Fall Protection Program administrators from each center joined NASA’s Construction Safety Working Group at Kennedy Space Center (KSC) June 2-3 to provide valuable input on one of the most dangerous work activities in construction. The group members helped focus this second annual face-to-face on fall protection, including discussions on requirements, rescue plans and training. 

“Falls are one of the number one causes of fatalities in construction, so it’s important to discuss fall protection and involve the community,” explained Vanessa Pellegrino, Occupational Safety subject matter expert with Alphaport, Inc.

Previously, the Space Shuttle Program handled the procurement, development and standardization of a singular fall protection process. With the agency moving on to new programs and projects after the end of shuttle, the Construction Safety Working group is having to explore new processes for fall protection, including policies and training.

An expert from the Naval Facilities Engineering Command gave a presentation on changes and updates to ANSI/ASSE Z359, Fall Protection Code, and EM 385-1-1, Section 21, Safety and Health Requirements Manual. The group followed the presentation with an in-depth review of when NPR 8715.3C, NASA General Safety Program Requirements, requires adoption of ANSI/ASSE Z359 to ensure that everyone understands agency expectations. Another expert from LIB, Inc., provided tips for developing and conducting rescue plans. Rescue plans, which explain what to do if someone falls, need to be in place before work begins.

Other fall protection discussions focused on training for qualified persons. Although the agency has sufficient training for fall protection users and competent persons (people on a construction site with the authority to take action to remedy hazards should they see something unsafe), there is a lack of NASA training for qualified persons (people on a construction site with a solid understanding of the requirements and systems, as well as an engineering background). Because each center only needs a few people trained at this level, it’s not reasonable or economical to develop training at the center level. Currently, many centers send employees to external training to be qualified, but these courses can be lengthy and expensive.

“We need an internal capability to train qualified persons,” said Gerry Schumann, the working group chair. “We want to develop our own training and are exploring different options, like train-the-trainer, to get an effective and cost efficient program up and running.  We also want to focus on fall prevention efforts for the agency.”

The working group is looking into a variety of delivery-methods for the course as well, including developing a hybrid course where part is taught in the classroom and part is taught online.

“We’re looking at how we can do the training virtually, or even live-virtually so people don’t have to travel,” said NASA Safety Center Operational Safety Technical Discipline Team Lead Jerry Piasecki.

Confined Space

The Occupational Safety and Health Administration (OSHA) recently released a new confined space standard, 29 CFR 1926, Subpart AA. An OSHA compliance officer presented to the group on the new standard. Prior to Subpart AA, there was no standard for confined space in construction.

Subpart AA will affect how prime contractors, referred to as the controlling employer, communicate with both the host (NASA) and its subcontractors. 

To learn more about the new Confined Space standard, take a look at a presentation given by OSHA Compliance Assistance Specialist Joan Spencer at KSC. 

Confined Spaces in Construction

Taking Responsibility

The group also discussed how to handle multi-employer worksites. When a worksite involves the government, a prime contractor and any number of subcontractors and something goes wrong, who is ultimately accountable?

“It’s easy to get wrapped around the axle with this, and the government tries to claim ownership for everything,” said Piasecki. “But that doesn’t help anyone.”

“There’s a philosophy on who’s responsible, but people need a refresher,” added Schumann. “Who’s accountable is after the fact. We want to look at it now, before something goes wrong, and determine who can affect change — it’s hard with so many people involved.”

The philosophy is that the person who generated or created the hazard is responsible for communicating it to workers, making recommendations on how to work safely and providing necessary protective equipment. For example, if a contractor is completing road work at a NASA facility and there happens to be toxic chemicals at a nearby facility that workers could be exposed to, NASA “owns” that hazard. However, if the contractor tears up the road and creates a temporary hazard, the contractor “owns” the hazard created by the hole in the ground. (For more information, including details on the employers that can be held accountable for creating, controlling, exposing and correcting hazards, check out OSHA’s Multi-Employer Citation Policy.)

Members plan to continue exploring options for communicating tips on how to handle multi-employer worksites.

Future Plans

The group is developing a plan for an agency-level fall protection standard with best practices for operating a safe worksite. The guide will be similar to others in the Institutional Safety discipline, such as the standard for lifting devices and fire protection.

Members also are reviewing ANSI/ASSE 359 to determine which pieces the group would like to adopt for the upcoming revision to NPR 8715.3, General Safety Program Requirements.

“We’re going to pick and choose the procedures we want to require at the agency-level at NASA,” said Pellegrino.

The group will continue its bi-monthly telecom meetings to collaborate on these items until next year’s face-to-face at Ames Research Center.