Working at Heights

Program Elements
August 31, 2020
Working at Heights – Program Elements

Table of Contents
Purpose, Scope and Critical Controls ............................................................................................... 3
A. Work Planning ............................................................................................................................... 4
B. Fall Prevention Measures ............................................................................................................. 5
C. Fall Protection Measures .............................................................................................................. 5
D. Roof Access Permit System/Package.......................................................................................... 7
E. Ladders, Scaffolds and Elevated Work Platforms ...................................................................... 8
F. Fall Rescue Planning................................................................................................................... 11
G. Equipment Inspection and Maintenance ................................................................................... 13
G. Training ........................................................................................................................................ 15
Revision History................................................................................................................................ 19

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Working at Heights – Program Elements

Purpose, Scope and Critical Controls

The Working at Heights program elements are designed to ensure that work at heights is performed in a safe manner.
These program elements apply to all International Paper sites and majority owned subsidiaries and contain required site
actions to implement the requirements of the Working at Heights Performance Standard effectively.

Working at Heights is defined as:

 Any work performed on a surface that is four feet (1.2 meters) or more above an adjacent surface
 Working within the exclusion zone of an unprotected fall hazard such as a roof edge or unguarded skylight
 Work that is four feet (1.2 meters) or more off the ground on rolling stock such as flatbed trailers, bulk chemical
tankers, railcars, trucks containing wood products (chip/bark/ash), etc.
 In addition, the Working at Heights program elements shall apply if a risk assessment determines a person can
fall into, or onto dangerous equipment.

This is a global minimum expectation and does not contain all local, state and federal/country regulatory requirements.
Each site must identify and comply with their regulatory requirements. If IP and regulatory requirements conflict,
comply with the most stringent expectation.

Critical Control – a control or “layer of protection” that is crucial to preventing an event or mitigating the
consequences of the event (to help us fail safely). The absence or failure of a Critical Control will significantly
increase the risk despite the existence of other controls in place and is therefore essential for the safety of our
employees and non-employees.

The Critical Controls are identified by an icon in the Program Elements.

Critical Controls Actions that Can Help Avoid Harm

Fall Prevention  Install and maintain guardrails and physical barriers.
Fall Protection  Wear fall protection above 4 feet and on mobile platforms.
 Use approved anchor points.
 Carry suspension trauma safety straps if you are using fall arrest.
Safe Ladder Use  Select the right ladder and use it properly.

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Working at Heights – Program Elements

A. Work Planning
Use the table to determine what tools and permits are required for routine vs. non-routine work planning.

Work Planning Requirements Routine Work Non-Routine Work

Document safe work methods
 Integrate working at heights planning into existing site
SOP/PJSA processes
Standard Operating Pre-Job Safety
 Identify task(s), method(s) and critical work steps
Procedure (SOP) Assessment (PJSA)
 Establish start/stop work criteria
 Identify adjacent hazards, such as rotating equipment
that pose an entanglement hazard
Fall Evaluation and Control Fall Evaluation Form Fall Evaluation Form
May be incorporated into
 Control measures for working at heights SOP or an attachment
 Approved anchor point
 Unprotected roof hazard – permit required Roof Access Permit Roof Access Permit
Fall Rescue Assessment and Planning
 Rescue options (self, buddy, skilled rescue team)
 On-site vs. External skilled rescue team Fall Rescue Plan Fall Rescue Assessment
 Ensure skilled rescue team has resources to execute
rescue operations at time work will be performed

1. Use your site’s existing Standard Operating Procedure (SOP) and Pre-Job Safety Assessment (PJSA) processes,
but include all requirements shown in the table above.

2. The Fall Evaluation must include the following information for work at heights:
 Adjacent hazards, such as rotating equipment that pose an entanglement hazard Fall Evaluation
 The control measures for working at heights Template
 Approved anchor point (if applicable) available in
Toolbox
 Fall rescue assessment or plan (if applicable)
 Other permits required, such as a Roof Access Permit

The Fall Evaluation may be incorporated into or attached to a Standard Operating Procedure (SOP).

3. See Section D: Roof Access Permit System/Package for Roof Access Permit requirements.

4. Fall Rescue Assessment: Is required when a Personal Fall Arrest System (PFAS) will be used and a permanent fall
rescue plan has not been developed. Fall Rescue
 Assess capability for self-rescue or unskilled buddy rescue. Assessment
 Identify work that may need professional or skilled rescue services. Contact them Template
to confirm they have resources to execute rescue operations at the time work is available in
Toolbox
scheduled.
 See Section F – Fall Rescue Planning for detailed requirements of the Fall Rescue
Assessment and Fall Rescue Plan.

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Working at Heights – Program Elements

B. Fall Prevention Measures

1. Sites must develop and implement fall prevention measures to eliminate the risk of falls during work at heights.
Fall prevention is engineering controls designed to separate the worker from the fall hazard. Approved fall
prevention measures are:
 Fixed barriers such as standard railings and skylight guards
 Permanent catwalks and work platforms equipped with standard railing systems
 Scaffolds equipped with standard railing systems
 Mobile Elevated Work Platforms (MEWPs) (formerly scissor, boom, and aerial lifts) equipped with
standard railing systems. Travel restraint is used to prevent climbing out of, or ejection from the work
platform.

Specifications for standard railings, skylight guards and fall prevention measures are located in the Working at
Heights Toolbox.

C. Fall Protection Measures

Use Fall Protection when fall prevention cannot be implemented. Fall protection is a control or countermeasure
designed to mitigate the risk of a fall, or to minimize the potential for injury after a fall occurs. Approved fall
protection measures are:

1. Travel restraint systems. Travel restraint systems shall meet the following specifications:
 Consist of a suitable anchorage capable of supporting a load of at least 5,000 pounds (22.2 kN) per
person attached to the anchor point. Reference the IP Anchor Point Considerations document for
guidance selecting non-certified anchorages.
 Prevent the worker from approaching closer than 12 inches (30 cm) from the fall hazard

2. Personal fall arrest systems (PFAS). Personal fall arrest systems shall meet the following specifications:
 Consist of a suitable anchorage capable of supporting a load of at least 5,000 pounds (22.2 kN) per
person attached to the anchor point. Reference the IP Anchor Point Considerations document for
guidance selecting non-certified anchorages.
 Include a deceleration device capable of limiting arresting force to 900 pounds (4.0 kN) or less
 Utilize a full body harness designed to distribute fall and arresting forces over a combination of the
thighs, pelvis, waist, chest, and shoulders
 Minimize swing fall and prevent the worker from falling more than 6 feet (1.8 meters) or striking the
lower surface
 Self-retracting lifelines (SRLs) are they only style of lanyard permitted for fall arrest purposes. The total
length of webbing, deceleration devices, snaphooks, and connectors must not extend more than 24
inches (61 cm) beyond the opening of the housing when fully retracted.
 Use of a shock-absorbing lanyard is restricted at IP and must be reviewed and approved by a Fall
Protection Competent Person with documented management/EHS Department approval.

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Working at Heights – Program Elements
3. Exclusion Zones
 Roof exclusion zone is an area within 15 feet of an unprotected fall hazard (e.g. roof edge, unguarded
skylight or fragile area).
 A non-roof exclusion zone is an area adjacent to an unprotected fall hazard (e.g. floor opening, wire pit,
tank top, broke hole).
 The default exclusion zone is 15 feet. If 15 feet is not available or an additional hazard is
created, the distance may be reduced on a case-by-case basis. The minimum size of an
exclusion zone is 6 feet (1.8 meters) from the unprotected fall hazard.
 A Competent Person must evaluate the hazards and select the maximum practical distance
that can be achieved. The evaluation must be approved by management/EHS Department and
documented to file using the Non-Roof Exclusion Zone Distance Exception Form or
equivalent. You may add information, establish stricter requirements, or change the layout of
the template form, but no information can be removed from the original templates.
 Workers must not enter any exclusion zone without the use of a personal fall arrest or travel restraint
system secured to an approved anchor point.
 A warning line that meets the following criteria may be constructed to allow personnel to be on the safe
side of the warning line without the use of a personal fall arrest or travel restraint system.
 Erected at the edge of the exclusion zone
o Roof: not less than 15 feet (4.6 meters) from the fall hazard
o Non-roof: not less than 15 feet (4.6 meters) from the fall hazard unless there is an
approved exception. Never less than 6 feet (1.8 meters) from the fall hazard.
 Consist of substantial ropes, wires, or chains on supporting stanchions, with high visibility
flagging affixed at regular intervals
 Maintained in a taut condition with stability sufficient to prevent them from being easily
knocked over or blown over by high winds
 Painted lines on a walking/working surface are not accepted as warning line systems, but may
be used to indicate where the warning line should be installed. NOTE: This may allow the site
to install the warning line from behind the 15 feet (4.6 meter) distance without wearing fall
protection.

4. Secure adjustment straps, webbing, and other loose objects on fall protection equipment close to the body to
mitigate moving equipment entanglement hazards.

5. Personal Fall Arrest System (PFAS) and travel restraint system components from different manufacturers may be
used together under the following circumstances:
 With prior written permission from all manufacturers; or,
 When the combination has been reviewed, deemed compatible, and approved by a Fall Protection
Competent Person.

6. Any time a person is working alone and wearing a Personal Fall Arrest System (PFAS), they must carry a
communication device (phone, radio or lone worker device) and confirm it is operating properly before
beginning work.

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Working at Heights – Program Elements

D. Roof Access Permit System/Package

1. Roof Survey - Sites shall conduct a survey of their roof areas and identify all unprotected fall hazards. The
unprotected fall hazards and their associated exclusion zones must be marked on a roof diagram or satellite
photograph. When multiple unprotected fall hazards exist in an area, exclusion zones for those individual
hazards could overlap.
 Unprotected fall hazard - any fragile roof area, roof edge, or a roof opening [at least 12 inches (31 cm)
in its least dimension] through which a person may fall and that is not protected by an IP-approved fall
prevention measure.
 Unprotected roof area - any location exterior to the building that has a walking or working surface that
is four feet (1.2 meters) above an adjacent surface and that contains any unprotected fall hazard.
 Roof exclusion zone - an area extending from the edge of an unprotected roof fall hazard to a distance
of 15 feet (4.6 meters) into which a worker may not enter without the use of IP-approved fall prevention
or fall protection measures.
 Sloped roof - roof with a pitch of 10 degrees or more.

2. Roof Access Permit

 Control all access to a sloped roof or any unprotected roof area via a Roof Access Permit.
 Issue Roof Access Permits for the duration of the task, not to exceed 7 days. Sites may choose to reduce
the valid period of a permit to less than 7 days.
 If a project extends beyond 7 days, close the existing permit and issue a new permit.
 Post Roof Access Permits at the primary point of roof access for the duration of the permit period.
 Permits must contain all elements in the Standard Roof Access Permit in the toolbox. Sites may add
additional information and customize the permit, but may not delete any elements from the standard
permit.

3. Working Alone and Communication

 If a Roof Access Permit is required, you may not work alone.
 Do not access unprotected roof areas alone. At least two people are required when accessing any
unprotected roof area.
 At least one person accessing the roof must have a communication device (two-way radio, cell phone,
etc.) and confirm that it works properly before accessing the roof.

4. Roof Access and Egress

 Roof access points that require permits must have a sign (in the local languages) posted indicating that a
roof access permit is required.
 At minimum, the word “DANGER” or an equivalent signal word must be on any roof access signage. The
sign must also contain the following or similar wording: “Roof Access Permit Required”.
 Sites are not required to lock roof access points. However, if a site has roof access points that are
controlled by lock and key, they must ensure multiple access points are unlocked during roof access.
 If there is only one roof access point, you must have a plan to rescue workers and/or the ability to create
additional access/egress points.

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5. Weather Monitoring
 The site or persons on the roof must monitor weather conditions and have a plan to stop work and seek
shelter under the following conditions:
i. Active tornado warning within 50 miles (80 kilometers) of the facility when the path of the
storm is in the general direction of the facility
ii. Thunderstorm activity within 10 miles (16 kilometers) of the facility
iii. Strong winds are present at the facility; “strong winds” are defined as 25 mph (39 kph) or higher
(Level 6 or greater on Beaufort scale)
 Roof access is prohibited under the following conditions unless a personal fall arrest or travel restraint
system is utilized:
i. Sleet, freezing rain, or other active icing weather conditions
ii. Snow cover obscures an unprotected fall hazard (such as an unguarded skylight) from sight

6. Upset Conditions
 Roof access is prohibited during routine venting of NCG or other hazardous gas exhaust systems located
on the roof, unless a functional, calibrated, and properly bump-tested multi-gas monitor or personal gas
detector equipped with sensor(s) for the air contaminant(s) of concern is utilized.
 Roof access is prohibited during any emergency or accidental venting of NCG or other hazardous gas
exhaust systems located on the roof, unless appropriate respiratory protection is used and roof access is
required to address the emergency condition.

7. Stop Work
 Roof access may have been safe at the time the permit was issued, but shall cease immediately if any of
the STOP work conditions on the permit develop.

E. Ladders, Scaffolds and Elevated Work Platforms

1. Ladders – General Requirements:
 Design Requirements:
 Ladders must not be self-made or constructed of natural materials such as wood or bamboo.
 Setup/Installation:
 Confirm the ground is firm and level and the ladder is stable.
 Barricade the area if other work or traffic could displace the ladder.
 Do a pre-use inspection
 Use:
 Follow all manufacturer warnings and instructions
 While climbing, descending or performing work on a ladder:
1. Maintain three points of contact
2. Keep your hips positioned between the ladder’s side rails
3. Don’t carry tools or materials in your hands
 If you are working from a ladder more than 4 feet (1.2 m) above your work surface and cannot
maintain three points of contact or must move your body’s center of gravity out of the ladder’s
side rails – you must use a Personal Fall Arrest System (PFAS). Consult a Fall Protection
Competent Person with questions.

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Working at Heights – Program Elements
2. Fixed ladders:
 Design Requirements:
 Have rungs that are equally and uniformly spaced along the length of the ladder at reasonable
intervals and wide enough to allow for sufficient footing while climbing
 Be free of sharp edges, burrs, or other hazards
 Be firmly affixed to the surface and of sufficient strength to sustain twice the intended working
load
 Be equipped with a self-closing swing gate where workers could walk into the ladderway
opening. The swing gate must consist of both a midrail and top rail.
 When ladder rungs are used as anchor points for a personal fall arrest system, each rung shall be
capable of supporting a minimum 5,000-pound (22.2 kN) load rating.
 Consider the potential for secondary falls when designing and installing fixed ladders.
 Use:
 If you are working from a ladder more than 4 feet (1.2 m) above your work surface and cannot
maintain three points of contact or must move your body’s center of gravity out of the ladder’s
side rails – you must use a Personal Fall Arrest System (PFAS). Consult a Fall Protection
Competent Person with questions.

3. Portable ladders (extension or step)

 Design Requirements:
 Metal ladders are prohibited, except for firefighting.
 Only portable fiberglass ladders with insulating rubber feet are acceptable.
 Ladder feet must be slip or skid-resistant.
 Rungs must be designed to minimize slipping (i.e. corrugated, ridged, knurled, dimpled or
coated with skid-resistant material).
 Use a ladder that is rated to support the load (person + materials).
 Setup/Installation:
 Set up ladders on firm level surfaces or use engineered leveling devices.
 Extension Ladders
1. Set up extension ladders at a 4:1 angle.
2. Extend the ladder at least 3 feet (0.9 meters) above the surface you will access.
3. If possible, secure the extension ladder at the top and bottom.
 Stepladders
1. Open the ladder completely and lock the spreader bar braces
2. Do not use a stepladder as a straight ladder
 Use:
 Only use ladders as described in the manufacturer’s guidelines.
 If you are working from a ladder more than 4 feet (1.2 m) above your work surface - Use a
Personal Fall Arrest System (PFAS) if you cannot maintain three points of contact or must move
your body’s center of gravity out of the ladder’s side rails. Consult a Fall Protection Competent
Person with questions.

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Working at Heights – Program Elements
4. Manually Propelled Mobile Ladder Stands
 Design Requirements:
 Manually propelled mobile ladder stands must be rated to support the load (person and
materials).
 They may be constructed of metal, but must not be used near energized electrical equipment.
 The work platform must be protected by guardrails. The point of entry may be protected by a
swing gate or chain.
 A locking mechanism and/or rubber feet must be at the bottom of the ladder stand to prevent
movement when a person is on the platform.
 Steps must be designed to minimize slipping (i.e. corrugated, ridged, knurled, dimpled or coated
with skid-resistant material).
 Setup/Installation:
 Wheels must be locked or the stand must be immobilized while it is in use.
 Use:
 Do not move or reposition while a person is on the stand.
 Maintain three points of contact while climbing and descending.

5. Scaffolds
 Design Requirements:
 Be capable of supporting at least four times the intended working load
 The structural members of scaffolds shall not be self-made or constructed of natural materials
such as wood or bamboo. Wood scaffold planking is allowed if it is scaffold grade.
 Have planking that extends 6-12 inches (15-30 cm) beyond the end support or that is secured in
place to prevent movement or shifting
 Have an access ladder or other means of access to prevent climbing on cross-members
 Be erected and maintained in a plumb condition to prevent the possibility of tipping
 Be constructed to maintain an aspect ratio of no more than 4:1 (height to least base dimension)
or be securely anchored to an immovable building structure if the aspect ratio exceeds 4:1
 Setup/Installation:
 Scaffold footings, anchorages, and substrates are level and stable and shall not displace, settle,
or shift under the weight of the scaffold and its rated working load (including the appropriate
safety factor, if any).
 Secure mobile scaffolds in place prior to use. Do not move or reposition a mobile scaffold while
a person is on the scaffold.
 Barricades must be installed if:
o There is potential for dropped objects
o There is potential for the scaffold to be displaced by motorized equipment.
 Scaffold Use:
 Sites must implement a scaffold tag system to identify if the scaffold has been inspected by a
Scaffold Competent Person and is safe for use. The tag system must include the inspection
results, inspection date and signature of the competent person. [SEE TOOLBOX FOR SAMPLE
TAGS]
 Maintain three points of contact while climbing and descending the scaffold.
 Fall protection is not required on scaffolding if you are working in an area where the scaffold
meets all inspection requirements, and all structural members, planking and railings are in place.
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Working at Heights – Program Elements
If you must wear fall protection on a scaffold, consult a Fall Protection Competent Person with
questions.

6. Mobile Elevated Work Platforms (MEWPs) (formerly scissor, boom and aerial lifts)
 ATTENTION: Reference the Motorized Equipment Program Elements for all requirements before
attempting to operate a MEWP. The requirements below are fall protection-specific items that must be
implemented in addition to the Motorized Equipment Program Elements.
 Design Requirements:
 Mobile Elevated Work Platforms must have manufacturer-certified 5000 lb fall protection
anchor points.
 Setup/Installation:
 Scissor, boom and aerial lifts shall not travel while in an elevated position.
 Barricades must be installed if:
 There is potential for dropped objects
 There is potential for the lift to be displaced by motorized equipment
 Use:
 Occupants of scissor, boom and aerial lifts must wear fall protection and maintain 100% tie-off.
 Travel restraint
 In general, fixed length and shock absorbing lanyards are prohibited for use at
International Paper sites. One of the limited acceptable uses is for fall restraint inside an
aerial lift basket.
 The best option for fall restraint in an aerial lift is a full body harness and a fixed length
lanyard (no shock absorber) attached to the basket’s integrated anchor point.
 If it is not safe to use a fixed length lanyard, use a self-retracting lanyard (SRL) that is
properly attached to a full body harness and the basket’s integrated anchor point.
o The SRL must be OEM rated for aerial lift use and may need to be installed in a
reverse configuration.
 Fall arrest
 The best option for fall arrest in an aerial lift is a full body harness and a self-retracting
lanyard (SRL) attached to the basket’s integrated anchor point.
o The SRL must be OEM rated for aerial lift use and may need to be installed in a
reverse configuration.
 If the aerial use is used to access an elevated surface, the SRL must be a double-leg
lanyard that provides 100% tie-off while the worker transitions from the anchor point in
the lift to an anchor point outside of the lift.

F. Fall Rescue Planning

1. Sites shall plan for and provide prompt rescue to workers who have fallen and are suspended by a personal fall
arrest system. The target time for rescue should be within six minutes of an arrested fall but shall not exceed 15
minutes.

2. The site must provide each employee who uses a Personal Fall Arrest System (PFAS) with a pair of suspension
trauma safety straps and require that they be attached to the employee’s harness during all work using a PFAS.
They help prevent suspension trauma and orthostatic intolerance while suspended and waiting for rescue.

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Working at Heights – Program Elements
3. Sites shall designate, train and utilize an onsite, employee-based rescue service unless this is not reasonable and
an external professional rescue agency (such as a local fire department or rescue squad) can provide rescue
services within the designated 15 minute limit.

4. External Rescue Team

 Sites that elect to utilize an offsite professional rescue agency shall verify that the agency is properly
equipped, trained, and capable of providing rescue services for any post-fall scenarios to be encountered
at the site. This verification shall be performed prior to the offsite agency being formally designated as
the rescue service provider and shall include an onsite visit by the agency and formal review of
anticipated post-fall rescue scenarios.
 You must evaluate that agency using the External Post-Fall Rescue Agency Evaluation Form.
 You must provide copies of fall rescue plans to that agency.

5. On-site Rescue Team

 Sites utilizing an onsite rescue team shall acquire and maintain the appropriate manpower and types and
quantities of rescue equipment based on the post-fall rescue scenarios identified. Inspection criteria are
outlined in Section G: Equipment Inspection and Maintenance.

6. Post-Fall Rescue Drills

 Sites shall conduct post-fall rescue drills at least annually.
 For sites that utilize an external professional rescue agency, the annual drill shall be used to verify the
outside agency’s response time and effectiveness.

7. Fall Rescue Plan –

 A permanent Fall Rescue Plan is required for all work at heights that will need rescue team support. This
applies to support from both IP Emergency Response Teams and external agencies.
 A sample Fall Rescue Plan is provided in the toolbox. Your site’s Fall Rescue Plans must include at
minimum, the same information shown in the sample.
 Fall rescue plans shall be written and shall be implemented prior to work at height using a personal fall
arrest system.
 Written rescue plans shall be reviewed annually with the IP Emergency Response Teams/external
agencies and revised, as necessary.
 Written rescue plans must be proactively shared with external rescue agencies if the site relies on them
to perform post-fall rescues.

8. Fall Rescue Assessment

 Is required when a Personal Fall Arrest System (PFAS) will be used and a permanent fall rescue plan has
not been developed.
 A Fall Rescue Assessment evaluates the rescue options based on the fall rescue hierarchy
Fall Rescue Hierarchy
Complex Rescue Team Skilled rescue team, high angle rescue, tripod rescue
 Buddy Rescue Unskilled rescue with common equipment (ladder, lift)
Simple Self-Rescue PFAS with self-rescue capability
 Confirms self-rescue and buddy rescue tools and materials are available and working properly
 Identifies work that may need professional or skilled rescue services and confirms they have resources
to execute rescue operations at that time.
 Evaluate fall rescue assessments at the completion of the work to determine if they need to be
converted into a permanent fall rescue plan.

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9. Post-Fall Rescue Debrief
 Sites shall conduct debrief meetings after annual drills and after any actual post-fall rescue event to
determine the effectiveness of the rescue plan.
 The written post-fall rescue plans shall be revised when debrief meetings identify either gaps in the
response plan or opportunities for improvement of the plan.

G. Equipment Inspection and Maintenance

1. Sites must maintain an inventory of fall protection equipment.

2. Sites shall maintain equipment in good working order at all times.

 Fall prevention equipment, ladders, scaffolds, and certain fall protection systems (warning line systems,
etc.) determined to be damaged or defective shall be evaluated to determine if the damage requires
taking the equipment out of service. Based on that evaluation, barricade, tag out, and/or remove it from
service and repair or replace in a timely manner.
 Fall protection personal protective equipment (such as full body harnesses, lanyards, self-retracting
lifelines, etc.) determined to be damaged, defective, or exposed to a load shall be immediately
discarded and replaced.

3. At minimum, conduct equipment inspections according to the table below. Sites may choose to increase the
frequency of inspections beyond the minimum requirements below.
 Documentation of initial and annual inspections is mandatory.
 Annual is defined as every 12 months. For example, if the last inspection was conducted on January 12
of the current year, the next inspection must be conducted in or before the month of January of the
following year.
 Note that more frequent inspections may be necessary to comply with manufacturer’s
recommendations or your local, state or federal/country requirements.

Equipment Inspection Name Frequency Inspector Qualifications Must Document

Standard railing New or modified – After new or Initial Walking/Working Yes
systems and modified installation, inspect Surfaces Competent
skylight guards skylight guarding and railings. Person
Annual – Inspect existing skylight 12 months Walking/Working Yes
guards and railings at least every Surfaces Inspector
12 months.
Personal fall Pre-use – inspect all fall arrest or Pre-use Fall Protection No
arrest or travel travel restraint equipment prior to Authorized User
restraint each use.
equipment Annual – inspect all fall arrest or 12 months Fall Protection Yes
travel restraint equipment at least Competent Person OR
every 12 months. Equipment Inspector
Anchor points New or modified – inspect new or Initial Fall Protection Qualified Yes
modified anchor point installation Person
prior to first use.
Pre-use – inspect anchor points Pre-use Fall Protection No
prior to each use. Authorized User

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Working at Heights – Program Elements

Equipment Inspection Name Frequency Inspector Qualifications Must Document

NOTE: For some anchor points
installed at remote or highly
elevated positions, it may not be
possible for the worker to inspect
the anchor point prior to each use.
Annual –inspect anchor points 12 months Fall Protection Yes
every 12 months. Competent Person OR
Equipment Inspector
Post-fall –inspect any anchor point Post-event Fall Protection Yes
exposed to a fall event prior to Competent Person
placing the anchor point back into
service.
Warning line New or modified – inspect new or Initial Fall Protection Yes
systems modified warning line systems Competent Person
prior to first use.
Annual – inspect all warning line 12 months Fall Protection Yes
systems at least every 12 months. Competent Person OR
Equipment Inspector
Fixed ladders Initial – Inspect after new or Initial Ladder Competent Yes
modified installation prior to first Person, Engineer, EHS
use. Dept
Annual –inspect fixed ladders at 12 months Authorized Ladder Users Yes
least every 12 months.
Portable ladders Pre-use – inspect portable ladders Pre-use Authorized Ladder Users No
prior to each use.
Manually Pre-use – inspect manually Pre-use Authorized Ladder Users No
Propelled propelled mobile ladder stands
Mobile Ladder prior to each use.
Stands

Scaffolds Initial – inspect newly erected or Initial Scaffold Competent Yes

modified scaffolds prior to the first Person
use.
Daily – inspect scaffolds prior to Daily Scaffold Competent Yes
use on each day that they will be Person
used.
Pre-use – review the scaffold Pre-use Scaffold Authorized User No
inspection tag.
Mobile Elevated
Work Platforms
Inspection requirements are in the Motorized Equipment Program Element.
(aerial, boom
and scissor lift)
Horizontal Life Initial – inspect after new or Initial Fall Protection Qualified Yes
Lines modified installation prior to first Person
(Permanent) use.
Pre-use – each person who Pre-use Fall Protection No
anchors to the horizontal lifeline Authorized User
must perform a pre-use inspection
prior to each use.

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Working at Heights – Program Elements

Equipment Inspection Name Frequency Inspector Qualifications Must Document

Annual – inspect permanent 12 months Fall Protection Yes
horizontal lifelines at least every Competent Person OR
12 months. Equipment Inspector
Horizontal Life Initial – inspect after installation Initial Fall Protection Yes
Line prior to use. Competent Person OR
(Temporary Equipment Inspector
Portable - i.e. Pre-use – each person who Pre-use Fall Protection No
Miller’s Life Line anchors to the horizontal lifeline Authorized User
in a Bucket) must perform a pre-use inspection
prior to each use.

G. Training
Sites shall ensure that the following persons are properly trained:

Target Audience Course and Role Frequency Requirements

 Employees who “Safe Roof Access” Initial – Prior to accessing Training must consist of at least
access roof areas toolbox training (or roof areas for the first time the following topics:
and their equivalent training  Fall and other hazard
supervisors material developed by Refresher – 36 months recognition for roof areas
 IPCCs who the site)  An explanation of the roof
supervise access permit process
contractors who After completing the  A review of IP-approved fall
access roof areas course the employee is prevention and protection
an Authorized Roof measures
Accessor
 Employees who “Ladder Safety” toolbox Initial – Prior to utilizing a Training must consist of at least
use portable or training (or equivalent ladder or mobile ladder the following topics:
fixed ladders, training material stand for the first time  Portable ladders, fixed
mobile ladder developed by the site) ladders and mobile ladder
stands and their Refresher – 36 months stands
supervisors After completing the  Pre-use inspection
 IPCCs who course the employee is  Proper ladder set-up
supervise an Authorized Ladder  Safe climbing and ladder use
contractors who User (including 3-point contact)
use portable or  Special considerations (such
fixed ladders or as ladder use in proximity to
mobile ladder energized electrical
stands equipment, swing gates)
 Employees who “Scaffold User Safety” Initial – Prior to utilizing a Training must consist of at least
work from toolbox training (or scaffold for the first time the following topics:
scaffolds and equivalent training  Scaffold use tag review
their supervisors material developed by Refresher – 36 months  Safe access and egress from
 IPCCs who the site) scaffolds
supervise  Safe scaffold use
contractors who After completing the  Fall protection requirements
use scaffolds course the employee is when on scaffolds
an Authorized Scaffold
User

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Working at Heights – Program Elements
Target Audience Course and Role Frequency Requirements
 Employees who “Scaffold Erector” Initial – Prior to assembling Training must consist of at least
erect scaffolds Third party or building a scaffold for the the following topics:
first time  Erecting, disassembling,
After completing the moving, operating, repairing,
course the employee is maintaining and inspecting
an Authorized Scaffold the scaffold
Erector
 Employees who Third party “Scaffold Initial – Prior to supervising Training must consist of at least
supervise scaffold Competent Person” scaffold construction and the following topics:
construction and course or equivalent performing daily scaffold  Be knowledgeable about the
perform daily delivered by a qualified inspections structural integrity of
scaffold trainer scaffolds and the degree of
inspections Refresher – 36 months maintenance needed to
After completing the maintain them
course the employee is  Erecting, disassembling,
an Scaffold Competent moving, operating, repairing,
Person maintaining and
 Inspecting the scaffold
 Employees who “Fall Protection Initial – Prior to utilizing the Training must consist of at least
use fall protection Equipment Users” issued fall protection the following topics and include a
equipment and toolbox training (or equipment for the first time hands-on demonstration:
their supervisors equivalent training  Each employee must
 IPCCs who material developed by Refresher – 12 months demonstrate ability to put on
supervise the site) and take off PFAS
contractors who  Inspection requirements
use fall protection After completing the specific to the type of
course the employee is equipment issued
an Authorized Fall  How to identify damage or
Protection Equipment defects in the equipment
User  Action to take if damaged or
defective equipment is
identified
 Proper use, care, cleaning,
storage, and maintenance of
equipment issued

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Working at Heights – Program Elements
Target Audience Course and Role Frequency Requirements
Fall Protection “Fall Protection Initial Training – prior to Training must consist of at least
Equipment Inspector Equipment Inspector” first inspections the following topics and include a
hands-on demonstration:
After completing the Refresher – every 36  Inspection requirements
course the employee is a months or when new specific to the type of
Fall Protection equipment is introduced equipment
Equipment Inspector  How to identify damage or
defects in the equipment
Training options:  Action to take if damaged or
 Third party training defective equipment is
course identified
 Read user manual
inspection section
 Read manufacturer
inspection manual
 Watch manufacturer
inspection videos
 Review custom-
engineered products
with engineer and/or
IP Fall Protection
Competent/Qualified
Person
Fall Protection Third party “Competent Initial – Prior to being Training must consist of at least
Competent Persons Person” training course designated a “Competent the following topics:
(or equivalent course Person”  Fall hazard identification,
delivered by a qualified elimination, and controls
trainer) Refresher – At least once  Applicable fall protection
every 36 months regulations
After completing the  Fall protection procedures
course the employee is a  Detailed inspection of
Fall Protection equipment components and
Competent Person systems
 Determination of when a fall
Note: Experience may be protection system is unsafe
substituted for training  Conduct a post-fall rescue
so long as the person can assessment
demonstrate proficiency  Selection and use of non-
in all topics listed under certified anchorages
training requirements.

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Working at Heights – Program Elements
Target Audience Course and Role Frequency Requirements
Fall Protection Third party “Qualified Initial – Prior to being Training must consist of at least
Qualified Persons Person” training course designated a “Qualified the following topics:
(or equivalent course Person”  Fall hazard identification,
delivered by a qualified elimination, and controls
trainer) Refresher – At least once  Applicable fall protection
every 36 months regulations
After completing the  Fall protection procedures
course the employee is a  Detailed inspection of
Fall Protection Qualified equipment components and
Person systems
 Development of fall
protection system
engineering standards,
including design, selection,
and analysis of certified and
non-certified anchorages
 Determining free fall
distances, fall clearance, and
swing fall
 Development of post-fall
rescue procedures
 Contractors “Site Contractor Initial – Prior to working at Site-Specific Requirements:
 Truck Drivers Orientation” the site
 Vendors  Roof Access Permit System
 Non-Employees Refresher – every 12  Scaffold Safety & Tag System
performing work months  Ladder Safety
on-site  Mobile Elevated Work
Platform Safety
 Fall Protection
 Shock-absorbing lanyards are
prohibited
 Emergency Planning and
Rescue

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Working at Heights – Program Elements

Revision History
Revision Date Element Description of Changes
1/15/2014 All Document approved and published
2/4/2014 Ladder and Scaffold Safety Changes to clarify natural materials prohibition and add exceptions to
metal ladder prohibition
6/12/2014 Fall Protection Measures Removed “access to egress” installation requirement for warning line
systems
Roof Access Permit Changed requirement to post permits at all possible points of roof
Systems access to post only at the primary point of roof access
10/14/2014 Fall Prevention Measures Added aluminum to the acceptable materials of construction for
standard railings
5/6/2015 Risk Assessment Added PJSA requirement from H&S Alert
Fall Prevention Measures Clarified scope of elevated work platforms to include grating floors
Fall Protection Measures Added SRL requirements from H&S Alert
Modified to allow co-mingling of equipment suppliers
Roof Access Permit Modified to require two persons only on unprotected roof
Systems
6/5/2015 Ladder and Scaffold Safety Changed scaffold plank security requirement (section E.7., bullet #2)
to allow for either overlap or physical means of security
3/18/2016 Equipment Inspection and Removed scissor, boom and personal aerial work lift inspection criteria
Maintenance from table (now included in and required by the Motorized Equipment
Program Elements)
10/25/2016 Equipment Inspection and Removed catwalk and platform inspection criteria from table (now
Maintenance included in and required by the Walking and Working Surfaces
Program Elements)
08/31/2020 All Program Elements updated with changes from Deliberate
Improvement Project – see Change Summary for details.
Critical Controls identified.
Format updated.

August 31, 2020 Page 19 of 19