Initially implemented by ISEA, the group representing manufacturers of safety equipment, the dropped object standard was adopted by ANSI, resulting in ANSI/ISEA 121-2018. The standard "establishes minimum design, performance, testing, and labeling requirements for solutions that reduce dropped objects incidents in industrial and occupational settings."
This standard covers a specific and deadly hazard, and let me tell you that it is absolutely important. Not only have I personally investigated this type of incident, but I've had a very personal near miss when working at the base of a 90-foot high grain elevator. A co-worker dropped a nail puller from that height and it missed me by less than an inch – I felt it go by before it landed. I still remember seeing it stick through a half-inch sheet of plywood flooring at my feet. Worse, that was in the days before hardhats were required!
Like other work hazards at heights, dropped objects are manageable and preventable. The changes the standard details are not complex in terms of the work. In my opinion, the two most significant needs are:
- To ensure you have done your due-diligence regarding the work you do and the tools and equipment you use – and drive this change through your company, sub-trades, and supply chain
- Training and education, performance review, inspection, and compliance enforcement
But let's look at it more closely. If anyone in your organization works at heights, here's what you need to know about the dropped object standard.
What Does ANSI/ISEA 121-2018 Cover?
The standard covers four specific categories of equipment used at heights:
- Tool attachments
- Tool tethers
- Securing containers
- Anchor attachments
What counts as heights in this case? OSHA regulations for fall protection vary by industry and task. And when workers need fall protection, they should also be using dropped object protection.
In construction, fall protection is needed when workers are working six feet or higher off the ground. Workers, then, don't have to climb to extreme heights before dropped objects become a real concern.
(Find out at what height falls become deadly.)
Why Do We Need This Standard?
In the world of safety, the rules, regulations, standards, and codes are unfortunately written in numbers, costs, and blood. Many manufacturers and companies have long recognized the need to take proactive measures to prevent dropped object incidents; however, standards are required to help force active change in an industry-wide capacity.
A dropped object standard is crucial. Just take construction, for example. In 2017, 44 of the 971 fatalities in construction were caused by dropped objects. And as with every hazard, there are costs associated with these incidents, both as a result of property damage and injuries to workers.
How Does the Dropped Object Standard Related to OSHA Regulations?
ANSI/ISEA 121-2018 is not directly enforceable by OSHA, but it is recognized as an industry best practice. That means OSHA can reference an ANSI/ISEA standard (or other consensus standard) in a letter of interpretation or cite an employer under the General Duty Clause, Section 5(a)(1), which requires employers to maintain a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm” to employees.
The standard is not currently a law, but it may become one in the future. Many regions, industries, and companies are taking measures to implement this best practice, which could pave the way for legislation.
Complying with the General Duty Clause
The criteria for a General Duty Clause violation include:
- There must be a hazard
- The hazard must be recognized
- The hazard causes or is likely to cause injury or death
- The hazard must be correctable
If you work in an environment where workers or others are at risk of being hit by something that falls, you must do the following:
- Secure tools and materials to prevent them from falling on people below
- Barricade hazard areas and post warning signs
- Use toe boards and screens on guardrails or scaffolds to prevent falling objects
- Use debris nets, catch platforms, or canopies to catch or deflect falling objects
(Learn about The 3 T's of Dropped Object Prevention.)
What Safety Managers Need to Ask Themselves
If you're a safety manager, here are some of the questions you should seek answers for when it comes to dropped objects. The list might not be exhaustive, but it's a great place to start.
- Does your organization perform work at heights?
- Does your current documented hazard and risk analysis include dropped objects?
- Are your tool and equipment suppliers and manufacturers working to provide equipment that meets ANSI/ISEA 121-2018?
- How much do you need to modify your existing fall protection, working at heights, worker training and education to include this new standard?
- Does your current contract for subcontractors and tradespeople contain language that speaks to dropped object prevention?
- Do you have an inventory of your tools and equipment, including securing containers used at heights and existing permanent and temporary anchors that will need to be inspected to determine if they will meet the requirements of the standard?
- Will your task and job analysis, field level risk assessments, and other similar processes need to be changed?
- What will senior managers and finance need to know about the impact and costs of this standard on the budget, bids, and the bottom line?
|Free Download: 5 Big Facts to Know About ANSI/ISEA 121-2018 |
Additional Things to Consider
ANSI/ISEA 121-2018 does not specify when a worker needs to tether equipment or what equipment needs to be tethered. That decision is left up to the company and the safety manager. That means a policy, procedure, and performance review is in order.
Manufacturers do not have to make equipment that meets the standard. It is up to safety professionals to find manufacturers and suppliers who are already producing compliant products or can provide them.
I have spent a long time in the business, and one of the most important lessons I've learned is that OHS standards, regulations, acts, codes, and laws ensure successful, high quality, profitable, world-class performance. Safety managers know what that means: people get to go home at the end of the day, and they have a place to go back to work safely tomorrow.