Application of System Safety to Prevention of Falls from Height in Design of Facilities, Ships and Support Equipment for Weapons Systems

by Mark B. Geiger, M.S.E., CIH, CSP, Arlington, Virginia

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Manpower Costs and Their Link to Safety
Operations that are unsafe are also often inefficient. Workers are often capable of overcoming hazardous situations through extreme care and labor-intensive, specialized procedures. Thus, mishap statistics may be lower than would be predicted by the configuration of the work area [Ref. 10]. This may be the case for falls in confined spaces.

Because available statistical information about falls in shipyard confined spaces was incomplete, an evaluation of work tasks was used to identify relative efficiency provided by alternative configurations.

By conducting a detailed review of work process, man-hour costs and time associated with the present and a proposed configuration [Ref. 9], operations were reviewed for a "typical" shipyard maintenance involving entry of and refurbishing 30 large storage tanks. Savings of approximately 30% or $250,000 per shipyard period were projected. This is estimated to amount to approximately $2.5 million over the life of an individual ship.

Fall Protection in Building Design and Construction
Falls from height account for approximately 40% of English construction industry accidents [Ref. 2]. OSHA reports that 32% of construction deaths (335 of 1,048 fatalities in 1995) are linked to falls from height⁹.

Safety should be incorporated into design in order to reduce both risk and cost [Ref. 11]. In the construction industry, safety includes both design of the facility against failure, and protection of the workers involved in that process. Work at elevated heights and the associated need for fall protection are key elements of building construction and maintenance. In a chapter written by Craig B. Schilder in the book Innovations in Safety Management: Addressing Career Knowledge Needs, Schilder addresses fall protection for both construction and maintenance in the context of system safety and cites the Construction Industries Institute (CII) software program "Design for Safety Toolbox,"¹⁰ addressing design issues. He also has provided a general checklist for building design review that includes fall protection [Ref. 12]. The Naval Facilities Engineering Command (NAVFAC) [Ref. 3] provides one of the most detailed guidelines for addressing fall prevention during planning and design. This reference specifically addresses the responsibilities of designers, construction managers and facility owners to create and maintain a safe working environment with particular reference to potentially lethal hazards addressed by fall protection programs. The European Senior Labor Inspectors Committee has focused upon this issue in cooperation with the U.K.'s Health and Safety Executive.¹¹

Many of the more progressive construction firms and process-engineering consultants have begun to address fall protection as a design element in design and operations. For example, an FAA contractor, Horne Engineering, broadened the concept of safety operations of the FAA air traffic control and communications network to include operator safety and fall protection for maintainers of communications towers and related equipment [Ref. 13].

Requirements for Life-Cycle Cost and Risk Management within Government Defense Systems and Facilities

The role of the U.S. federal government should be addressed because of the leadership role and economic influence it provides. Many systems acquired and maintained by the Department of Defense such as ships, aircraft¹², cranes, large vehicles¹³ and related support equipment and facilities include significant potential fall hazards. Additionally, the federal government and contractors who support federal acquisition efforts employ a high number of system safety practitioners.

Regulatory requirements relevant to federal and defense systems and supporting facilities include DoDI 5000.1 and DoDD 5000.2, acquisition regulations that specifically require cost and risk management throughout a program's life cycle to include design, testing, production fielding, maintenance and ultimate demolition/disposal or recycling. Federal Acquisition Regulations (FAR), Clause 52.236-13, states that contractors performing construction and demolition work on Department of Defense contracts are required to comply with the latest version of USACE EM385-1-1 (USACE 2003). This reference provides specific, enforceable programmatic requirements for Safe Access and Fall Protection (Section 21) and addresses the issue throughout other sections.

Early planning is documented as a key cost-control measure. The Naval Facilities Engineering Command's fall protection group has documented cost increases of a factor of 10 for each stage of fall protection design [Ref. 3]. For example, application of fall protection measures that would cost $1X at the drawing stage will increase to $10X if fall protection must be included after roof-mounted equipment is located and $100X if considered during the construction phase.

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