Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.
A worker descending a vertical ladder on a water tower in 2014 was critically injured after falling five metres while properly using a Class Frontal-Fixed Rail Ladder (Class FRL) Fall Protection System. A Class FRL Fall Protection System is a type of vertical fall protection using a permanently installed metal rail anchoring system with an automatic fall arresting device called the "trolley" or "carriage".
The investigation revealed a weakness in the design of some Class FRL Fall Protection Systems, which may not adequately protect workers who fall backward or who squat and roll backwards into a fall while connected by a body harness to the trolley which slides along the vertical rail. If a worker leans back, the trolley’s internal braking system can be pulled off the rail, allowing the trolley to slide down the rail. If a worker falls backwards or squats and rolls backward into a fall (as opposed to falling straight down or inwards towards the ladder) the trolley may not lock, allowing a worker to fall freely. In the 2014 incident, the worker fell from a water tower ladder as shown in Figure 1.
Figure 1: How the water tower worker fell
In 2010, the Ministry of Labour published a similar Alert, Class Frontal Fixed Rail Ladder (FRL) Fall Protection System, Alert #26/0510, after a worker was injured after falling back, then down 20 metres from a ladder attached to a tower while using a Class FRL Fall Protection System. In 2010, the investigation determined that the Class FRL Fall Protection System might not adequately protect workers who fall backward in a standing position.
Class FRL Fall Protection Systems are used on vertical access ladders which normally do not have a cage, such as the ladders on communication towers, chimneys and water tanks (towers).
Even though a Class FRL Fall Protection System may be currently certified to CSA standards and/or have a CSA standards stamp on the side of the trolley unit, this should not be interpreted to guarantee worker safety and employers should not rely on such a stamp. Further investigations into the system are needed to ensure the system protects against a squatting position/rollback fall or a fall backwards.
Class FRL Fall Protection Systems whose design characteristics require the connection between the worker and the trolley to be in tension and where the trolley remains disengaged regardless of the tension force applied should not be used. Employers must take reasonable precautions to protect workers in these circumstances. This may include using alternative fall protection or access systems, as appropriate, for the adequate protection of the health and safety of workers using vertical access ladders.
Employers who own or rent structures which have a Class FRL Fall Protection System installed must ensure that the Class FRL Fall Protection System is capable of protecting a worker in the case of a squatting position/rollback fall or a fall backwards. The Ministry recommends that employers contact the manufacturer to ensure that the particular Class FRL Fall Protection System is capable of protecting a worker from any type of fall (including a backward fall and falling from a squatting position) before it is used.
Note: This Alert replaces the Class FRL Fall Protection System, Alert #26/0510 published in 2010 by the Ministry of Labour.
For more information contact:
Infrastructure Health and Safety Association
Or contact the Ministry of Labour Health & Safety Contact Centre toll-free at 1-877-202-0008.
For further reference see also:
Ministry of Labour
Remember that while complying with occupational health and safety laws, you are also required to comply with applicable environmental laws.
Please photocopy Ministry of Labour Alerts, distribute them widely and post them where people will see them.
Disclaimer: This web resource has been prepared to assist the workplace parties in understanding some of their obligations under the Occupational Health and Safety Act (OHSA) and the regulations. It is not intended to replace the OHSA or the regulations and reference should always be made to the official version of the legislation.
It is the responsibility of the workplace parties to ensure compliance with the legislation. This web resource does not constitute legal advice. If you require assistance with respect to the interpretation of the legislation and its potential application in specific circumstances, please contact your legal counsel.
While this web resource will also be available to Ministry of Labour inspectors, they will apply and enforce the OHSA and its regulations based on the facts as they may find them in the workplace. This web resource does not affect their enforcement discretion in any way.