1. DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION From Compliance to Commitment: Fall Protection, OSHA, and the At-Risk Worker 2016 Chicagoland Safety, Health and Environmental Conference

2. 2 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Workplace safety is a collective concern "No one should have to sacrifice their life for their livelihood, because a nation built on the dignity of work must provide safe working conditions for its people." --Thomas E. Perez, Secretary of Labor

3. 3 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Why Fall Protection Is Top Of Mind Fall protection is the fastest growing sector in the safety market $3.5 billion dollar market by 2020 Proposed changes to the IBC, new local building codes, increased OSHA enforcement efforts and higher fines are fueling interest in fall protection EHS professionals like YOU

4. 4 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Why Fall Protection Is Top Of Mind

5. 5 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Why Fall Protection Is Top Of Mind

6. 6 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Why Fall Protection Is Top Of Mind

7. 7 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The Cost of Fatal Workplace Accidents Centers for Disease Control estimates the hospital costs for a fatal injury--$991, 027 The National Safety Council—cost to society is $1.42 million per death Both Models Account For Direct Costs Only: workers’ compensation, medical expenses, civil liability damages, litigation costs, and OSHA penalties Indirect costs of workplace fatalities are even higher: workplace disruptions, loss of productivity, worker replacement and training, future workers compensation/insurance premiums, loss of key accounts, investor confidence, and workers leaving for safer jobs. All-In costs for workplace deaths average $3 million dollars per incident.

8. 8 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Non-Fatal Injury Costs According to Liberty Mutual’s 2016 Workplace Safety Index, the most disabling non-fatal workplace injuries cost US employers….Liberty Mutual’s 2016 Workplace Safety Index $62 billion in direct workers’ compensations costs—more than a billion per week Falls cost $15.5 billion per year in direct workers’ compensation costs

9. 9 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Fines Are Rising OSHA penalties were frozen…new structure: The Federal Civil Penalties Inflation Act excluded OSHA from raising fines based on annual inflation rate—result: no increase in penalties from 1990-2016. Higher Penalties Effective Aug 1, 2016 Citations other than serious violations are increasing from a maximum threshold of $7,000 to $12,600 Serious violations will increase from $7,000 to $12,600 Willful and repeat violations are rising from $70,000 to $126,000 OSHA is now eligible to make annual increases in penalties for non-compliance to keep pace with inflation

10. 10 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The Impact of Willful OSHA Violations July 2016--MHS Technical Services employee falls 22 feet to his death while working on conveyor equipment at a UPS hub. MHS has a track record of OSHA violations dating back to 2009, including a violation in the same UPS facility in 2015. Fines for serial disregard for fall protection totaled $320,000 Landing in OSHA’s Severe Violators Enforcement Program (SVEP) can haunt your company for years:OSHA’s Severe Violators Enforcement Program Lengthy Process To Be Removed From List Drain of Talent from Your Organization Some Companies Can’t/Won’t Do Business With Vendors That Have Poor Safety Records Publicly Traded Companies Take Hits—Lower Stock Prices

11. 11 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Top Ten OSHA Violations 2015 https://www.osha.gov/Top_Ten_Standards.html

12. 12 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Fall Protection Regulations (29 USC 654) OSHA General Duty Clause (Not Specific to Fall Protection) OSHA: Standards – 29 CFR- 1910-Occupational Health and Safety Standards for General Industry OSHA: Standards – 29 CFR- 1926 -Occupational Health and Safety Standards for Construction, Subpart M OSHA 1956.502(d)(20) --Rescue

13. 13 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Understanding OSHA’s General Duty Clause 29 U.S.C. § 654, 5(a)1: Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.“ Any recognized hazard created in part by a condition not covered by an existing OSHA regulation and there are no specific standards may be cited under the general duty clause Hazard may be recognized due to: Common knowledge based on the specific industry In plain view Or should be known by the employer

14. 14 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION General Duty Clause Standards Of Proof To Establish A Violation of the General Duty Clause, OSHA Must Prove: The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed The hazard was recognized The hazard was causing or was likely to cause death or serious physical harm There was a feasible and useful method to correct the hazard. A general duty citation must involve both the presence of a serious hazard and exposure of the cited employer’s employees Key Takeaway—Not having a knowledge of the specific violation is not an acceptable defense in the eyes of OSHA.

15. 15 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Fall Protection Regulations—FAQ’s Frequently Asked Questions… At what working heights does OSHA require the use of fall protection? General Industry (OSHA 1910) - 4 feet Construction Industry (OSHA 1926) - 6 feet Does working more than 6 feet from an unprotected leading edge eliminate the need for fall protection? The preamble to 29 CFR 1926, Subpart M states: “OSHA has determined that there is no safe distance from an unprotected side or edge that would render fall protection unnecessary”……but there are some exceptions…. That interpretation was the rule until July 23, 1996, when a letter of interpretation was written that stipulated for a low-slope roof, “However, when employees working 50 to 100 ft away from the unprotected edge have been properly trained, then the situation can be considered a de minimis condition.”

16. 16 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Understanding OSHA Fall Protection Regulations— Rescue Requirements OSHA 1956.502(d)(20) “The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.” Employers are required by law to have a full and comprehensive rescue plan in place for personnel working at height. Fall protection system may do its job—but your employee may die without a means of prompt rescue Dialing 911 is not a rescue plan OSHA does not specify a time limit for prompt rescue, but ANSI standards reference a six minute window to prevent orthostatic shock—a condition where pooling of blood in lower extremities can cause a fall victim to loose consciousness or die. https://www.youtube.com/watch?v=C_l2Y2KSjcA

17. 17 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The ABC’s of Fall Restraint and Fall Arrest Systems Anchorage – Body Harness – Connecting Device

18. 18 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The ABC’s of Fall Restraint and Fall Arrest Systems OSHA defines anchorage as a “secure point of attachment for lifelines, lanyards, or deceleration devices….” (Anchorages to which personal fall arrest equipment is attached shall be capable of supporting at least 5,000 pounds (22.2 kN) per employee attached… Or shall be designed, installed, and used as part of a complete personal fall arrest system which maintains a safety factor of at least two, under the supervision of a qualified person.

19. 19 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The 5,000 lb. Anchorage Requirement Explained Certified Anchors: 2x the applied load Non-Certified Anchors: 5,000 lbs Systems designed by a qualified person typically limit applied loads 900-1200 lbs Worst case scenario 2x 1200lbs – 2,400 lbs Key question to ask—is the structure used to attach the non-certified anchor rated at 5,000 lbs?

20. 20 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Qualified Person….. OSHA 29 CFR 1926.32(m)—A qualified person is an individual “who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” A qualified person has the training and expertise to calculate end loads, fall clearances, and determine the required quantity and location of intermediate and end-posts, and install or supervise the installation of the system Not every qualified person can determine if the structure the system attaches to is sufficient to withstand the moment loads during fall arrest.

21. 21 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The Hierarchy of Fall Protection Fall Arrest—Minimize Consequences of a Fall Fall Restraint Passive Fall Protection Eliminate the risk

22. 22 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Passive Fall Protection Portable Guardrail Systems Does not require use of a body harness Tie-off not required No Training / Easy to Use Increase Mobility & Productivity System Does Not Require Annual Re-certification Portable, Weighted Base Plates Eliminate Roof Penetrations

23. 23 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Passive Restraint Fall Protection Permanent Guardrail System

24. 24 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Passive Restraint Fall Protection Loading Dock Safety Gates

25. 25 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Guardrail Requirements 1926.502(b)(1) Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria of this paragraph. 1926.502(b)(2)(i) Midrails, when used, shall be installed at a height midway between the top edge of the guardrail system and the walking/working level. 1926.502(b)(3) Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge. 1926.502(b)(5) Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N) applied in any downward or outward direction at any point along the midrail or other member.

26. 26 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Restraint Systems Anchorage + Body Harness + Connecting Device = Worker’s Is Unable to Reach the Building’s Leading Edge

27. 27 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Restraint Systems

28. 28 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Arrest/Fall Restraint Single Point Anchors

29. 29 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Single Point Anchor Summary Advantages: Cost-Effective, Ease of Use, Effective for Applications Where Work Area Is Compact—30 Degree Cone Disadvantages: Limited Coverage Area, Improper Use Can Create Swing Fall Hazards

30. 30 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Requirements for Single Point Anchors Single Point Anchors 1926.502(d)(15) Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows: 1926.502(d)(15)(i) as part of a complete personal fall arrest system which maintains a safety factor of at least two; and 1926.502(d)(15)(ii) under the supervision of a qualified person. Personal Fall Arrest Systems 1926.502(d)(16) Personal fall arrest systems, when stopping a fall, shall: 1926.502(d)(16)(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level; 1926.502(d)(16)(iv) bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m); and, 1926.502(d)(16)(v) have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.

31. 31 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Arrest/Fall Restraint Horizontal Lifeline With Tip-Over Posts Wire Rope Connected to multiple anchors points Provides horizontal movement along work surface while maintaining 100% tie-off Systems may be subjected to extreme forces during fall arrest Is the structure strong enough to withstand fall arrest forces?

32. 32 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Horizontal Lifeline Application With Rigid Posts

33. 33 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Horizontal Lifelines For Non-Rooftop Applications

34. 34 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION The Importance of Structural Analysis

35. 35 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Horizontal Lifeline Summary Advantages Of Horizontal Lifelines HLL’s Span Larger Coverage Areas Than SPA’s, Guardrail and Rigid Rail Systems Suitable for Fall Arrest & Fall Arrest Applications Requires Less Fabrication & Installation Time Than Other Fall Protection Systems Small Footprint/Often Concealed From Ground Level Disadvantages of Horizontal Lifelines Requires Use of Body Harness Greater Fall Clearance Distances Are Required Higher Deflection Systems Than Rigid Systems

36. 36 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION OSHA Requirements for Horizontal Lifelines Horizontal Lifelines 1926.502(d)(8) Horizontal lifelines shall be designed, installed, and used, under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two. Personal Fall Arrest Systems 1926.502(d)(16) Personal fall arrest systems, when stopping a fall, shall: 1926.502(d)(16)(ii) limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness; 1926.502(d)(16)(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level; 1926.502(d)(16)(iv) bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m); and, 1926.502(d)(16)(v) have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.

37. 37 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail Fall Arrest Systems

38. 38 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Arrest Articulating Trolley Beam Designs

39. 39 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail Fall Arrest System-Rail Application

40. 40 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail Fall Arrest System-Mining Application

41. 41 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail Fall Arrest System-Steel Mill Application

42. 42 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail Systems Summary Advantages of Rigid Rail Systems Minimizes Fall Clearance Distances / Minimal Deflection With Proper Engineering, Can Mount To Existing Structure Easily Accommodate Multiple Users Disadvantages Longer Fabrication & Installation Lead Times Larger Footprints When Not Attaching to Existing Structure More Expensive Than Lifeline Solutions

43. 43 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Rigid Rail OSHA Requirements 1926.502(d)(16) Personal fall arrest systems, when stopping a fall, shall: 1926.502(d)(16)(ii) limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness; 1926.502(d)(16)(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level; 1926.502(d)(16)(iv) bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m); and, 1926.502(d)(16)(v) have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.

44. 44 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Vertical Systems—Ladder Cages & Lifelines

45. 45 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Vertical Systems—Ladder Cages & Lifelines

46. 46 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Vertical Systems Summary Cages May Create A False Sense of Security—No Fall Arrest Capability Vertical Cable-Based Systems Are Faster to Install & Often More Cost Effective OSHA Doesn’t Specify One Approach Over The Other 1926.1053(a)(18) Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels. 1926.1053(a)(19) Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following: 1926.1053(a)(19)(i) Ladder safety devices; or 1926.1053(a)(19)(ii) Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or 1926.1053(a)(19)(iii) A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).

47. 47 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Fall Arrest Transportable Solutions

48. 48 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Building Commitment An Effective, Comprehensive Fall Protection Program Requires Work At All Levels of the Organization C-Suite Level: Do Key Decision Makers Understand The Stakes? Investment in Fall Protection Protects Workers & Minimizes Financial Exposure Supervisor Level: Relying Exclusively On The Top/Down Approach Doesn’t Work Front Line Level: Must be confident that the system design will not interfere with work processes Key Question To Ask: What message are we sending to employees, their families, our customers, and shareholders when we accept OSHA fines and civil judgments as a cost of doing business?

49. 49 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Make OSHA’s GDC Work For You! 29 U.S.C. § 654, 5(a)1: Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.“ Any recognized hazard created in part by a condition not covered by an existing OSHA regulation and there are no specific standards may be cited under the general duty clause Hazard may be recognized due to: Common knowledge based on the specific industry In plain view Or should be known by the employer Key Takeaway—Think of the GDC as ammunition supporting your case for a fall protection initiative rather than an OSHA “gotcha” tool

50. 50 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Start With A Plan Most commercial and industrial facilities have multiple locations and work areas that can… Trigger an OSHA inspections/citations/fines Cause serious injury and or death Key Question to ask—where do we start? Fall Hazard Assessment—Identify unsafe areas in your plant, potential options for mitigating the hazards, and budgetary numbers for planning purposes Risk Analysis—Helps with prioritization so your program can be implemented over time while minimizing financial exposure and potential loss These steps are NOT formal OSHA requirements, but they do say something about your safety culture and commitment…..

51. 51 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION Key Questions To Ask….. Does the proposed fall protection company offer… A turnkey approach, including in-house engineering, fabrication, project management, installation, training, and recertification? In House PE services with the ability to stamp drawings in your state? Electronic archival of engineering documentation and inspection records? Rescue Training and Consulting? Certified Competent Installation/Training Personnel? Fall Hazard Assessments and Risk Analysis? AWS D 1.1Fabrication Certification? Assumption of Full Liability for the System?

52. 52 DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC THE EXPERTS IN FALL PROTECTION DIVERSIFIED FALL PROTECTION ™ Division of Lorad, LLC “Life Matters” Contact Information: 24400 Sperry Drive Westlake, Ohio 44145 Phone: 440-348-9460 Fax: 440-348-9455 Web-site: www.fallprotect.comwww.fallprotect.com Email: Trosenthal@fallprotect.com