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HSEQ POLICY MANUAL
SESI
PM702
PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
1.0
2.0
3.0
4.0
Purpose
This fall protection policy establish requirements to ensure that fall protection
training, operation and practices are communicated to and understood by the
affected employees. This policy applies to all operations where there is potential
risk of personnel falling.
Scope
This policy applies to SESI Business Units, subsidiaries and affiliated business
groups that, under the direction of their respective Executive Vice President have
implemented the Superior HSEQ Management System.
The United States (U.S.) Code of Federal Regulations is a baseline for our global
operations. Where other local, state or federal/country requirements exceed
the U.S. regulatory requirements, the more stringent requirements shall apply.
Reference
Corporate Form, HSEQSESISCF006, Job Safety Analysis
Corporate Form, HSEQSESISCF042, Lanyard Inspection
Corporate Form, HSEQSESISCF043, Full Body Harness Inspection
Corporate Form, HSEQSESISCF044, Lifeline Inspection
Corporate Form, HSEQSESISCF045, Tag Line Inspection
Corporate Form, HSEQSESISCF047, Self Locking Carabiners Inspection
Corporate Form, HSEQSESISCF048, SRL Inspection
Corporate Form, HSEQSESISCF049, SRL Sealed Unit Inspection
Corporate Form, HSEQSESISCF050, Rescue/Positioning Device Inspection
Corporate Form, HSEQSESISCF051, Fall Protection Rescue Plan
Responsibilities
4.1
Vice President of Corporate HSEQ responsibilities are:
4.2
Administration, interpretation, and maintenance of this document to
keep it current with business conditions.
SESI Business Management and HSEQ leader responsibilities are:
HSEQSESIPM702
Ensuring compliance with this document at the SESI Business
Management level and performing the activities as described.
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HSEQ POLICY MANUAL
SESI
PM702
PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
Business Unit Management and HSEQ Managers are responsible for
determining whether this policy applies to their respective Business Unit
(HSEQSESIPM110, Applicability to Superior Business Units) and
initiating the Management of Change process to deviate from this policy
as appropriate.
5.0
6.0
Definitions
5.1
A fall restraint system consists of the equipment used to keep a worker
from reaching a fall point, such as the edge of an elevated working surface.
The most commonly utilized fall restraint system is a standard guardrail. A
tieoff system that "restrains" the worker from falling off an elevated working
surface is another type of fall restraint.
5.2
A personal fall arrest system means a system used to arrest an employee in
a fall from a working level. It generally consists of an anchor point,
connectors, a body belt or full body harness and may include a lanyard,
deceleration device, lifeline, or suitable combinations of these. The entire
system must be capable of withstanding the impact forces involved in
stopping or arresting the fall. The forces increase with the fall distance due
to acceleration.
General
6.1
6.2
6.3
Primary protection shall be accomplished by engineered guardrails for work
areas above six feet or more above a secured deck, ground, or water. Other
means of fall protection should be used when decking and guardrails are not
feasible.
Note: Six feet (1.8 m)shall be measured from the work platform (i.e. persons
feet) to the deck or floor below.
Fall protection systems shall be built for purpose systems that meet local
regulatory requirements (example in the United States: 29 CFR 1926.502).
Each affected Company employee working at an elevation of six feet or
greater above the ground, a secured deck or any height over water is
required to wear a full body harness with a shockabsorbing lanyard
attached to a structural member.
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
6.4
6.5
6.6
6.7
7.0
Additional conditions for wearing fall protections might include when
working on scaffolding, working on a boat landing or plus 10 level not
surrounded by handrails and when working on a fixed or portable ladder
when an employee is above six feet.
The lanyard must be of such a length as to prevent the employee from falling
and striking the next lower level. In no case will the lanyard be greater than
six feet long.
Fall hazards shall be discussed at prejob safety meetings and noted in the
JSAs. All fall hazards identified must be eliminated or special precautions
shall be addressed before the job can start.
Fall protection plans will be developed at each facility as required by local
regulatory requirements.
Fall Protection
7.1
Permanently installed ladders, ten feet or higher, require fall protection. A
cage does not qualify as fall protection.
7.2
Hoist areas six feet or higher shall be protected by a guardrail system or a full
body harness. If the guardrail system must be removed to facilitate hoisting
operations and an employee must lean through the access opening or out
over an edge to receive or guide equipment or materials, the employee must
utilize fall protection.
7.3
Open holes six feet or higher must be covered or protected by a guardrail
system. Open holes above work areas must be covered to prevent objects
from falling from above. Areas below the hole may be barricaded off if there
is a risk of dropped objects.
7.4
All Companyowned ramps, runways and other walkways used by employees
must contain a guardrail system.
7.5
Each affected Company employee working less than six feet above dangerous
equipment shall ensure that either a guardrail system is in place or the
equipment has some other type of equipment guard.
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HSEQ POLICY MANUAL
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PM702
PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
8.0
Falling Objects
8.1
Each affected Company employee is required to wear a hard hat in
designated areas, but when exposure to falling objects from a structure
above a working area is a potential risk, other measures will be considered.
Toeboards, guardrail systems, canopy structures, or barricades shall be used
when necessary and nogo zones shall be utilized when practical.
8.2
Toeboards
8.3
Be a minimum of 3.5 inches high and no more than inch
clearance above the surface
Be solid or have openings not over 1 inch in greatest
dimension
Be capable of withstanding a force of at least fifty pounds
applied in any downward or outward direction at any point
Be erected along the edge of the overhead walking/working
surface for a distance sufficient to protect employees below
If tools, equipment or materials are piled higher than the top edge of a
toeboard, an additional type of protection, paneling or screening shall
be placed from floor to guardrail to protect employees from falling
objects.
Good housekeeping must be practiced to prevent slip, trips and falls
and dropped objects.
When used as protection from falling objects, toeboards shall:
Canopy Structures
When used as protection from falling objects, canopies shall be strong
enough to prevent collapse and to prevent penetration by falling objects.
8.4
Guardrail Systems
When used as protection from falling objects, guardrails shall have
openings small enough to prevent passage of potential falling objects.
Below are general requirements for guardrail systems:
HSEQSESIPM702
Top edge height of top rails shall be 42 inches + 3 inches above
the walking/working level
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PM702
PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
HSEQSESIPM702
Midrails, screens, mesh, or intermediate vertical members
shall be installed between the top edge of the guardrail system
and the walking/working surface when there is no wall at least
21 inches high
Guardrail systems shall be capable of withstanding, without
failure, a force of at least 200 pounds applied within 2 inches of
the top edge in any outward or downward direction at any
point along the top edge
When the 200 pound test load specified above is applied in a
downward direction, the top edge of the guardrail shall not
deflect to a height less than 39 inches above the
walking/working level
Midrails, screens, mesh, intermediate vertical members, solid
panels, and equivalent structural members shall be capable of
withstanding a force of at least 150 pounds applied in any
downward or outward direction at any point along the midrail
or other member
Guardrail systems shall be surfaced to protect employees from
punctures or lacerations and to prevent clothing from snagging
The ends of top rails and midrails must not overhang terminal
posts, except where such overhang does not constitute a
projection hazard
Steel and plastic banding cannot be used as top rails or mid
rails
Top rails and midrails of guardrail systems must be at least
onequarter inch nominal diameter or thickness
When guardrail systems are used at hoisting areas, a chain,
gate or removable guardrail section must be placed across the
access opening between guardrail sections when hoisting
operations are not taking place
At holes, guardrail systems must be set up on all unprotected
sides or edges. When holes are used for the passage of
materials, the hole shall have not more than two (2) sides with
removable guardrail sections. When the hole is not in use, it
must be covered or provided with guardrails along all
unprotected sides or edges.
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HSEQ POLICY MANUAL
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PM702
PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
9.0
If guardrail systems are used around holes that are used as
access points (such as ladderways), gates must be used or the
point of access must be offset to prevent accidental walking
into the hole
If guardrails are used at unprotected sides or edges of ramps
and runways, they must be erected on each unprotected side
or edge
If wire rope is used for top rails, it must be flagged at not more
than 6 feet intervals with highvisibility material.
For United States regulatory reference, more details can be
found in 29 CFR 1926.502 (b) (115) and Appendix B,
Guardrail Systems
Fall Arrest
9.1
Each Company facility shall evaluate their employees work conditions and
environments to determine the personal fall arrest system that best suits the
environment. Below are general requirements for personal fall arrest
systems:
DRings (min of 2 inside diameter) and snaphooks shall have a
minimum tensile strength of 5,000 pounds. Connectors shall be drop
forged, pressed or formed steel and shall have a corrosionresistant
finish with all edges and surfaces smooth.
Snaphooks shall be a lockingtype snaphook. Unless the snaphook is a
locking type, they shall not be engaged to the following:
Directly to webbing, rope or wire rope
To each other
To a DRing that another snaphook or other connector is
attached
To a horizontal lifeline
To any object which is incompatibly shaped or dimensioned in
relation to the snaphook such that unintentional
disengagement could occur by the connected object being able
to depress the snaphook keeper and release itself
Lanyards shall have a minimum breaking strength of 5,000 pounds
Selfretracting lanyards which automatically limit freefall distance to
two feet or less shall be capable of sustaining a minimum tensile load
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
of 3,000 pounds applied to the device with the lanyard in the fully
extended position
Selfretracting lanyards that do not limit freefall distance to 2 feet or
less, ripstitch lanyards, and tearing and deforming lanyards shall be
capable of sustaining a minimum tensile load of 5,000 pounds applied
to the device with the lanyard fully extended
Ropes and straps (webbing) used in lanyards and strength
components of body harnesses shall be made from synthetic fibers.
Anchorages used for attachment of personal fall arrest equipment
shall be independent of any anchorage being used to support any
other equipment.
Personal fall arrest systems, when stopping a fall, shall:
Limit maximum arresting force on an employee to 1,800
pounds when used with a body harness
Be rigged such that an employee can neither freefall more
than 6 feet or contact any lower level
Bring an employee to a complete stop and limit maximum
deceleration distance an employee travels to 3.5 feet and have
sufficient strength to withstand twice the potential impact
energy of an employee freefalling a distance of 6 feet
The attachment point of the body harness shall be located in the
center of the wearers back near shoulder level or above the wearers
head
Body harnesses and its components shall be used only for employee
protection and not used to hoist materials
Fall arrest systems and components subjected to impact loading shall
be removed from service immediately
Fall protection shall not be attached to hoists.
When fall protection is used at hoist areas, it shall be rigged to allow
the movement of the employee only as far as the edge of the
walking/working surface
Because not all components are interchangeable, fall arrest systems
shall not be modified without proper evaluation. Wornout
components shall be replaced by a qualified vendor already supplying
the systems.
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
9.2
The use of body belts for fall arrest is prohibited and a full body harness is
required.
9.3
Fall protection devices (i.e. full body harnesses, lanyards, ropes, etc.) must be
recertified every three years (36 months) from the date of manufacture or
replaced. A qualified person must inspect all fall protection devices at least
once a year. All fall protection devices that have experienced one (1) shock
from a person or falling object must be removed from service and submitted
to the appropriate HSE Representative with a report on the incident.
9.4
All equipment purchased for use as fall arrest systems must meet or exceed
local regulatory, ANSI and ASTM standards before purchase. Prior to
purchasing fall protection equipment, its suitability shall be verified for the
intended application with the manufacturer.
10.0 Positioning Device Systems
10.1 Below are general requirements for positioning device systems:
Positioning devices shall be rigged such that an employee cannot free
fall more than two feet
Positioning devices shall be secured to an anchorage capable of
supporting at least twice the potential impact load of an employee's
fall or 5,000 pounds, whichever is greater
10.2
10.3
Pelican hooks are acceptable as a positioning device, but should not be used
as a primary means of connection.
Shall meet local regulatory requirements, i.e., example in the United States:
29 CFR 1926.502 (e) (110).
11.0 Safety Monitoring System
11.1 When the use of conventional fall protection is not feasible or the use would
create a greater danger to employees, Supervisory level personnel shall
contact their respective Leader and HSEQ Representative to discuss
additional options. The worksite must be classified as a controlled access
zone and a safety monitoring system shall be implemented.
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
11.2
The highestranking Supervisory level personnel onsite shall designate a
Safety Monitor. The Safety Monitor will be solely designated to this duty
and will be capable of recognizing fall hazards, warn the employees when it
appears that the employee is unaware of the hazards or is acting in an unsafe
manner, and shall be on the same surface within visual sight distance of the
employee being monitored.
12.0 Tieoffs
12.1 Selecting suitable anchorage points is an important part of using fall
protection correctly. In an ideal situation, anchorage points are installed
initially on equipment or structures. So, in some cases, anchorage points may
have to be installed to existing equipment or structures. A qualified
Professional Engineer shall design modifications made to existing equipment
and/or structures. In other cases, there will be a need to devise an anchor
point from existing structures such as:
Large eyebolts made of an appropriate grade steel
Steel members or Ibeams (these shall only be used with an
acceptable strap for the connection. Lanyards with a snaphook
clipped onto itself is prohibited.)
Guardrails or railings only if they have been designed for use as an
anchor point (shall be able to provide documentation on design)
12.2
Strength of a personal fall arrest system is based on it being attached to an
anchoring system, which does not reduce the strength of the system. If a
means of attachment is used that will reduce the strength, that component
shall be replaced by a stronger one that will also maintain the appropriate
maximum arrest force. The following are circumstances that would weaken
the strength of fall protection:
Tying a knot in a lanyard can reduce its strength by fifty percent or
more and shall not be done unless a stronger lanyard is used to
compensate for the weakening effect of the knot or a lanyard with an
appropriately incorporated connector is used to eliminate the need
for a knot
Tying a lanyard around an Ibeam, or similar support, can reduce its
strength by seventy percent or more due to the cutting action of the
beam edges and shall not be done unless a webbing lanyard is used
around the beam
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
12.3
Tying a lanyard around or over rough or sharp surfaces reduces
strength drastically and shall be avoided. Alternates would include
use of a snaphook/DRing connection, wire rope tieoff and effective
padding of the surface, or an abrasionresistance strap around or over
the surface.
When planning a tieoff point, the hazards of obstructions in the potential fall
path of the employee shall be considered.
13.0 Elongation and Deceleration Distances
13.1 During the arresting of a fall, a lanyard will experience a length of stretching
or elongation, whereas activation of a deceleration device will result in a
certain stopping distance. These distances shall be available with the lanyard
or device instructions and must be added to the freefall distance to arrive at
the total fall distance before an employee is fully stopped. Sufficient distance
to allow for all of these factors must also be maintained between the
employee and obstructions below to prevent an injury due to impact before
the system fully arrests the fall.
14.0 Inspections
14.1 All personal fall arrest systems must be inspected prior to each use and may
be documented utilizing the referenced forms (or equivalent).
14.2 Webbing
Webbing can be found on the body of a belt, harness or lanyard. The entire
surface of webbing shall be inspected for damage. Beginning at one end,
bend the webbing in an inverted U. Holding the body side of the belt
toward you, grasp the belt with your hands 6 to 8 inches apart. If edges are
frayed, fibers are broken, stitches are pulled, or cuts or chemical damage is
observed, the component must be replaced before next use or in accordance
with manufacturer recommendations.
14.3 Buckle
HSEQSESIPM702
The buckle shall be inspected for loose, distorted or broken
grommets. Do not punch additional holes in waist strap or other
strength members. Belts without grommets shall be inspected for
torn or elongated holes that could cause the buckle tongue to slip.
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FALL PROTECTION
The buckle shall also be inspected for distortion and sharp edges. The
outer and center bars must be straight. Corner and attachment points
shall overlap the buckle frame and move freely back and forth in the
sockets and the roller shall turn freely on the frame.
Rivets shall be tight and not able to move. The body side of the rivet
base and outside rivet burr shall be flat against the material. The
rivets shall not be bent, pitted, cracked, or show signs of chemical
exposure.
14.4
Rope
The rope lanyard shall be inspected from endtoend for fuzzy, worn, broken,
or cut fibers. Weakened areas shall show noticeable changes in the original
rope diameter and shall be replaced if the diameter is not uniform
throughout. As the rope ages, it becomes more imperative that testing and
inspection of the integrity is completed by a qualified personnel.
14.5
Safety Strap
The safety strap shall be inspected for cut fibers or damaged stitches
inchbyinch by flexing the strap in an inverted U noting cuts, frayed
areas or corrosion damage. Friction buckle shall be checked for
slipping and sharp buckle edges. The tongue buckle shall be replaced
when holes are excessively worn or elongated.
Any components with the following significant defects shall be
removed from service immediately:
HSEQSESIPM702
Cuts, tears, abrasions, mold, or undue stretching
Alterations or additions which might affect efficiency
Damage due to deterioration
Contact with fire, acids or other corrosives or chemicals
Distorted hooks or faulty hook springs
Loose or damaged mountings
Nonfunctioning parts
Wearing or internal deterioration in the ropes
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PERSONNEL WORK APPAREL & PROTECTIVE EQUIPMENT
FALL PROTECTION
15.0 Cleaning
15.1 Basic care of fall arrest systems prolong their life and contribute to their
performance. Clean components in accordance with manufacturer
recommendations which can be communicated by Business Unit HSEQ
department to appropriate employees using equipment.
15.2 Store the system in a clean, dry area free of fumes, sunlight or corrosive
materials in such a way that it will not warp or distort.
16.0 Rescue Plan
16.1 Prior to starting work in a fall hazards work area, a Fall Protection Rescue
Plan (HSEQSESISCF051) or equivalent, must be written and in place at
each worksite.
16.2 This plan is required to provide for the rescue of an individual from their
suspended fall protection devices in less than fifteen minutes from the time
of the fall.
16.3 Each employee involved must be ready to perform a rescue in the event that
an individual falls and is suspended by their fall protection device.
16.4 The plan shall include necessary equipment that may be used, roles of each
employee and procedures.
17.0 Training
17.1 Company employees exposed to fall hazards shall receive fall protection
training. Fall protection training will consist of instruction on how to
recognize the hazards of falling and the procedures to be followed to
minimize these hazards. Employees shall be trained on the safe use of the
system including:
Application limits
Proper anchoring and tieoff techniques
Estimation of freefall distance, including determination of
deceleration distance and total fall distance to prevent striking a
lower level
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FALL PROTECTION
17.2
17.3
17.4
Methods of use
Inspection and storage of the system
The Company will ensure that instructors teaching fall protection will be
qualified as per local regulatory requirements [example in the United States:
CFR 1926.203(a) (2) (iviii)].
Refresher training shall be provided at the Business Units discretion when
the following are noted:
Deficiencies in training;
Work place changes; and/or,
Fall protection systems or equipment changes that render pervious
training obsolete.
Training shall be documented and maintained on file.
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