Guideline No. 21: Working at heights
This guideline makes reference to the provisions regarding working at heights in the (Regulation for Industrial Establishments Reg. 851) and the (Regulation for Construction Projects O. Reg. 213/91) and also outlines best practices, procedures and equipment for film and television production.
The Regulation for Construction Projects applies during the installation / erection and removal of stages, set, sound systems and lighting systems for film and television production. The Regulation for Industrial Establishments applies while filming is in progress and while moving pre-constructed sets and stages related to an on-going production. In addition, the Regulation for Industrial Establishments applies during the manufacturing of sets in a shop prior to being transported to the venue.
I. Risk assessment
- A competent person should assess the risks associated with any job task and identify, control or eliminate any fall hazards.
- The best option for eliminating a fall hazard is a guardrail system. A worker shall be adequately protected by a guardrail system that meets the requirements of the Regulation for Construction Projects or the Regulation for Industrial Establishments.
- When the fall hazard cannot be eliminated, then the hazard shall be controlled by using a fall protection system in accordance with the Regulation for Construction Projects or the Regulation for Industrial Establishments.
II. Hazard recognition
The Regulation for Industrial Establishments (including sections 13, 14 and 85) applies after the construction/erection of the set/stage has been completed. Section 85 applies where a worker is exposed to the hazard of falling and the surface to which he or she might fall is more than three metres below the position where he or she is situated. Section 13 sets out the situations where guardrails are required and section 14 outlines the specifications of a guardrail.
The Regulation for Construction Projects (including ss. 26.1-26.9) applies to construction projects and including the installation/erection and removal of stages, set, sound systems and lighting systems. The protection in the regulation relating to fall hazards apply where a worker is exposed to any of the following hazards including but not limited to:
- falling from a height of more than 3 metres (approx. 10 feet)
- falling into operating machinery
- falling into water or another liquid
- falling into or onto a hazardous substance or object
- falling though an opening in a work surface
- The Regulation for Construction Projects (ss 26.2(1) ) states: “An employer shall ensure that a worker who may use a fall protection system is adequately trained in its use and given adequate oral and written instructions by a competent person.” Section 79 of the Regulation for Industrial Establishments requires that workers required to wear protective equipment such as fall protection equipment shall be instructed and trained in the care and use before wearing such equipment.
- Among other things, employers shall ensure that:
- training records are kept, including participants’ names and training dates; (s. 26.2(2)&(3))
- the training records are available to Ministry of Labour, Training and Skills Development inspectors on request. (s. 26.2(4))
IV. Rescue plan
- According to the Regulation for Construction Projects (ss 26.1(4)) written rescue procedures must be in place before a fall arrest system or a safety net is used. In addition, a rescue plan should be in place whenever a fall protection system is used. The plan should be posted in a conspicuous place. (For more detailed information, see the section “Rescue Plan” below.)
Definitions of terms used in this guideline
- Aerial or elvating work platforms
- Hydraulic or electrical controlled devices used to elevate personnel or materials. In the film and television production, these include: scissor lifts, articulated boom lifts, individual personnel lifts, self-propelled lifts, manual "push-around" lifts, elevating rolling work platforms, self-propelled elevating work platforms, boom-type elevating work platforms, and vehicle-mounted aerial devices.
- Certified by a professional engineer.
- Certified point of attachment for lifelines, lanyards or deceleration devices.
- A self-closing device used to connect various parts of personal fall arrest or work-positioning systems.
- Fall protection
- A method of minimizing the possibility of falling.
- Fall arrest protection
- An assembly of components joined together so that when the assembly is connected to a fixed support, it is capable of arresting a worker’s fall.(ss 1(1)of the Regulation for Construction Projects)
- Fall restricting system
- A type of fall arrest system that has been designed to a limited a worker’s fall to a specified distance. (ss 1(1) of the Regulation for Construction Projects)
- Full body harness
- A device that can arrest an accidental vertical or near vertical fall of a worker and which can guide and distribute the impact forces of the fall by means of leg and shoulder strap supports and an upper dorsal suspension assembly which, after the arrest, will not by itself permit the release or further lowering of the worker. (ss 1(1) of the Regulation for Construction Projects)
- Guardrail system
- An assembly of components joined together to provided a barrier to prevent a worker from falling from the edge of a surface. (ss 1(1) of the Regulation for Construction Projects)
- Flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage.
- A flexible line for connection to an anchorage at one end to suspend vertically (vertical lifeline), or for connection to anchorages at both ends to stretch horizontally (horizontal lifeline), and which serves as a means for connecting other components of a personal fall arrest system to the anchorage.
- Aerial or elevating work platforms.
- Climbing above a primary anchor point.
- Personal fall arrest system
- System used to arrest a worker in a fall from an elevation. It consists of an anchorage, connectors and full-body harness, and may include a lanyard, deceleration device and/or lifeline.
- Rope grab
- Deceleration device which travels on a lifeline and automatically, by friction, engages the lifeline and locks to arrest the fall of a worker.
- Rolling A-Frame Ladders
- An A-Frame ladder positively attached to a dolly board. The locking castor wheels are to be outside the profile of the ladder. Fall Arrest should be used if working beyond the ladder profile.
- Self-propelled elevating work platforms; Scissor lifts
- A portable work station which is moved along the floor/ground/deck by mechanical means.
- Self-retracting lifeline/lanyard
- A deceleration device that automatically adjusts its length under mild tension and arrests a fall.
- Travel restraint system
- An assembly of components capable of restricting a worker’s movement on a work surface and preventing the worker from reaching a location from which he or she could fall. (ss 1(1) of the Regulation for Construction Projects)
- Work positioning systems
- Aerial or elevating work platforms, ladders, boatswain’s chairs, and scaffolding.
Note:The definitions which have not been taken from the Regulation for Construction Projects are provided for convenience only and should not be interpreted to have legal significance.
- A worker shall be adequately protected by a guardrail system. Requirements for guardrails are found in the regulation for construction projects (s.26.1) . The regulation for industrial establishment (ss. 13 and 14) contains provisions for permanent guardrails. The regulation for construction projects provides that if it is not reasonably possible to install guardrails, a worker must be adequately protected by at least one of the following methods of fall protection:
- safety net
- travel Restraint system
- fall Arrest System
- fall Restricting System
- The following components of fall arrest, fall restricting, travel restricting, systems and safety net must be designed by a professional engineer in accordance with good engineering practice and meet the requirement of the following with CSA standards (or equivalent):
- Connecting Components for Personal Fall Arrest Systems CAN/CSA Z259.12-01
- Safety Belts and Lanyards CAN/CSA/Z259.1-95
- Full Body Harnesses CAN/CSA/Z259.10-M90
- Fall Arresters and Vertical Lifelines CSA Z259.2.5-12
- Self-Retracting Devices for Personal Fall-Arrest Systems. CAN/CSA-Z259.2.2-98
- Descent Control Devices. CAN/CSA-Z259.2.3-99
- Shock Absorbers for Personal Fall-Arrest Systems. CAN/CSA-Z259.11-M92
- Fall Restrict Equipment for Wood Pole Climbing. CAN/CSA-Z259.14-01
I. Passive systems
- Guardrails & Handrails: See above.
- Safety Net: The Regulation for Construction Projects outlines the requirements for safety nets in section 26.8.
- Orchestra Pit Protection Covers (See Orchestra Pits Guideline)
II. Travel restraint system
Travel restraint is a system which prevents a worker from physically reaching the fall hazard, thereby effectively eliminating the hazard. Key requirements for travel restraint systems can be found in section 26.4 of the Regulation for Construction Projects.
III. Fall arrest system
A Personal Fall Arrest System (PFAS) includes a full body harness, connector, lifeline, and certified anchorage components. Key requirements for fall arrest systems can be found in section 26.6 of the Regulation for Construction Projects and section 85 of the Regulation for Industrial Establishments .
For wire rope assemblies, synthetic slings or other components, refer to the manufacturer’s installation recommendations.
An anchor point should be independent of the supporting or suspension system of the worker.
Anchorage used for vertical fall arrest should be located directly above the work area.
A permanent anchor system used as the fixed support in a fall arrest system, fall- restricting system or travel restraint system must adhere to the Building Code and it must be safe and practical to use as a fixed support (s. 26.7(1) of the Regulation for Construction Projects) .
If the requirements for a permanent anchor system are not met, the minimum anchorage requirements for the temporary fixed support are outlined in the Regulation for Construction Projects (s. 26.7(2)) for:
- Permanent Anchor Points
- Temporary Anchor Points
- travel restraint
- fall arrest
- fall restricting
V. Vertical lifelines
Two typical examples are:
Note:Since these two examples are not specifically referenced in s.26.7(2) of the Regulation for Construction Projects, they may not necessarily indicate legal compliance
- Vertical Lifelines (VLL) are for vertical access or ladder protection. For specific requirements for lanyards or lifelines, see section 26.9 of the Regulation for Construction Projects.
- 5⁄8" diameter (three-strand or kernmantle) synthetic fibre rope, with compatible rope grab.
- 3⁄16" diameter Self-Retracting Lifeline (SRL) Independent Wire Rope Core (IWRC) wire rope, with fall-indicating snap hook.
- Vertical lifelines should be suspended separately from any work position or platform system, unless authorized by an engineer.
- Primary anchorage to a commercial lighting truss system is not recommended for any vertical lifeline system, unless authorized by an engineer.
- Overclimbing a self-retracting lifeline anchor point is not recommended by any manufacturer.
- An energy-absorbing lanyard should not be used in combination with a self-retracting lifeline, unless the lifeline manufacturer specifically includes one for use within the system.
- A self-retracting lifeline should be attached directly to the dorsal D-ring on a full-body harness. A sternal D-ring connection may be allowed in some applications for vertical ladder climbing only.
- Synthetic lifelines should not be used in direct proximity to pyrotechnics or high-heat luminaires.
- A self-retracting lifeline should not be stored in an extended position unless permitted by the manufacturer.
VI. Horizontal lifelines
Two typical examples of manufactured systems are:
Note: Since these two examples are not specifically referenced in s.26.9 of the Regulation for Construction Projects , they may not necessarily indicate legal compliance
- Horizontal Lifelines (HLL) installations include rigging grids and lighting systems. For specific key requirements for lanyards or lifelines, see section 26.9 of the Regulation for Construction Projects.
- 5⁄8"diameter (three-strand or kernmantle) synthetic fibre rope, with energy absorber, tensioning device and connecting O-rings.
- 3⁄8" diameter IWRC (independent wire rope core) wire rope, with energy absorber and tensioning device.
- Minimum anchorage requirements and vector force calculations vary by manufacturer. The interpretation of these calculations shall be made by a professional engineer. (For specific requirements for horizontal lifeline systems, see s. 26.9(8) of the Regulation for Construction Projects ).
- Snap hooks must be connected to the supplied O-ring on a synthetic horizontal lifeline.
- Commercially available horizontal lifelines should always be used as directed by the manufacturer.
- The number of workers using a horizontal lifeline system should not exceed the manufacturer’s specifications.
- Synthetic lifelines should not be used in direct proximity to pyrotechnics or high-heat luminaries.
Work positioning and access systems
Fall hazards may be avoided or reduced by using a work positioning system. Anyone working on an elevated work positioning system should be trained by a competent person.
Scaffolding must be erected in accordance with the manufacturer’s recommendations. Key requirements for scaffolding can be found in the Regulation for Construction Projects ss.125-142.8).
An external anchor point should be used by the worker when erecting scaffolding.
II. Elevating work platforms
For specific key requirements, refer to the Regulation for Construction Projects (s.143-149) and the Regulation for Industrial Establishments (s.52).
- All personnel shall be trained in the safe operation of any elevating work platform prior to use and shall use the equipment according to the manufacturer’s instructions.
- An elevating work platform shall only be used if it complies with the National Standards of Canada standard O. Reg. 213/91, s. 144 (1)(a)).
- A travel restraint system must be worn and attached to the engineered anchor point on the platform if workers are on platform when it is moved horizontally or vertically. (Regulation for Construction Projects O. Reg. 213/91, s.148 (e)). This guideline recommends the use of a full body harness at all times when working on a platform.
- An elevated work platform should only be operated on a strong, stable, horizontal and level surface unless permitted by the manufacturer (refer to operator’s manual).
- Do not modify an elevated work platform in any way unless permitted by manufacturer and certified by an engineer. This includes adding planks or ladders to an elevated work platform to gain additional height.
- Do not modify elevated work platform to override safety features.
- Never exceed the manufacturer’s rated capacity of an elevated work platform.
- A communication system and a rescue plan must be in place before a worker goes to height.
- The worker going to height should always control the elevated work platform. No ground-operated controls shall be engaged without the permission of the worker at height, except in an emergency.
- Elevated platforms should not be anchored or attached to a permanent structure while working at height.
- An elevated work platform should not be used as a crane unless specifically designed for that use.
- A forklift should not be used as an elevating work platform unless designed and permitted by manufacturer or approved by professional engineer (see #2). Section 52 of the Regulation for Industrial Establishments could also apply.
III. Boatswain's chair
- Boatswain’s chairs should be CSA approved.
- Refer to the key requirements in the (Regulation for Construction Projects ss. 137, 140 and 141) or the (Regulation for Window Cleaning Reg. 859) when using a boatswain’s chair.
- Every part of a hoisting and rigging system shall be capable of supporting at least 10 times the maximum load to which the part is likely to be subjected. ( Regulation for Construction Projects, s. 137(8))
- Workers in a boatswain’s chair shall wear a full body harness connected to a separate fall arrest system. (Regulation for Construction Projects, s. 141(1))
For specific key requirements, refer to the (Regulation for Construction Projects ss. 78-84) and the (Regulation for Industrial Establishments ss. 18-19 and 73).
- Select the proper ladder for the intended use.
- Inspect all ladders prior to every use to ensure structural integrity. Damaged or defective ladders should be removed from service.
- Use ladders on firm, level surfaces. Stabilize the base of the ladder to prevent slipping and/or moving. Ensure ground surfaces, rungs and steps are clear of slippery substances.
- Keep the base of the ladder clear for access and for traffic control. When necessary, use cones, tape, or a spotter to secure high traffic areas.
- Do not leave tools or materials on top of any ladder. Ensure personal tools are secure when climbing ladders.
- Straight or extension ladders should be installed on a 3:1 or 4:1 slope, e.g. one foot out at the base, for every four feet up.
- When working above three meters (10 ft), secure the ladder. The top of a straight or extension ladder should be secured to an independent anchorage to prevent lateral movement.
- Independent fall arrest is necessary when using a ladder as a work station above three meters (i.e. not when using a ladder to access another level.). This includes rolling A-frame ladders.
- Always face the ladder when climbing up or down. Always maintain 3 – point contact and avoid reaching beyond the side-rails of the ladder.
- Follow the manufacturer’s recommendations to determine which rungs of the ladder are appropriate to work from.
- Ladders made of non-conductive material should be used while working around energized wiring and equipment.
- When working in outdoor conditions extra safety measures must be taken.
- Never use ladders horizontally as scaffold planks or runways, unless they have been designed for that purpose.
Key requirements for lifting workers with cranes can be found in the (Regulation for Construction Projects s. 153(2)) and in the (Regulation for Industrial Establishments s. 52).
According to the (Regulation for Construction Projects s. 26.1(4)), written rescue procedures must be in place before any use of a fall arrest system or safety net is used. A rescue plan should be in place whenever personnel are working at height. This plan should be posted in a conspicuous place and communicated to all workers before work begins.
A rescue plan includes:
- The designated trained person(s) in charge of rescue.
- Qualified on-site first aid personnel (with contact numbers) and equipment (as per the Regulation for First Aid Requirements (Reg. 1101) under the Workplace Safety and Insurance Act, 1997).
- Names and contact phone numbers of Emergency Medical Services (EMS) or fire services resources in the jurisdiction.
- Emergency access to worksite.
- A back-up system of communications.
- All rescue or emergency control procedures for any mechanical hoisting systems or elevating devices being used in the workplace.
- Annual review and rehearsal of rescue procedures.
- Procedures to lock-out and secure activated safety devices and unsafe work areas.
Equipment inspection, maintenance and storage
- The Regulation for Construction Projects requires that a competent worker shall inspect a fall arrest system before each use ("s. 26.6(6)).
- Follow the manufacturer’s instructions and recommendations for equipment, including documentation, inspection schedule, maintenance, and storage. It is the duty of the owner and/or employer to ensure all equipment is inspected and maintained by a competent person. Follow the manufacturer’s warnings about retirement schedules. Replace items, even if unused, according to the manufacturer’s recommended retirement scheduling.
- If the integrity of any fall protection equipment is in doubt, it shall be retired from service permanently or repaired and re-certified by the manufacturer.
- Check with the manufacturer’s instructions before using any cleansers, markers, paint, stickers on synthetic materials or hardware.
- Store fall protection equipment to avoid moisture, abrasion, dirt, ultraviolet light, extreme temperatures and other hazards. Use appropriate containers to store equipment.
Appendix (useful terms)
- Deceleration device
- Any mechanism, such as a rope grab, rip-stop lanyard, integral lanyard, tearing or deforming lanyards, automatic self-retracting lifelines/lanyards, etc., which serves to dissipate a substantial amount of kinetic energy during a fall, and thus limit the arrest force.
- Deceleration distance
- The distance between the location of a worker’s full body harness attachment point at the moment of activation of the deceleration device during a fall, and the location of that attachment point after the worker comes to a full stop.
- Free fall
- The act of falling before a personal fall arrest system begins to activate.
- Free fall distance
- The vertical distance between the onset of the fall to the point where the fall arrest system begins to apply force to arrest the fall.
- Lower levels
- Areas or surfaces to which a worker can fall. Such areas or surfaces include, but are not limited to, ground levels, floors, platforms, ramps, runways, orchestra pits, traps, water, equipment, structures, or portions thereof.
- Gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide, in a wall or partition, through which employees can fall to a lower level.
- Connector comprised of a hook-shaped member with a self-closing keeper, or similar arrangement, which may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object.
- Low protective barrier that is an integral part of a guardrail system and will prevent the fall of materials or equipment to lower levels.
- Unprotected sides and edges
- Any side or edge (except points of access) of a walking/working surface, e.g., floor, roof, ramp, or runway where there is no wall or guardrail system at least 36 inches (0.9 m) high.
- Walking/working surface
- Any surface, whether horizontal or vertical on which a worker walks or works, such as floors, roofs, ramps, bridges, runways, but not including ladders.
- Warning line system
- Temporary demarcation erected to warn workers that they are approaching an unprotected edge. This shall outline an area at least 2 metres from a fall hazard in which work may take place without the use of guardrail or safety net systems to protect workers in the area. (May also be referred to as a "bump line".)
- Work positioning device system
- Full-body harness system rigged to allow a worker to be supported on an elevated surface and work with both hands.
Note: Many of these terms are referred to in the Regulation for Construction Projects and the Regulations for Industrial Establishments however, they are not defined in these regulations. These definitions are provided for convenience only and should not be interpreted to have legal significance.