CB30012: 1. Fall Protection Plan

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A Fall Protection Plan (FPP) is a documented plan to work at a fall risk. The Construction Regulations of 2014 define a fall protection plan:

“fall protection plan” means a documented plan, which includes and provides for:

(a) All risks relating to working from a fall risk position, considering the nature of work undertaken,

(b) the procedures and methods to be applied in order to eliminate the risk of falling, and

“fall risk” means any potential exposure to falling either from, off or into;

When developing a fall protection plan, the first step will be to draft a method statement. In the method statement, you identify the method of access- ladders, scaffolding, MEWP or rope access. From there you can identify the type of equipment needed such as a harness, and what type of harness. Lifelines, descending devices, ascending devices etc. Look carefully at the OEM (original equipment manufacturer) specifications of the equipment as well as the SANS standards.

Now you can identify what method will be used, will it be fall arrest or rope access, and what type of training is necessary for the employees.

There is no such thing as a one-fit fall protection plan. Each site will differ and the fall protection plan must be in line with your scope of work.

For practical purposes, you could break down your fall protection planning into ten sections, with each section responding to a component towards compliance with Construction Regulation 10.

These sections relate to your fall protection policy, work site and job conditions, fall risk assessment, legal appointments, training management, health management, equipment management, operating procedures, emergency procedures, review and amendments.

1. Fall Protection Policy

Your policy should include a statement on how the employer will meet statutory requirements, such as the OHS Act, national or international standards (SANS, ISO, etc.), and industry standards (professional bodies, such as the Institute for Work at Height), and corporate standards.

2. Work at Height Site Information

Gather and collate relevant information on the site; who, what, when, where, and how. Part of the information gathering process includes:

Notification of Construction Work in terms of CR4.1 (b), submitted to DOL seven days prior to commencement of construction work
Contact Information of relevant management staff, contractors, and emergency services
Worksite location/s, address, GPS coordinates, road and site access points
Method statement, with a description of the site, project phases, jobs, access methods and equipment requirements. What fall arrest or rope access equipment will be used, how you would gain access, scaffolding positions and methods, and equipment applications

3. Fall Risk Assessment

A detailed baseline risk assessment must be performed by a competent person (CR9.1 and CR10.2 a), including;

Identify hazards and risks (including training and behaviour) to which your employees may be exposed
Analyse and evaluate the risks and hazards
Document your plan and work procedures to remove, reduce and manage the risks and hazards
The risk assessment must be communicated to all employees by the competent risk assessor or fall protection planner. Risk assessments must be monitored and reviewed in response to significant changes in plan, equipment, or staff

4. Legal Appointments

Appointments required by the OHS Act, relevant to work at height, include:

Fall Protection Planner CR 10.1 (a)
Risk Assessor CR9.1
Rescuer CR10.2 (e)
Equipment Controller CR10.2 (d)
Rope Access Technician CR18.7
Fall Arrest Technician CR10.2 and 10.4 (b)
Rope Access Supervisor CR18.1

Appointees must be competent in terms of the definition of a competent person in the Construction Regulations.

5. Training Management

The applicable training must be identified per designation, and appointment letters must state the required training. Records of training must be kept and identified on a training matrix.

6. Health Management

Relevant employees must have a valid medical fitness certificate. A medical fitness register must be kept with details and expiry dates of the medical certificates.

7. Work at Height Equipment Management

According to CR10.2 (d) and 10.4 (c)(i), there must be a procedure for inspection, testing and maintenance of all each kind of fall protection equipment.

Equipment Inventory for different types of equipment, with unique numbering, quantity and status. Inventory records must be kept at the equipment storage.

- Booking-in and booking-out documents by the equipment controller, with copies at the stores as well as in the fall protection plan file
- Inspection records for intervals not exceeding 3 months of all equipment on the inventory list are kept at the stores
- Pre-use inspection records by users, with records on file
- Defective equipment is reported to the appointed person (CR8, 7), who reports to the Equipment Controller. Replace defective equipment and amend the inventory list

8. Work at Height Operating Procedures

Refer to training manuals, equipment instructions, manufacturer’s recommendations, industry best practices, company procedures, client specifications, as well as your operating procedure.