BRIEF

Policy Summary

Lawrence Berkeley National Laboratory's (Berkeley Lab's) Fall-Protection Program applies to work on any walking or working surface having an unprotected side or edge above a lower level that is:

• 6 feet high or more (for construction work).
• 4 feet high or more (for nonconstruction work).

Surfaces include leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 1.2:1 (horizontal to vertical), hillsides, roofs, and surfaces with open holes or skylights.

Who Should Read This Policy

Berkeley Lab employees, construction contractors, nonconstruction subcontractors, vendors, and affiliates who work on any walking or working surface having an unprotected side or edge above a lower level that is:

• 6 feet high or more (for construction work).
• 4 feet high or more (for nonconstruction work).

To Read the Full Policy, Go To:

The POLICY tab on this wiki page

To Read the ES&H Program Details, Go To:

ES&H Manual Chapter 30

Contact Information

EHS Subject Matter Expert for Fall Protection
EHS Division

POLICY

A. Purpose

Lawrence Berkeley National Laboratory's (Berkeley Lab's) Fall-Protection Program applies to work on any walking or working surface having an unprotected side or edge above a lower level that is:

• 6 feet high or more (for construction work).
• 4 feet high or more (for nonconstruction work).

Surfaces include leading edges, roofs, tanks, manholes, unguarded machinery, aerial lifts, ladders, slopes steeper than 1.2:1 (horizontal to vertical), hillsides, roofs, and surfaces with open holes or skylights.

B. Persons Affected

Berkeley Lab employees, construction contractors, nonconstruction subcontractors, vendors, and affiliates who work on any walking or working surface having an unprotected side or edge above a lower level that is:

• 6 feet high or more (for construction work).
• 4 feet high or more (for nonconstruction work).

C. Exceptions

Fall-protection work controls are not required under the following conditions:

1. For nonroofers only: work on a flat or low-sloped roof (slope of less than 4 in 12) when all of the following conditions are met:
   1. All work is conducted at least 15 feet from any unprotected edge.
   2. A warning line is used to denote the 15-foot distance.
   3. No work activities take place between the warning line and the unprotected edge.
   4. Workers follow the work rule of not going past the warning line.
2. During scaffold erection and dismantling, when all of the following conditions are met:
   1. The designated Competent Person overseeing the operation has determined that active fall protection is infeasible.
   2. The Competent Person has put a fall-protection plan in writing that meets the California Occupational Safety and Health Administration (Cal/OSHA) requirements found in the Construction Safety Orders, Sections 1635.1–1667.
   3. The Competent Person has submitted the written fall-protection plan to Berkeley Lab Project Management for review and approval prior to commencing the operation
3. Climbing up and down ladders when the user can maintain three-point contact (consisting of two feet and one hand) at all times.
4. Work from ladders higher than 6 feet and below the third rung when the user can maintain three-point contact (consisting of two feet and one hand) at all times.
5. Work from platform ladders when the user can demonstrate that he or she can work safely inside the rails of the ladder.

D. Policy Statement

1. At Berkeley Lab, height limits are set at:
   1. 6 feet for construction work
   2. 4 feet for nonconstruction work
2. A written fall-protection plan is required for any task requiring fall protection. For most situations, a Fall-Protection Matrix Permit (FPMP) is used. An FPMP can be obtained and will be approved by the fall-protection subject matter expert (SME) / LBNL Fall-Protection Competent Person.
3. Authorized Persons are Berkeley Lab employees (including affiliates and directly supervised subcontractors) who perform work tasks where the use of fall-protection equipment is required. Authorized Persons must successfully complete Berkeley Lab training course EHS0276 (Fall Protection) and be authorized by their supervisors or work leads. Only trained Authorized Persons can use fall-protection equipment.
4. New construction and installations with fall hazards must be designed to eliminate the need for fall protection.
5. Work controls are required under the following conditions:
   1. Any work task on a walking/working surface with an unprotected side or edge above height limits.
   2. Any work task on an aerial lift (including a scissor lift only if an engineered anchor point is provided by the manufacturer) when working above the protection system at floor openings, unprotected perimeters above height limits, and whenever a fall above height limits could occur.
   3. Any work task done by steel erectors and sheet metal installers above height limits.
   4. Any use of a portable ladder when working above height limits or above the third rung (from the top of the ladder).
   5. Any use of a portable ladder when working above height limits and below the third rung when the user cannot maintain three-point contact (consisting of two feet and one hand) at all times. A written fall-protection plan is required for any task requiring fall protection. In most cases, an FPMP will be used for planning.
   6. Any use of scaffolding, including erecting and dismantling, requires a written fall-protection plan to identify and control site and access issues with the scaffolding location.
6. Work controls must be used when working above height limits.
   1. Initial work controls are identified in:
      1. Work Planning and Control (WPC) activities or
      2. Task-based JHAs.
   2. Control systems to be used are:
      1. Passive systems that eliminate the need for fall protection through the application of engineering controls (such as lowering the work surface or providing barriers, such as parapets, that prevent contact with the leading edge) or administrative controls (such as changing a process, sequence, or procedure so that workers do not need to work at heights).
      2. Active systems that protect the worker through fall-arrest equipment. An active fall-protection system or personal fall-arrest system (PFAS) requires the use of specialized fall-protection equipment that must be fitted to the user and worn to control fall hazards. The user is secured to an anchorage point at all times, even while moving from point to point.
      3. See the program document for special requirements covering:
         1. Scaffolding
         2. Steel erection
         3. Tree trimming
         4. Roofing and nonroof work on roofs
         5. Fixed ladders
         6. Confined spaces
         7. First-person-up situations

E. Roles and Responsibilities

F. Definitions/Acronyms

See ES&H Manual, Chapter 30, Fall-Protection Program, for technical terms related to the details of this policy and its implementation.

G. Recordkeeping Requirements

Fall-Protection Matrix Permit

H. Implementing Documents

I. Other References

J. Contact Information

EHS Subject Matter Expert for Fall Protection
EHS Division

K. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• 10 CFR 851, Worker Safety and Health Program
• Title 8 CCR, Division 1, Chapter 4, Subchapter 4, Construction Safety Orders (for all construction safety unless 29 CFR 1926 Safety and Health Regulations for Construction is more strict) (Cal/OSHA Standard)
  • Article 6. Excavations (Sections 1539–1547)
  • Article 16. Standard Railings (Sections 1620–1621)
  • Article 17. Ramps, Runways, Stairwells, and Stairs (Sections 1623–1626)
  • Article 18. Access and Egress (Sections 1629–1631)
  • Article 19. Floor, Roof, and Wall Openings (Sections 1632–1633)
  • Article 20. Temporary Floors (Section 1635)
  • Article 21. Scaffold – General Requirements (Sections 1635.1–1637)
  • Article 22. Scaffolds – Various Types (Sections 1640–1655)
  • Article 23. Suspended Scaffolds (Sections 1658–1667)
  • Article 24. Fall Protection (Sections 1669–1672)
  • Article 25. Ladders (Sections 1675–1678)
  • Article 29. Erection and Construction (Sections 1709–1722.1)
  • Article 30. Roofing Operations and Equipment (Sections 1723–1731)
  • Article 31. Demolition (Sections 1733–1737)
• Title 8 CCR, Division 1, Chapter 4, Subchapter 7. General Industry Safety Orders (for all General Industry safety unless 29 CFR 1910, Occupational Safety and Health Standards for General Industry is more strict) (Cal/OSHA Standard)
  1. Group 1. General Physical Conditions and Structures (Sections 3207–3299)
  2. Group 2. Safe Practices and Personal Protection (Sections 3300–3416)
  3. Group 3. General Plant Equipment and Special Operations (Sections 3420–3583)
  4. Group 4. General Mobile Equipment and Auxiliaries (Sections 3620–3920) 

Implementing Documents

Other References