Working group updates Fall Protection Program

ByRebeccaColeman

Naval Safety Command

NORFOLK, Va Representatives from acrossthewarfarecommunitiesandMarine Corps comprise the Navy’s Fall Protection Working Group which met at the Naval Safety Command July 18-20 to review currentpoliciesinplacefortheFallProtectionProgramandproposeupdatestoChapter 13 of OPNAV M-5100.23 Additionally, the working group reviewed and updated the Department of the Navy’s Fall ProtectionGuide Falls from height are the second-leading unintentionalfatalworkplaceevent,accordingtotheNationalSafetyCouncil Workers intheconstructionindustryaremostatrisk, withthemostnonfatalcasesinvolvingdays awayfromworkand20%ofallnonfatalfallfrom-heightcaseseachyear

In its first year, NAVSAFECOM’s local area assessments noted 168 fall protection discrepancies, ranging from poorly maintained handrails to a lack of a unit fall protectionprogram.Since2017 theNavyhas incurredfourfatalfalls ofwhichthreecould have been mitigated under the Fall Protection Program, based on data from the Risk Management Information safety reporting system. These statistics underscore the importance of the working group’s purpose. During the first two days, the working groupconductedacomprehensivereviewof OPNAVM-5100.23 Chapter13 andOPNAVINST 5100 19F Chapter 13 in an effort to update the chapters to reflect changes in regulatoryrequirements

“The intent is to eventually merge these twochaptersintoonecohesivechapterthat encompasses all fall protection requirements for all warfare areas, providing the end user a singular document for all fall protection requirements,” said Charles Gum, Shore Directorate deputy director NAVSAFECOM. Requirements that are specific to a particular warfare area or community will be added as an addendum tothesingularchapter.

Forming one, cohesive fall protection chapter across all warfare communities will make it easier to understand and allow peopletoaccessjustoneplacetofindpolicy, saidGum.

Before the group got started, Gum provided a quick refresher of the current safetyandoccupationalhealthhierarchy:

„ Department of Defense Instruction (6055.01-SOH)

„ DoN Safety Program (SECNAVINST 5100.10)

„ NavySafetyProgramManual(5100.23)

„ Community-Specific Safety Guidance (OPNAVINST5100.19,3750 etc.)

„ Headquarters/Immediate Superior in Command(ISIC)Guidance,LocalStandard OperatingProceduresandInstructions

Gum noted OPNAV M-5100.23 provides

NORFOLK(May11,2023) Operations Specialist SeniorChiefPettyOfficerLuke Mckenzie,assigned to the Naval SafetyCommand and Marine Corps StaffSgt.AshleyLeachman,assigned to MarineAviation Logistics Squadron 12 demonstrate a fall-arrest rescue as part ofthe Competent Person forFall Protection Course.The Naval Safetyand EnvironmentalTraining Centerholds the Competent Person forFall Protection Course to train and equip Navypersonnelwith the knowledge and skills needed to prepare and implement fall protection and prevention plans,and fallarrest rescue plans and procedures (U.S.NAVYPHOTOBYMASSCOMMUNICATIONSPECIALIST1STCLASS(SW/AW)WESTONA.MOHR) the “what” in the regulatory requirements

The instruction outlines the Echelon 1 perspectiveandisspecificinsomeareasonly toensureconsistencyanduniformity

TheHeadquarters,ISICandlocalinstructions describe the “how, what and who” performs the requirements spelled out in the OPNAV instruction. Every organization executes its processes a bit differently These local instructions allow organizations to tailor their processes in a way that worksbestforthem,aslongastheymeetthe requirements,saidGum.

“The5100.23istheNavy’stop-tierinstruction,” said Gum. “One of the reasons we’re merging is to alleviate the end user from havingtofindmultipleinstructions;5100.23 will be the one instruction. No longer will people say, ‘I’m from the afloat community, so I’m only going to read the afloat instruction.’

Gumnotedtherewasatimewhen5100.23 was named the ashore manual

It no longer saysthatinordertoreinforceitistheNavy’s overarchingOccupationalSafetyandHealth Manualthatallothersafetymanualsacross allwarfareareasshouldalignto

The working group also focused on removing duplicative or obsolete information from the instructions Proposals were made to clarify and remove ambiguous phrasing and ensure processes were up to date and aligned with current policy For example, the working group removed themandatoryminimumcumulativetraining-hour requirements for various positionswithinthefallprotectionprogramand replacedthemwithtrainingsyllabustopics requiredforthepositiontoallowcommands moreflexibilityintrainingtheirpersonnel.

The last two days of the meeting were spent revising the Fall Protection Guide, whichwaslastupdatedthreeyearsago

“There’s been a misunderstanding that theguideisactuallypolicy anditisnot, said Gum “There is guidance in the front of the guidethatleadspeopletobelieveitispolicy. It was intended to be designed as a guide nottomimicpolicy Thatunderstandinghas beenblurred.”

To correct this perception, the group updated the glossary and removed obsolete and duplicate definitions Proposed commentsweremadethroughoutthedocumenttoremoveanylanguagethatwasdirectiveinnature

The group also clarified sections and terminology throughout, tightening the verbiageandensuringconsistency.

“The guide is an important asset for SailorsandMarines,andwebelievetheupdates will enhance their fall protection programs and serve as a complement to the OPNAV policy,”saidGum.

The updated Fall Protection Guide is expected to be released to the naval enterprise in late September 2023 The updated Chapter 13 of OPNAV M-5100.23 will be released next year due to the time it takes forallstakeholderstoconcuroncontent