Working at Heights Practices

[MNicolai]

In our theatre, we have a few different applications, none of which necessarily require the use of a harness, although a harness is suggested. Specifically, our FOH catwalk and scissor lift use.

As per the suggestion of an ETCP rigger we contracted in to perform some work for us, we purchased a fall arrest harness. So far I've been the only one to use it on a handful of occasions. Only once would I have not performed worked without it, the other times being applications where I would've felt safe on our catwalk with the harness being more a formality and example to students walking around the venue than anything else.

The problem I have is that we have no procedure in place for someone who has fallen while wearing a harness. Given the locations a harness is used, people can readily access the positions a harness would be secured to, and could possibly pull a person up. Still, dead-lifting someone 15', possibly unconscious, and then having pull them through the railings of the catwalk is not ideal. Conversely, I wouldn't want our solution to be to simply tie a rope to the end of the lanyard and then have a team of EMS personnel lower the victim to ground level. That's putting a lot of faith in responders' physical capabilities. Aside from that, there's only so much time a person can be in a harness, dangling from a structure before they have severe complications.

So what's the next action I should pursue on formulating a response plan for someone having fallen? Bearing in mind that we fall into a gap that leaves us with only a couple people who would ever use the harness and rather than deal with the complications of what-if's, would rather not a wear a harness but still lean out over the catwalk railings to put gels in the fixtures, replace lens tubes, and such forth.

I certainly want to coordinate with the fire department, but don't want to rely on them for advised working at heights practices.

Is this an OSHA thing or will a well-rounded ETCP rigger suffice for telling us how we're doing it wrong?

 

[cprted]

I would get a workplace safety consultant to come in and help you out. They will know all the applicable OHS regs inside and out. In my area, a rescue plan is a required element of fall protection. There are self-retracting lanyards that have a self-rescue feature built-in. They're pretty snazzy and could be a good solution depending on your situation. Also, if you're working on a catwalk, a fall restraint system may be a good option. These are the things you can talk about with a consultant.

How is it that you need to rescue someone dangling 15' below the catwalk? In my area, the maximum free fall distance allowed in a fall arrest system is 6.5' with a shock absorbing lanyard or 4' without a shock absorbing lanyard.

 

[MNicolai]

How is it that you need to rescue someone dangling 15' below the catwalk? In my area, the maximum free fall distance allowed in a fall arrest system is 6.5' with a shock absorbing lanyard or 4' without a shock absorbing lanyard.

I used my PeakWorks iPhone app for a semi-realistic distance. A 6' lanyard, anchor height roughly the same height as my D-ring, gives 6' for the lanyard length, 3.5' for the deceleration, and 2.5' for harness stretch, plus another 3' for safety. My actual lanyard might be shorter but I haven't measured it. Basically, I pulled a number out of a just-about thin air for the sake of argument with little intent for it to be completely accurate to the specific harness we own.

(actually, I pulled the number out of thin air and then found that PeakWorks gave the same number by sheer coincidence -- it was for the sake of discussion and not meant to be any carefully conceived number)

 

[derekleffew]

Mike,
In addition to the response plan, it appears you are ignoring (or at least haven't mentioned) a very significant component of the ANSI Z359 Fall Protection Code. See also OSHA 1926.500 .

 

[MNicolai]

Mike,
In addition to the response plan, it appears you are ignoring (or at least haven't mentioned) a very significant component of the ANSI Z359 Fall Protection Code. See also OSHA 1926.500 .

I don't doubt this. An ETCP-certified rigger told my boss we should have a harness, and now we have a harness. That's the full extent to which owning a harness has been thought out, and that's why I'm raising this issue in the first place. Simply owning the harness doesn't make anyone safer, but because this last weekend was the first time I've used it in several months, that time being the first time I had used it ever, it's been effectively a non-issue. It exists but has been ignored. It's there if an insurance provider or OSHA inspector asks questions or if we want to set a semi-decent example for students. I deny none of this.

Care to elaborate on which parts of these documents I've not mentioned and have probably ignored? -- both of which are documents I've not actually read before (because an ETCP rigger said, "You should own a harness," listed a couple ways we could use it, and didn't ever care to further elaborate on the responsibilities of using a fall protection system).

I'm going to stress the ETCP part, because I feel in this scenario, the certification and hiring of certified persons has failed me, a member of the industry, but I digress.

 

[derekleffew]

From Sapsis Rigging Fall Protection Systems :

If you have an existing structure we will:
# Inspect the facility and identify all areas where fall arrest solutions are needed.
# Submit a proposal detailing requirements for a Fall Arrest system, (correcting violations, upgrading your current system or installation of a new system)
# Develop an inspection and maintenance regimen for your System that will assist your facility in becoming OSHA compliant.
# Train employees in the inspection and use of the Fall Arrest system.
# Develop a rescue plan for all areas of your System.
# Act as a liaison between you and your local authorities concerning a Fall Arrest Rescue Plan.

It appears you/the facility/your rigger have attempted to condense the above down to "purchase a harness," and are now working on "develop a rescue plan." I would agree that you received bad or incomplete advice, but being an ETCP-Certified Rigger makes one no more an expert in the area of Fall Protection than being an ETCP-Certified Entertainment Electrician makes one an Electrical Engineer.

Any fool with a credit card can purchase a harness, but I would argue that without proper training and understanding of the complete system, he may be more dangerous than one who doesn't have a harness at all.

For starters, WHAT are you clipping that shock-absorbing lanyard to? The 1.5" fixture mounting pipe? An I-beam? Unistrut? How do you KNOW the attachment point meets the 5000# capacity as specified in Z359?

See this PDF for more: http://www.millerfallprotection.com/pdfs/ANSI-Z359Standard/Understanding ANSI Z359.pdf .

 

[MNicolai]

I clip to the square tubing used to create the rails. It's at least 2" tubing, with welds to the super structure every 8' or so horizontally along the catwalk, plus a greater density of vertical uprights along the railing. No one's tested it for 5000# point loads, but it's certainly not just the fixture mounting pipe.

 

[cprted]

I clip to the square tubing used to create the rails. It's at least 2" tubing, with welds to the super structure every 8' or so horizontally along the catwalk, plus a greater density of vertical uprights along the railing. No one's tested it for 5000# point loads, but it's certainly not just the fixture mounting pipe.

Here's the thing, under my OHS regs, a gaurdrail system only needs to be rated to withstand a 1500 lbs force, you need 5000 for a tie-off point. Think of it this way, would you be comfortable suspending your brand new Ford F-350 from that railing? If not, you shouldn't be tying off to it.

 

[MNicolai]

From what I've been reading more appropriately I don't know that we need a fall arrest system but rather a fall restraint system.

Back to the original question: How do I find someone qualified enough in fall protection systems to provide the proper services we would need? From the sounds of it an ETCP rigger doesn't necessarily fit the bill, which is where my first instinct would've been to go to on this subject.

 

[SteveB]

A very timely subject as I pondered fall restraint/arrest while in my JLG at +20 ft last Friday. As I rolled along (self powered lift) I felt the need to be in a harness. Note that the existing rail system does it's job of keeping me in the bucket, but I felt vulnerable. I don't feel vulnerable at 15ft., but the OSHA rule says I need a harness.

Interesting thing though, the very first page on the OSHA website states that State and Local governments are not under OSHA jurisdiction and I'm a State of NY employee and in a State building. So the next question is does our college abide by OSHA reg's ?. I'll call Tuesday.

Then I still want a harness. A poll of my 3 electricians that focus for me in the JLG says that none of them have ever used a harness in a Genie/JLG bucket at any other place of work, so maybe 10 other NYC area theaters that don't know the rule. All of these folks question as well the wisdom of clipping in to a bucket that might tip, but that's the OSHA rule.

So a call to Sapsis is in order, then I have to determine WHERE on my JLG we are supposed to clip. Does it have a rated attachment point ?. Rated to 5,000 lbs according to what I'm reading here ?. Good question.

Good timing on this post as well.

 

[MNicolai]

Those thoughts are where I believe a fall restraint system is what is actually practical. A fall arrest system does little good in a lift unless you're performing work adjacent to a structure that you can secure an anchorage point to. In theatre, that's rarely an option.

If you fall over the railing, you're ensuring that not only will you bring the lift down with you, but that after you've hit the ground as the lift tips over, that it will indeed crush you.

On my catwalk, I don't see any reason for a fall arrest system because what we need is not a system that allows us to fall over an edge we fully intend to lean over, but instead need something that will only let us lean over enough to comfortably drop a gel into the end of a fixture but absolutely no further.

A person shouldn't be capable of falling in the first place for these applications.

But it's never been easy get an answer out of anyone when it comes to these questions, so I'm left to educated guessing. Riggers, contractors, and everyone else I've asked have always given different non-answers about harnesses in lifts, or at the very most, answers that were unsatisfactory.

To most, a harness is a harness is a harness, and that's where the conversation ends.

 

[Footer]

As far as who to call....
Sapsis does this as well as many other rigging companies. They have the engineers to do load studies on your facility and decide what you need. Also, nearly any iron/steel erection company should be able to get you a good system. This is a very common thing in general industry and what we do is not really that different from the catwalks and steel that exist in general industry.

 

[derekleffew]

...then I have to determine WHERE on my JLG we are supposed to clip. Does it have a rated attachment point ?. ...

In the case of lifts, the purpose of a lanyard is for fall restraint--to prevent you from doing something stupid (climbing out of the basket), rather than fall arrest (slow you down and not let you hit the floor). The 5000# rating is not applicable.

 

[Van]

View attachment 3950
In the case of lifts, the purpose of a lanyard is for fall restraint--to prevent you from doing something stupid (climbing out of the basket), rather than fall arrest (slow you down and not let you hit the floor). The 5000# rating is not applicable.

All man lifts, manufactured in recent history have a rated, suitable attachment point for a lanyard. It is, typically, a clearly marked 'U-bolt' screwed through one of the main structural beams of the cage.
The return question should be, " Why am I operating a man lift when I don't know this? and why haven't I been properly trained ? "

 

[MNicolai]

The answer to your return question is unfortunately simple. General use of a scissor lift doesn't require use of a harness. You aren't required to wear a harness until you start reaching over the railings and standing on them. Therefore, proper training (at least around here) tends to not talk about harnesses. When the lift rental company comes in to give their safety spiel, it focuses more on not using lifts on sloped surfaces, outdoors on windy days, and basic movement operations as well as how to manually lower the basket in the event of a failure of some kind. After you've gone up, driven around a little bit, and come back down, they give you a card saying you've completed their training without doing something incredibly stupid.

 

[SteveB]

And as follow up to my question about OSHA and the State of New York, I was told today by our campus health and safety officer that the State of New York has adopted all OSHA regulations to "cover all public employees" employees and that they are enforced by the NY State Dept.of Labor. I read this to mean City of NY as well as every municipality in the State. Only other person I can think this affect is Mrs. Footer when she works at the Egg in Albany and possibly Kyle, who might have mentioned his facility is owned by the City of Saratoga ?.

 

[Van]

The answer to your return question is unfortunately simple. General use of a scissor lift doesn't require use of a harness. You aren't required to wear a harness until you start reaching over the railings and standing on them. Therefore, proper training (at least around here) tends to not talk about harnesses. When the lift rental company comes in to give their safety spiel, it focuses more on not using lifts on sloped surfaces, outdoors on windy days, and basic movement operations as well as how to manually lower the basket in the event of a failure of some kind. After you've gone up, driven around a little bit, and come back down, they give you a card saying you've completed their training without doing something incredibly stupid.

Actually that's not the right answer or rather not the one I was looking for. When you recieve training for the operation of a man lift it should include any and all situations. If your training does not include the demonstration of the location of the lanyard attachment device then your training is by definition, Incomplete. Also, Perhaps your 'General use of a scissor lift..." doesn't require the use of a harness, but in many places the first thing you do is clip in and the last thing you do is un-clip, or you go home.

 

[SteveB]

When you recieve training for the operation of a man lift it should include any and all situations. If your training does not include the demonstration of the location of the lanyard attachment device then your training is by definition, Incomplete. .

Well no, this is not the case. The equipment manufacturer can show you that there is an attachment point, but they are not showing you how to use it. Use of a harness and lanyard is only required by OSHA in certain circumstances. Many state and local municipalities do not follow OSHA regulations and are not required to, thus a training session on a Genie, given to government employees, may well be "complete" as to the operation of the equipment, while not taking into account any "other" regulations that may or may not apply. Operation of the counterweight fly system, may well train you on how to safely load counterweights, but will not teach you, nor should it, that wearing fall protection is required. Likewise, operation of an ETC dimming system, is not going to teach you how to safely follow the local electrical codes.

 

[Footer]

Only other person I can think this affect is Mrs. Footer when she works at the Egg in Albany and possibly Kyle, who might have mentioned his facility is owned by the City of Saratoga ?.

Both my space and Mrs.Footer's space are state owned. We each work for non-profits that operate inside the state facilitys. At The Egg, the state (Office of General Services) is responsible for all gear inside the building, including lifts and fall arrest. However, no one at the Egg is a state employee so standard OSHA regs apply. Same goes for my space.

When I was down in a local one venue a few months ago, they had many of these type of things the stagehand call board:Theatrical Stage Employees | Local One | IATSE. Might be worth a read. Then again, they also had a memorandum posted saying what safe operation of a genie type lift was that was ignored by the house crew.

 

[mstaylor]

Whether you fall under OSHA regs or not, the training should be the same. Normal use of a scissor lift does not require a harness but most scissor lifts have the ability to lay the hand rails down. At that point a harness is required. A vertical lift is the same as far as no harness. The thing I never understood is the welded rigging point is attached to the hand rail in many lifts but the hand rail isn't allowed to be used.
As far as a harness on a catwalk, don't know without seeing it but I can'timagine it would help all that much. If needed, probably a horizontal lifline would be the ticket but a safety inspector is the one to tell you. He can also help you develope a rescue plan.
A rigger saying you need a belt and then offering no direction in it's use or even saying that you need training in the use is very irresponsible.
Never ever work in any lift and attach to a building tie-off. That is a perfect way to end up hanging with no lift under you and no way for anyone to rescue you.