Working at Heights

Policy Statement

This policy is intended to provide direction for all City of Toronto divisions to protect employees who work at heights.

The hierarchy of controls shall be considered and applied to hazards associated with working at heights. Refer to Appendix A for an illustration of the hierarchy of controls.

Application

This policy applies to all City of Toronto employees who may be working from heights and exposed to a fall:

  • More than 3 metres (10 feet),
  • More than 1.2 metres (4 feet) if work area is used as a path for a wheelbarrow or similar equipment,
  • Into operating machinery,
  • Into water or another liquid,
  • Into or onto a hazardous substance or object, or
  • Through an opening on a work surface.

A guardrail system must be used if an employee may be exposed to a fall of 2.4 metres (8 feet) or more and have access to the perimeter or an open side of any of the work surfaces listed below:

  • A floor, including the floor of a mezzanine or balcony,
  • The surface of a bridge,
  • A roof while formwork is in place, or
  • A scaffold platform, work platform, runway or ramp.

A barrier at least 1.1 metres high shall be provided at the top of every wall of an excavation that is not sloped, if the excavation is more than 2.4 metres deep and there is the risk of a person falling in.

For situations involving contractors, refer to the Managing Health and Safety Aspects of Contracts for Services policy.

Definitions

Anchorage

A secure connecting point capable of safely withstanding the impact forces (weight capacity) applied, as applicable, by a fall arrest, fall restricting or fall prevention system, or anchorage subsystem.

Bottoming out

A situation when a falling worker hits the ground or other object before the fall is arrested. Refer to Appendix B for an illustration on Fall Arrest Hazards.

Competent person

A person who is qualified because of knowledge, training and experience to organize the work and its performance; is familiar with the Occupational Health and Safety Act and the regulations that apply to the work; and has knowledge of any potential or actual danger to health or safety in the workplace.

Construction

Includes erection, alteration, repair, dismantling, demolition, structural maintenance, painting, land clearing, earth moving, grading, excavating, trenching, digging, boring, drilling, blasting, or concreting, the installation of any machinery or plant, and any work or undertaking in connection with a project but does not include any work or undertaking underground in a mine.

Fall arrest system

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.

Fall restricting system

A type of fall arrest system that has been designed to limit a worker’s fall to a specified distance.

Fall prevention

A system that prevents or eliminates the hazard of a fall.

Fall protection

Equipment used to mitigate or limit the effects of a fall from a height. Fall protection does not stop the fall; it is equipment used by employees to limit the distance and effects of a fall when working in an area where a potential fall exists.

NOTE: Fall prevention and fall protection are two different systems to protect employees.

Fixed support

A permanent or temporary structure or a component of such a structure that can withstand all loads and forces the structure or component is intended to support or resist and is sufficient to protect a worker’s health and safety, and includes equipment or devices that are securely fastened to the structure or component.

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.

Guardrail system

An assembly of components joined together to provide a barrier to prevent a worker from falling from the edge of a surface.

Project

A construction project, whether public or private, including,

  1. The construction of a building, bridge, structure, industrial establishment, mining plant, shaft, tunnel, caisson, trench, excavation, highway, railway, street, runway, parking lot, cofferdam, conduit, sewer, watermain, service connection, telegraph, telephone or electrical cable, pipe line, duct or well, or any combination thereof,
  2. The moving of a building or structure, and
  3. Any work or undertaking, or any lands or appurtenances used in connection with construction.

Safety belt

A belt worn around the waist of a worker and all the fittings for the belt appropriate for the use being made of it.

Safety factor

The ratio of the failure load to the specified load or rated load. Refer to Appendix C for a Safety Factor illustration.

Safety net

A safety net that complies with section 26.8 of Ontario Regulation 213/91, and is located and supported in such a way that it arrests the fall of a worker who may fall into it without endangering the worker.

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.

Work belt

A belt that has a back support pad and a connecting hook at the front and that is capable of supporting a worker.

Training

The Ministry of Labour has outlined the training requirements for workers on construction projects who use any of the following methods of fall protection:

  • Travel restraint systems,
  • Fall restricting systems,
  • Fall arrest systems,
  • Safety nets, and
  • Work belts or safety belts.

These workers are required to complete a working at heights training program that has been approved by the Chief Prevention Officer (CPO) and delivered by a CPO approved training provider before working at heights.

Workers who work at heights, but do not meet the criteria outlined by the Ministry of Labour for Working at Heights certification, are to receive appropriate alternative training, such as the City of Toronto’s Fall Protection Awareness course in combination with appropriate practical training.

Additional training considerations must be given when scaffolding, ladders and elevated work platforms are utilized.

Responsibilities

Senior managers will ensure that:

  • All areas where there is a potential injury due to working at heights are identified
  • Procedures and processes to support implementation of this policy are developed
  • Procedures and processes are regularly reviewed after relevant workplace changes and after all falls or near falls
  • There is budget for:
  1. The installation and maintenance of equipment and building structures as required by this policy and occupational health and safety regulations
  2. Personal protective equipment for use by workers (NOTE: This equipment is typically stocked by the Purchasing and Materials Management Division (PMMD) City Stores
  3. Ministry of Labour approved training, when required
  • Fall arrest rescue procedures are developed (see Appendix D for a Sample Rescue Procedure and Appendix E for a Sample Site-Specific Fall Protection Work Plan)
  • Education and training is provided to ensure workers and supervisors understand and properly fulfill their role in fall protection and prevention
  • Equipment inspection and record keeping processes are in place
  • Ensure that a process is in place for certification by a professional engineer for equipment and systems, when required, and that corrective actions are taken to address identified deficiencies

Managers/supervisors will ensure that:

  • Work requiring the use of fall arrest, fall restricting, travel restraint equipment must not be performed alone
  • Hazard assessments are conducted to identify situations where workers will work at heights
  • Workers who work at heights and meet the criteria outlined by the Ministry of Labour receive CPO approved Working at Heights training before working at heights
  • Workers who work at heights, but who do not meet the criteria outlined by the Ministry of Labour for Working at Heights certification, are to receive appropriate alternative training, such as the City of Toronto’s Fall Protection Awareness course in combination with appropriate practical training (e.g. using specific equipment)
  • Workers are informed about fall hazards and how to work safely at heights
  • Workers are trained on the appropriate fall arrest, fall restricting and/or fall prevention systems and its inspection and use
  • Workers are trained and comply with this policy and relevant procedures
  • Equipment used for working at heights are:
  1. Inspected by a qualified person before use on each work-shift
  2. Inspected by a competent person annually with a written record to validate approval for continued use (refer to Appendix F for a sample inspection checklist)
  3. Inspected as per the manufacturer’s instructions
  4. Kept free from substances and conditions that could contribute to its deterioration
  5. Maintained in good working order
  • Permanent anchor points, as part of buildings, are inspected by a Professional Engineer annually and records are maintained
  • Temporary anchor points are inspected by a competent person prior to use
  • Any equipment that has arrested the fall of a worker is removed from service and is not returned to service until it has been inspected and recertified as safe for use by the manufacturer or its authorized agent, or by a Professional Engineer
  • Equipment that is removed from service must be destroyed prior to disposal
  • Follow the division’s established record keeping process

Workers shall:

  • Comply with regulations, this policy and the divisional fall protection procedures and work plan when working at heights
  • Attend all mandatory training
  • Participate in fall protection planning where relevant and when requested
  • Alert the supervisor about any unknown or unexpected fall hazards before beginning or continuing any work
  • Wear and use all equipment, clothing or devices in accordance with information and instruction provided
  • Inspect equipment before use and verify the annual inspection date is within the last twelve months
  • Protect the protective equipment from damage and keep equipment free from substances and conditions that could contribute to its deterioration (e.g. protect the equipment from sharp edges, heat, flame or corrosive substances)
  • Report to management any broken, defective or missing protective equipment or building structures
  • Maintain equipment in good working order
  • Maintain one hundred percent fall protection connection at all times when they are at risk of a fall
  • Ensure that any equipment that has arrested the fall of a worker is removed from service and that the occurrence is reported immediately to the supervisor

Joint Health and Safety Committees/Health and Safety Representatives will:

  • Include Working at Heights provisions in their monthly workplace inspections, where applicable, and report to management any identified deficiencies with working at height equipment or building structures (there is information in the JHSC Checklist that may assist in this process)
  • Review fall protection work plans and make recommendations for improvement, where appropriate

Occupational Health and Safety staff will:

  • Provide assistance to divisions in identifying hazards and developing site-specific programs and work plans, upon request
  • Assist divisions in accessing Ministry of Labour approved Working at Heights training, when such training is required
  • Deliver Fall Protection Awareness training as well as assist in workplace-specific training, upon request

Appendices

Fall Hazard Hierarchy of Controls Illustration (Appendix A)

Fall Arrest Hazards (Appendix B)

Safety Factor Illustration (Appendix C)

Sample Rescue Procedure (Appendix D)

Sample Site-Specific Fall Protection Work Plan (Appendix E)

Authority

The Occupational Health and Safety Act R.S.O. 1990, c. 0.1.

Construction Projects Regulation O. Reg. 213/91.

Industrial Establishments Regulation O. Reg. 851.

Occupational Health and Safety Awareness and Training Regulation O. Reg. 297/13.

Endorsed by

Occupational Health and Safety Coordinating Committee (OHSCC), December 4, 2019

Approved by

City Manager

Date Approved

January 29, 2020