Earlier this year, the Ontario Ministry of Labour completed a 90-day provincial compliance and enforcement campaign to ensure employers and workers were complying with the regulations laid out in the Occupational Health and Safety Act (OHSA). The goal of the campaign, part of the Safe at Work Ontario strategy to strengthen workplace safety, was to promote long-term compliance and decrease injury and fatality rates. The focus of the campaign was fall-related hazards at provincially-regulated construction sites, diving operations and window cleaning activities. Ministry inspectors visited sites to assess whether workplace parties were complying with regulations, adequate measures and procedures for the safe use of equipment were in place, and workers using fall protection systems were adequately trained.
The results of the blitz underscore the need for more awareness and training surrounding fall protection in the construction industry. Of the 7,313 total field visits conducted, 3,912 were at construction sites where fall hazards were identified. Inspectors visited 2,821 different construction projects during the campaign. A total of 784 stop-work orders, 3,421 orders and 121 summonses were issued for fall-related hazards. More than half of the orders issued were for violations related to missing or improper use or maintenance of guardrails, non-suspended scaffolds and fall protection systems. All sectors of the construction industry were issued orders during the campaign, including industrial, commercial and institutional (ICI); building construction; single-family housing; and apartment and multi-family housing.
In the preliminary report issued in May, the ministry concluded that the results of the campaign indicate several issues. First, the fact that 80 percent of the summonses were issued to supervisors indicates that there is a lack of adequate supervision on construction projects. Second, the type of violations observed indicates that work measures and procedures needed to keep workers safe were not in place. Third, a comprehensive look at the data suggests that workers and supervisors are not aware or adequately trained in fall-related hazards and general safe work measures and procedures.
Each of these issues can be remedied with a comprehensive fall protection program. The program is a combination of a written plan that defines the company’s policy, assigns responsibilities and lays out how fall hazards will be addressed, and the company’s implementation of the plan, including ongoing employee education and training.
Analysis. A key step in the development of the plan is a fall hazard analysis. This survey analyzes each fall hazard that will be encountered on a job site, how the hazard will be controlled, and the type of fall protection and rescue equipment to be used when an employee is exposed to the hazard.
Fall hazards can be controlled in a number of ways, with preference given to engineering out the hazard or changing work procedures so that employees are not exposed to the hazard. In the construction industry, these methods are usually not possible, so the next step is to implement passive fall protection systems such as guardrails and covers. Where this is not possible, a fall restraint system should be considered. A fall restraint system prevents a worker’s center of gravity from reaching the fall hazard. A fall arrest system should be implemented if none of the above methods are suitable. A fall arrest system is designed to stop a fall in progress.
Rescue Plan. For every fall hazard that is controlled, a rescue plan must be in place. This will address the procedure and equipment to be used to rescue a fallen worker, and must be specific to each hazard identified in the fall hazard analysis.
The fall protection plan should account for and delegate responsibilities for equipment inspection, record keeping, maintenance, equipment replacement, incident reporting, enforcement, accident investigation and training.
Training. The OHSA requires workers to be adequately trained in the proper use of fall protection equipment. To maximize comprehension, training should be conducted through a combination of classroom and hands-on work.
Employees should be taught how to recognize and control fall hazards and how to use written fall protection procedures. They should have an understanding of federal and provincial fall protection regulations, employee roles and responsibilities under these regulations and the company’s program, and post-fall rescue procedures. Practical instruction should include how to select, inspect, use, store and maintain fall protection and rescue equipment.
Worker training must be documented, and these records must be kept and made available to Ministry of Labour inspectors upon request.
Training should not be the last time employees are reminded of the importance of fall protection equipment. Constant reminders during toolbox talks as well as regular refresher training are keys to maintaining a high degree of safety consciousness among employees. Refresher training should be conducted at least every two years, but should be done more frequently if work procedures change or new fall protection or rescue equipment is implemented.
Non-compliance policy. If compliance continues to be a problem, consider implementing a policy that punishes non-compliance. This policy could range from no-tolerance to a tiered policy with varying consequences after each offense. Consequences from non-compliance could include dismissal from the job, sending the employee home without pay, asking the employee to pay a fine, or something a bit more creative. Make sure any policy is well-defined, consistently enforced and in line with provincial labour laws.
Developing a fall protection program and ensuring that workers are appropriately trained are the first steps in combating compliance problems in the construction industry. Ontario is also implementing several measures to improve safety on construction sites. These measures include strict enforcement targeting repeat offenders and shutting down construction projects when workers’ lives are in danger, increased focus on training and supervision during inspections, a public campaign to increase awareness of safety in different languages, and a telephone line for workers and the general public to report suspected unsafe work practices.
Minister of Labour Peter Fonseca states: “We cannot and will not stand by as worker safety is compromised. This is a shared responsibility, so I challenge employers, labour groups and workers to make sure that everyone returns home safe and sound after work.” Fonseca is right. There’s no better incentive to stay safe than the privilege of returning home to your family at the end of the day.
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John Fuke is global i-Safe manager with Capital Safety, designer and manufacturer of fall protection and rescue products, including the DBI-SALA and PROTECTA brands. For more information, visit www.capitalsafety.com or call 800-328-6146.
