REGULATORY COMPLIANCE WHEN WORKING AT HEIGHTS ON WIND TURBINES
The Occupational Safety and Health Act (OSHA) assures and enforces safe and healthful
working conditions for employees in the United States. Under the OSH Act, employers
have the duty to provide workers with a workplace free of recognized safety and health
hazards. It’s the Law.
Wind turbine workers routinely place themselves at risk when working at heights on these
elevated structures. As such, OSHA and ANSI require the use of fall protection equipment
and training for any workers exposed to the hazards of a fall. Fall protection is essentially
a system that protects workers who could lose their balance while working at heights,
usually resulting in injury or death.
Working at heights is inherently dangerous and therefore workers must be trained and
protected.OSHA requires the use of engineering controls when working at heights as
the first line of defense to protect the worker, (i.e. “engineer out the hazard”). When this
is not practical or simply not effective, then the use of a Personal Fall Arrest System (PFAS)
utilizing a full body harness with 100% tie-off in conjunction with a suitable anchor point,
connectors, related equipment and safe work practices, (administrative controls) are
essential and required by law.
OSHA’s hierarchy of prevention of injury from falls contains four key elements.
First, hazard identification and risk assessment. Second, hazard elimination and risk
control. Third, a change of process, material or procedure,
(including engineering and administrative controls). Lastly, the routine use of PFAS
in combination with trainingAND direct supervision. The emphasis here is on training.
OSHA states: “The employer SHALL provide a training program for each employee who
might be exposed to fall hazards”. OSHA continues in greater detail which will not be
discussed here however, we find the OSHA Standards addresses employee
training 853 times. Simply put, employers must train their workers. OSHA’s authority to
enforce workplace safety dates to the early 1970’s yet employers are still cited every day
for the failure of their employees to properly use PPE and PFAS correctly.
As mentioned in the key elements of injury prevention, OSHA and Regulatory compliance
for fall protection can be achieved by following these simple steps:
1. A thorough Job Hazard Analysis (JSA/JHA) and pre-planning must be conducted prior
to the start of each job.
2. A “Competent Person” has been designated and is on site during work activity.
A competent person is “one who is capable of identifying existing and predictable
hazards in the surroundings or working conditions which are unsanitary, hazardous,
or dangerous to employees, and who has authorization to take prompt corrective
measures to eliminate them.”
3. Fall protection training has been completed for all onsite employees and written
certification records maintained identifying the trainee, trainer, dates of training and
the signature of the person conducting the training.
4. A “site specific” rescue plan is in place and has been implemented, rescue equipment
has been provided at each jobsite where PFAS equipment is being used and all employees
have been trained and have demonstrated their ability in the use of the rescue gear and understanding of the plan.
5. Inspections must be conducted before each use on the following equipment: PFAS,
PPE, rigging, hand tools and powered tools/hoists.
Wind turbine workers who might be exposed to fall hazards must be trained to recognize
the hazards of falling and must be trained in the procedures to be followed in order to
minimize these hazards. Training is to be conducted by a competent person who is qualified
in the areas outlined in the standard. A thorough and complete understanding of the
consequences and dynamics of a fall, the proper use and limitations of the fall arrest system components and approved rescue procedures in the event of a fall are an absolute must as
required by law.
For further information or to schedule a class contact (317) 867-4487 ext. 21 or