Body Harness - Straps that are secured about the employee in a manner that will distribute fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders, with means for attaching it to other components of a personal fall-arrest system.  

Guardrail System - A barrier erected to prevent employees from falling to lower levels. A guardrail system includes a toe board, midrail and toprail located at a height 39”- 42” from the top of the work surface and is able to withstand 200 lbs of force applied in any direction. 

Lanyard - A strap that has double action, self-locking snaphook connectors at each end for connecting to body harnesses and anchorage points. All lanyards must include an integrated deceleration device.  

Leading Edge - The edge of a floor, roof, or other walking/ working surface, which changes location as additional floor, roof, etc., is placed or constructed. A leading edge is considered an unprotected side or edge when not under active construction. 

Lifeline - A component consisting of a flexible line for connection to an anchorage at one end to hang vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline). This serves as a means for connecting other components of a personal fall arrest system and/or positioning system to the anchorage. Lifeline systems must be engineered to have appropriate anchorages, strength of line designed to hold the number of individuals connected to it, line strength to aid in the arrest of a fall, and durability to hold a fallen employee(s) suspended until a rescue can occur.  

Personal Fall Arrest System (PFAS) - A system used to arrest (catch) an employee in a fall from a working level. It consists of an approved anchorage location, connectors, a body harness, and may include a lanyard, deceleration device, lifeline, or any combination of the before –mentioned items. 

Positioning Device or Restraint System - A system that prevents falls by supporting the employee in a working position. This system supports the employees, therefore eliminating the chance for a fall to begin. This system will include an approved anchorage location, connector, full body harness, rope lifeline and rope grab.

Total Fall Distance - The maximum vertical change in distance from the bottom of an individual’s feet at the onset of a fall, to the position of the feet after the fall is arrested. This includes the free fall distance and the deceleration distance.

Unprotected Sides and Edges - Any side or edge of a walking or working surface where there is no guardrail at least 36”-42” high.

Walking/Working Surface - Any surface, whether horizontal or vertical, on which an employee walks or works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel. Does not include ladders, vehicles, or trailers on which employees must be located to perform their work duties. 

Warning Line System - A barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge. 


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 methods. 

A. Fall Protection Locations:

Fall protection is required whenever the potential to fall 4 feet or more exists. The following locations are examples of where fall protection is required, however, this is not an exhaustive list of locations:

  1. All sloped roof locations during roof repair/maintenance/inspection (4:12 pitch or more).
  2. All exterior and interior equipment platforms, catwalks, antennas/towers, etc.
  3. All exterior and interior fixed ladders 20 feet or greater.
  4. All mezzanine and balcony edges.
  5. All open excavations, tanks or pits.
  6. If applicable and according to the manufacturer’s manual and instruction, tasks requiring use of the articulating, scissor platform or single manlifts. 
  7. All tasks requiring employees to lean outside the vertical rails of ladders or beyond guardrails (e.g., painting, stairwell light bulb replacement, etc.).
  8. Gymnasium and theatre mezzanine/theatre/catwalk areas- whenever an employee must step outside the guardrails of the catwalk, additional fall protection (e.g., 6- foot lanyard to full body harness, self-retracting lanyard or rope grab system) shall be used.
  9. Scaffolding erection - 10 feet in height or greater.
  10. Floor and deck openings
  11. Skylights
  12. Any other locations where a fall hazard is identified at 4 feet or greater.


B. Fall Protection Systems and Implementation

1. Engineering Controls

Engineering Controls will be used whenever possible to permanently eliminate or significantly reduce the risk of fall-related injuries. Examples of engineering controls include: 

  1. Relocating the object or process to a safer location (e.g., light bulb changing= the telescoping arm; changing valve=relocate at ground level, etc.)
  2. Permanent guardrails, toe boards, covers, and other rails or barriers that prevent falls
  3. Ladder cages
  4. Engineering and installing catwalks with proper guardrails
  5. Properly guarding hazardous equipment

    2. Fall Prevention Systems

When permanent engineering controls cannot be applied to reduce the risk, a fall prevention system will be utilized.

1. Guardrail – Passive Fall Protection System

Guardrails consist of a toeboard, midrail and top rail. 

  • The top edge height of the top rails must be between 39 and 45 inches above the walking/working level
  • Midrails must be midway between the top edge of the guardrail system and the walking/working level
  • Toeboards must be at the walking surface and will be at least 4” tall, with no more than 1/4“gap at the bottom
  • Must be able to withstand 200 pounds of force applied in any direction
  • Must be on all open sided floors
  • Around all open excavations or pits
  • On leading edges of roofs or mezzanines 

A positioning or restraint system, when used as a form of a fall prevention, will be designed to prevent the employee from going beyond the edge of the surface that they are working upon. The positioning system will incorporate a harness worn by the exposed employee. The harness will be attached to a rope with a rope grab or lanyard which will be attached to an anchor of suitable strength (min. 5,000 lbs.)

2. Positioning/Restraint Device System- Active Fall Protection System

  • Anchor point 
  • Full body harness
  • Restraint line or lanyard
  • Rope grab to restraint line
  • Connectors (self-locking snap hooks)

3. Warning Line System

Warning line systems are to be used to warn workers they are nearing the unprotected edge of the roof. Warning lines will consist of the following:

  • Will be erected 6 feet from the unprotected edge of the roof. 
  • Be constructed of stationary posts made of wood or metal at a height to position the warning line between 36” and 42”.
  • Wire, nylon rope or chain with a minimum tensile strength of 500 pounds and “Caution” tape will be strung from post to post and must be able to withstand 16 pounds of force.
  • The warning line will guard the perimeter of the roof where work is being performed. 

If an employee must access an area within 6 feet of the roof’s edge, for reasons other than exiting the roof via a ladder or fixed industrial ladder, the employee must don a full body harness and attach a fall restraint lanyard to an anchor point to prevent reaching the edge of the roof. 

3. Personal Fall Arrest Systems

When positioning or restraint systems cannot be used to reduce the risk, a personal fall arrest system will be utilized to catch a person if a fall occurs. 

  1. Personal fall arrest system:
    • Anchor point (rated at 5,000 pounds per person)
    • Full body harness
    • Restraint line or lanyard
    • Retractable lanyard
    • Rope grabs
    • Connectors (self-locking snap hooks)

C.  Administration Controls

When there are no feasible means to institute an engineering control, and restraint and positioning systems are too dangerous for implementation, the University reserves the right to utilize a trained contractor with the required expertise. 

All roof access on campus property are under State Statute: UWS 18.06 Conduct on University Lands. 

(9) Climbing; walking on roof. No person may climb into, out of or on university building or maintenance facilities or walk upon the roof of a university building; except when emergency access to a fire escape is necessary, or for required maintenance, or when authorized by the chief administrative officer. 


D. Requirements for Use of Personal Fall Arrest Systems (PFAS)

All employees on any project that are required to wear a personal fall arrest or positioning/restraint system will follow these requirements:

  1. Consists of anchorage, connectors, body harness, deceleration device, lifeline or suitable combinations.
  2. Personal fall arrest systems, when stopping a fall, shall be rigged so an employee can neither fall 6 feet or make contact with a lower level.
  3. Must bring an employee to a complete stop and limit the maximum deceleration distance traveled to three and a half feet. 
  4. Must be strong enough to withstand twice the potential impact energy of an employee free falling six feet or the free fall distance permitted by the system, whichever is less. 
  5. Must be inspected prior to each use for wear, damage and other deterioration. 
  6. If a PFAS component is found to be defective or subjected to impact, it must be removed from service immediately. 
    1. PFAS subjected to impact must be inspected by a competent person prior to reuse.
  7. PFAS shall not be installed to a guardrail system. 
  8. Body harnesses and components shall not be used to hoist materials or equipment. 
  9. Equipment and procedures to ensure a prompt rescue in the event of a fall shall be in place.

All components of a fall arrest system shall meet the specifications of the OSHA fall protection standard and shall be used in accordance with the manufacturer’s instructions:

  1. The use of non-locking snap hooks is prohibited
  2. D-rings and locking snap hooks shall:
    1. Have a minimum strength of 5,000lbb.  
    2. Be proof-tested to a minimum tensile load of 3,600lbs without cracking, breaking, or suffering permanent deformation.
  3. Lifelines must be:
    1. Designed, installed, and used under the supervision of a competent person
    2. Protected against cuts and abrasions.
    3. Equipped with horizontal lifeline connection devices capable of locking both directions on the lifeline when used on suspended scaffolds or similar work platforms that have horizontal lifelines that may become vertical lifelines.
    4. When vertical lifelines are used, each employee shall be attached to separate lifelines.
  4. Self-retracting lifelines and lanyards must:
    1. Automatically limit free fall distance to two feet or less and shall be capable of sustaining a minimum tensile load of 3,000lbs applied to the device with the lifeline or lanyard in the fully extended position. 
    2. If self-retracting lifelines and lanyards do not limit free fall distance to two feet or less, rip-stitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000lbs applied in the fully extended position. 
  5. Anchors must support at least 5,000lbs per person attached and must be:
    1. Designed, installed, and used under the supervision of a competent person
    2. Capable of supporting at least twice the weight expected to be imposed on it.
    3. Independent of any anchorage used to support or suspend platforms.

E. Safety Monitoring Systems

Where it is not feasible or would create a greater hazard to use a conventional fall protection system, a safety monitor may be applicable. 

  1. Safety monitors shall be:
    • Competent in the recognition of fall hazards
    • Capable of warning workers of fall hazard dangers
    • On the same walking/working surfaces as the employees, and able to see them
    • Close enough to work operations to communicate orally with employees
    • Free from other job duties that might distract them from the monitoring function
  2. Mechanical equipment shall not be used or stored in areas where safety-monitoring systems are being used on low-slope roofs. 
  3. Employees not covered by a fall protection plan, or not performing roofing work on low-slope roofs, shall not be permitted in areas where employees are protected by a safety monitor system. 
  4. Employees protected by a safety monitoring system must promptly obey directions from the safety monitor.

F. Warning Line System

A warning line system shall consist of vertical supporting braces and ropes, wires or chains and shall be erected around all sides of low-sloped roof work areas. In addition:

  1. Lines shall be flagged at no more than six-foot intervals with high visibility material. 
  2. The lowest point of the line (including sag) shall be between 34” and 39” from the working/walking surface. 
    1. Supporting braces shall be capable of resisting at least sixteen pounds of force applied horizontally against the stanchion, 30” above the walking/working surface. 
    2. Ropes, wires, or chains must have a minimum tensile strength of 500 pounds. 
    3. Lines must be fastened so that pulling on the line between supporting braces does not cause slack being taken up in adjacent sections. 
  3. Warning lines must be erected at least six feet from the edge, except in areas where mechanical equipment is in use. 
    1. When mechanical equipment is in use, warning line systems shall be re-erected at minimum 6 feet from the parallel edge to the direction of the mechanical equipment, and at least 10 feet from the roof’s edge which is perpendicular to the direction of the mechanical equipment operation. 
    2. Mechanical equipment shall be used or stored only in areas where employees are protected by a warning line system, guardrail, or PFAS. 
  4. Points of access, material handling areas, storage areas, and hoisting areas shall be connected to the work area by an access path formed by two warning lines. 
    1. When the path to a point of access is not in use, it must be barricaded by means of a rope, wire, or chain and equivalent to the strength and height of the warning line. 
  5. Employees are not permitted in the area between the roof edge and the warning line unless the employee is performing work in that area and should be protected by other means of fall protection. 


G. Controlled Access Zone (CAZ)

When used to control access to leading edge work, the CAZ shall be distinguished by a control line, or other means. In addition:

  1. The control line shall be flagged at no more than 6-foot intervals with high visibility material. 
    1. The line shall have a minimum breaking strength of 200 pounds.
  2. CAZ must be established between 6 and 25 feet from the unprotected edge or leading edge, except when constructing pre-cast concrete members. In this case, the control line must not be more than 60 feet from the edge, or half the length of the member, whichever is less. 
  3. The control line must 
  1. Run the entire length of the unprotected or leading edge. 
  2. Run approximately parallel to the edge. 
  3. Connect to a wall or a guardrail. 

H. Inspection of Fall Protection Systems

The following criteria will be utilized to maintain all equipment in good working condition:

Full Body Harnesses

  1. Inspect before each use
    1. Closely examine all the nylon webbing to ensure there are no burn marks, which could weaken the material.
    2. Verify there are no torn, frayed or broken fibers, pulled stitches, or frayed edges anywhere on the harness. 
    3. Examine the D-ring for excessive wear, pits, deterioration, distortions, or cracks.
    4. Verify that buckles are not deformed, cracked, and operate correctly. 
    5. Check to see that each grommet (if present) is secure and not deformed from abuse or a fall. 
    6. The harness should never have additional punched holes. 
    7. All rivets should be tight and not deformed. 
    8. Check tongue/straps for excessive wear from repeated buckling. 
  2. A Competent Person will complete an annual inspection of all harnesses and documentation will be maintained. 
  3. Storage will consist of hanging in an enclosed cabinet, to protect from damage. 
  4. All harnesses that are involved in a fall will be destroyed without exception by the designated Competent Person.             

Lanyards/Shock Absorbing Lanyards

  1. Inspect before each use: 
    1. Check lanyard material for cuts, burns, abrasions, kinks, knots, broken stitches and excessive wear. 
    2. Inspect the snaphooks and/or carabineers for excessive wear, distortions in the hook, locks, and eye and proper lock operation. Visually inspect the connecting collar of the snaphook for a red band. If a red band is visible, the snaphook has been subject to a fall and needs to be taken out of service. 
    3. Ensure that all locking mechanisms seat and lock properly.
    4. Once locked, locking mechanism should prevent the hook from opening.
    5. Visually inspect shock absorber for any signs of damage, paying close attention to where the shock absorber attaches to the lanyard. If the shock absorber shows signs of torn stitching or extended webbing, the lanyard may have been subject to a fall and needs to be taken out of service. 
    6. Verify that points where the lanyard attaches to the snaphooks are free of defects. 
  2. A Competent Person will complete an annual inspection of all lanyards and documentation will be maintained. 
  3. Storage will consist of hanging in an enclosed cabinet, to protect from damage. 
  4. All harnesses that are involved in a fall will be destroyed without exception by the designated Competent Person.  


  1. Inspect before each use: 
    1. Visually inspect the connecting collar of the snaphook for a red band. If a red band is visible, the snaphook had been subject to a fall and needs to be taken out of service.
    2. Inspect snaphook for any hook and eye distortions. 
    3. Verify there are no cracks or pitted surfaces. 
    4. The keeper latch should not be bent, distorted, or obstructed. 
    5. Verify that the keeper latch seats into the nose without binding. 
    6. Verify that the keeper spring securely closes the keeper latch. 
    7. Test the locking mechanism to verify that the keeper latch locks properly. 
  2. A Competent Person will complete an annual inspection of all snaphooks, and documentation will be maintained. 
  3. All snaphooks involved in a fall will be destroyed.        

Self-Retracting Lanyards/Lines

  1. Inspect before each use:
    1. Visually inspect to ensure there is no physical damage to the body.
    2. Visually inspect the connecting point for red collar to be visible, if red collar is visible, the lanyard has been subjected to a fall and needs to be taken out of service.
    3. Make sure all nuts and rivets are tight. 
    4. Make sure the entire length of the nylon strap/wire rope is free from any cuts, burns, abrasions, kinks, knots, broken stitches/strands, excessive wear and retracts freely. 
    5. Test the unit by pulling sharply on the lanyard/lifeline to verify that the locking mechanism is operating correctly. 
    6. If the manufacturer requires, make certain the retractable lanyard is returned to the manufacturer for scheduled annual inspections. 
  2. A Competent Person will conduct inspections annually of all self-retracting lanyards/lifelines and documentation will be maintained.
  3. All service shall be according to the manufacturer specifications. 
  4. Self-retracting lifelines will be sent to manufacturer after a fall. 

Tie-Off Adapters/Anchorages

  1. Inspect for integrity and attachment to solid surface. 
  2. A Competent Person will complete an annual inspection of all tie-offs and anchorages and documentation will be maintained. 
  3. All tie-offs and anchorages will be removed from service after a fall. 

Horizontal Lifelines

  1. Inspect before each use for structural integrity of line and anchors.
  2. A Competent Person will complete an annual inspection. 


  1. Temporary Systems- Daily visual inspection will be completed by a Competent Person with future frequency of inspection defined based on conditions/controls present. 
  2. Permanent Systems- Annual visual inspection will be completed by a Competent Person with future frequency of inspection defined based on conditions/controls present.


I. Storage and Maintenance of Fall Protection Equipment

  1. Never leave the personal fall arrest equipment in the bottom of a toolbox, on the ground, or outdoors exposed to the elements (e.g., sun, rain, snow, etc.). 
  2. Store equipment by hanging equipment by fastening hardware in a cool, dry location in a manner that retains its shape. 
  3. Always follow manufacturer recommendations and above listed guidelines for inspections. 
  4. Never force dry or use strong detergents in cleaning. 
  5. Never return wet equipment to the storage area. Always air-dry equipment before storing. 
  6. Never store equipment near excessive heat, chemicals, moisture, or sunlight.
  7. Never store in an area with exposures to fumes or corrosive elements. 
  8. Avoid dirt or other types of build-up on equipment. 
  9. Never use this equipment for any purpose other than personal fall arrest and/or positioning.
  10. Once exposed to a fall, remove equipment from service immediately and contact the Competent Person advising them of the fall. 


J.    Training Requirements

The ARS Superintendent or designee shall assure that each employee is trained, as necessary, by a Competent Person qualified in the following areas: 

  1. The fall hazards in the work area.
  2. The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection system to be used.
  3. The use and operation of guardrail system, personal fall arrest systems, controlled access zones, and other protection to be used.
  4. The role of each employee in the safety monitoring system when this system is used.
  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.

When the safety coordinator has reason to believe that any affected employee who has already been trained does not have the understanding and skill required, the employee must be retrained. Circumstances include:

  1. Changes in the workplace which render the previous training obsolete.
  2. Changes in the types of fall protection systems or equipment to be used make the previous training obsolete.
  3. Inadequacies in an affected employee’s knowledge or use of fall protection systems, or the employee indicates that they have not retained the understanding or skill. 


K.  Rescue Procedures

At the beginning of any work activity where fall protection equipment is to be used, rescue plans must be identified and discussed with all affected employees in case of a fall. The Competent Person will determine if the designated fire department should be put on alert depending on the potential severity of the fall. 

The employees must have a means of communicating problems or emergencies to others (such as radio, cell phone, observer stationed nearby). In the event of a fall, the following people will be notified as soon as possible:

  1. Rescue personnel
  2. Competent Person as identified in the fall protection program
  3. Manager/Supervisor of the employee

When fall protection equipment is utilized, the prompt and correct use of trauma straps should be used. 

All employees involved in a fall arrest or fall will be sent immediately for a medical evaluation to determine the extent of injuries, if any. 


L.   Fall Investigation

All fall investigation will be conducted by the employee’s supervisor, safety coordinator, and/or 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 the affected employee and witnesses
  2. Employee’s Work Injury and Illness Report
  3. Supervisor’s Incident Analysis and Prevention Report 



SPS 332 Public Employee Safety and Health

29 CFR 1926 Subpart M, Fall Protection

29 CFR 1910.Subpart D, Walking-Working Surfaces

29 CFR 1910.Subpart F, Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms

The Fall Protection Policy will be reviewed every 2-3 years and sooner if there are any changes.

Printable Pdf - Ch.9-FallProtectionProgram.pdf

Keywordsfall, harness, lanyard, edge, guardrail,   Doc ID96997
OwnerNick G.GroupCALS Safety & Health Resources
Created2020-01-09 12:36:19Updated2023-08-31 14:28:42
SitesCALS Safety & Health Resources
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