Compliance initiative results: suspended access equipment
Results of a province-wide enforcement initiative focused on suspended access equipment at construction projects from July 2 to September 27, 2019.
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From July 2, 2019, until September 27, 2019, the Ministry of Labour, Training and Skills Development (MLTSD) conducted a health and safety initiative focused on suspended access equipment (SAE).
To raise awareness of the hazards associated with use of SAE, we partnered with the Infrastructure Health and Safety Association (IHSA) to provide training, resources and education to workplace parties prior to and during the focused inspection blitz. The goal was to give workplace parties tools and knowledge to comply with health and safety requirements and prepare workplaces before the start of the blitz.
During the blitz, which ran from August 6 to September 27, 2019, inspectors conducted proactive field visits focused on ensuring workers using suspended access equipment were adequately trained in its use and given adequate oral and written instructions by a competent person and that the suspended access equipment had been designed, constructed, inspected, tested and maintained according to the law.
- conducted 217 field visits including 32 field visits with support role activities
- visited 155 construction projects
- issued 504 orders and requirements under the Occupational Health and Safety Act (OHSA) and its regulations, including 77 stop work orders
Inspectors checked that workers had been adequately trained on inspection and use of fall protection equipment used on the job, and that they had a valid working at heights (WAH) training certificate, as required.
Inspectors checked that employers were complying with the OHSA and its regulations at construction projects. This included checking that employers were taking appropriate action to assess and address hazards to protect workers.
The goals of the inspection blitz were to:
- raise awareness of health and safety hazards associated with using suspended access systems. Hazards could be found in installing, dismantling, inspecting and operating the equipment, and from WAH
- verify regulatory training requirements were met and that fall protection equipment was used properly
- increase workplace compliance with the law
- help to prevent injuries and illness that could arise from unsafe work practices
Suspended access equipment (SAE)
Workers can suffer serious injuries and death as a result of falls when SAE is improperly used and maintained. Over the past decade, there have been a number of serious incidents involving workers falling at construction workplaces in Ontario.
We chose the summer to raise awareness and conduct an SAE blitz because summer is when most SAE is used to do repairs. The timing was also appropriate to complement the ministry’s slips, trips and falls all-sector initiative, which finished on July 12, 2019. In addition, it has been two years since the regulatory changes for SAE in construction came into force and the blitz was an opportunity to follow up on the industry’s compliance with the changes.
Workplace inspection blitzes
Inspection blitzes are part of our Safe At Work Ontario compliance strategy. We announce to the sector in advance that we will be doing a blitz, although individual workplaces are not notified in advance. We typically post the results online within 90 days. Inspectors' findings may impact the number and level of future inspections of individual workplaces.
Inspectors may also refer employers to health and safety associations for compliance assistance and training.
From August 6 to September 27, 2019, inspectors visited construction projects across Ontario to check for compliance with the OHSA and sections 137 to 142.06 of O. Reg. 213/91: Construction Projects related to SAE. Inspectors checked that:
- SAE was designed, constructed, inspected, tested and maintained according to the law and that the components were compatible and in good condition
- workers received appropriate training to use/operate and install the SAE
- workers on SAE had received the Chief Prevention Officer (CPO) approved WAH training from a CPO-approved training provider as well as system specific training in the use of the particular fall protection system on the project
- daily pre-use inspections on the system components and anchorage connectors were conducted to identify defects prior to each day’s use
- a copy of the roof plan for the building or structure and a written assessment by a professional engineer (P. Eng.), that the roof anchor fixed supports were adequate for the purposes of attaching SAE and lifelines
- adequate public way protection was in place while overhead work on SAE was taking place
Inspectors took appropriate action if violations were found under the OHSA or its regulations, including:
- writing orders to employers, supervisors and workers for matters of non-compliance with the legal requirements
- issuing stop work orders where the inspector determined that the immediate health and safety of workers was at risk and requiring employers to comply with legal requirements before work could continue
In instances where SAE in use was not in compliance with the legislated requirements, including manufacturers’ instructions, inspectors issued orders to comply. Where compliance was questionable, they issued requirements for employers to provide additional information to make sure of the adequacy of the system and that the workers using it were protected.
Visits to projects
During the SAE blitz inspectors:
- conducted 217 field visits including 32 field visits with support role activities
- issued 504 orders and requirements:
- 485 orders for violations under the OHSA and its regulations
- 19 requirements to provide an inspector with workplace information
- issued an average of 3.25 orders and requirements per workplace visited
- issued an average of 2.34 orders and requirements per visit
Most frequently issued orders
The most frequently issued orders under O. Reg. 213/91: Construction Projects, were for:
- not wearing safety hat while working at the project [s. 22(1)]
- no guardrail installed where a worker has access to the perimeter, or open side of a work surface and exposed to a fall of 2.4 meters or more [s. 26.3(1)]
- a guardrail was in place but did not meet the regulatory specifications [s. 26.1(1)]
- workers did not receive system specific training on the type of fall protection being used [s. 26.3(2)]
- there was an uncovered opening on a work surface that a worker may fall through [s. 26.3(2)]
- failure to ensure a competent person prepared a written emergency rescue procedure before the first use of the SAE on the project [s. 141.5(1)(a)]
- failure to ensure a competent worker developed in writing a site-specific work plan before the first use of the SAE on the project [s. 141.5(1)(c)]
- failed to protect the lifeline from damage and abrasion while operating SAE [s. 142.06(3)(c)]
- failure to submit a notice of project to the MLTSD [s. 6(3)]
- worker not wearing fall protection personal protection equipment (PPE) as required when exposed to a fall [s. 26.1(2)]
- failure to complete an approved notification form and provide it to the ministry at least 48 hours before a suspended work platform system is used for the first time at a project [s. 7.1(2)]
The most frequently issued orders under the OHSA — 77 of 107 — were stop work orders under subsection 57(6). The 77 stop work orders issued were associated with 114 serious contraventions which the inspector deemed an immediate hazard to the health and safety of workers at the project.
Stop work orders associated with the contraventions under the SAE section of O.Reg. 213/91 included, but were not limited to, the following:
- no P. Eng. written document on the project stating that the fixed anchors on the building or structure met the requirements of clause 10.1.2 (Roof Plan) of CSA Standard Z271-10 and were adequate for the purposes of attaching work platforms, boatswain’s or bosun’s chairs (BC) and lifelines (s.141.2)
- no site-specific work plan complete with risk assessment (hazard identification) and emergency rescue procedures developed by a competent person before the SAE was put into service. (s.141.5)
- no site-specific written installation inspection report signed and sealed by a P. Eng. stating that the suspended work platform system (SWPS) was installed as per the site-specific drawing prior to the SWPS being put into service (s.141.8)
- no written installation inspection report by designated competent worker (DCW) confirming that the SWPS is installed as per the manufacturer’s generic installation drawings (s.141.7)
- no suspension line termination testing record for each wire rope termination (per termination) as per manufacturer's instructions, and/or to a maximum of 50% (s.142.02)
- a suspension line with a connecting end without a thimble adequately fastened (s.142.01).
- no evidence daily pre-useinspection was performed to identify if any defects / hazardous conditions in writing; SWPS/BC (must not be used until corrected/removed; keep a copy of inspection report for inspector review (s.142.04)
- lifeline not secured to independent fixed anchor fixed/support so that it will not fail if SAE fails (s.142.06)
- no system specific fall protection (PPE) training delivered to workers prior to the system being used [s.26.2(1)]
Compliance with SAE section of O. Reg. 213/91
Only two orders were issued under sections 138 and 138.1 training for users and installers of SAE. This shows that industry understands how critical training is to worker safety when using SAE on a project. However, based on the most frequently issued orders related to SAE, there appeared to be confusion regardinginspections, testing and maintainence requirements for SAE under the regulation. Also there was confusion over when engineered installation inspections are required versus when inspections by a DCW are sufficient prior to first use of SAE on a project. In addition, employers or trained workers are not ensuring the following requirements are met prior to using SAE on a project:
- the DCW prepared a written emergency rescue procedure
- the DCW developed in writing a site-specific work plan which included hazard assessment
- lifelines are protected from damage and abrasion while operating SAE
- an approved notification form is completed and provided to the ministry at least 48 hours before a suspended work platform system is used for the first time at a project
Other compliance issues
Our inspectors also audited the entire workplace for compliance with the construction regulation as part of a broader strategy to improve workplace health and safety. Based on the most frequently issued orders, it appears that compliance with fall protection continues to be an issue. Although few orders were written for no WAH training, it appears that employers are still failing to provide workers with adequate oral and written system specific training. Guardrails are not being used when practicable as the best protection against falls from heights or if guardrails are in place, they are not adequately built/installed to the requirements under the regulation.
Conclusion and next steps
The results indicate hazards related to SAE continue to be a key concern at construction projects.
We will continue to raise awareness of falls hazards, encourage the establishment of a strong internal responsibility system in every workplace, and be receptive to stakeholders’ suggestions and input towards achieving safer and healthier work environment.
Help for employers
Please contact our health and safety partners for more information on identifying, preventing and controlling these hazards.
The Infrastructure Health and Safety Association’s page on suspended access equipment has many free resources including fact sheets, risk assessment and work plan templates. They also provide training (fee required).
Learn more about:
- health and safety awareness products and training for workplace parties
- training for working at heights
For more information contact the Ministry of Labour, Training and Skills Development Health & Safety Contact Centre at
Always call 911 immediately in an emergency.
- footnote Back to paragraph Activities in which professional services staff (e.g. a hygienist, ergonomist, engineer etc.) or another inspector accompanies an inspector on a field visit to provide professional support and/or expertise.
- footnote Back to paragraph Activities in which professional services staff (for example, a hygienist, ergonomist, engineer etc.) or another inspector accompanies an inspector on a field visit to provide professional support and/or expertise.