Elevating Safety: Fall Protection Requirements on Mezzanine Levels

by Philip Jacklin 

When people consider the fall protection programs for their organization, an immediate assumption might be to consider only operations occurring on the building’s rooftop. However, rooftop safety does not inherently take any priority over any other elevated areas inside or outside of the building. Since falls are one of the most common workplace injuries & causes of fatality, all fall hazards should be taken seriously.

Many facilities utilize mezzanine levels to amplify their square footage for material storage or additional equipment. While they are effective in getting more floor space out of your foundation, they elevate workers from the ground level and could expose them to fall hazards. According to the Occupational Safety & Health Administration (OSHA), employers in the general industries are required to provide fall protection whenever an employee is exposed to a fall of four feet or greater to the next lower level. When such a fall hazard is present, OSHA permits the employer to use safety netting, a personal fall protection system, or guardrail. However, employers must carefully decide which fall protection method is feasible & most effective for mezzanine areas.

Duty to Provide Fall Protection

As stated earlier, OSHA 1910 states that fall protection must be provided to any worker exposed to falls of 4ft or greater. At the risk of stating the obvious, this requires providing fall protection 100% of the time the fall hazard is present. This is an important consideration because while many mezzanine platforms come from the manufacturer with guardrail installed, many organizations may consider their fall protection requirements fulfilled.

However, many operations performed on mezzanine levels require workers to temporarily remove guardrail to receive material loads onto the work platform. It stands to reason that if an employer can anticipate these operations, they have a duty to provide a secondary form of fall protection for the worker while guardrail panels are removed.

Guardrail Requirements & Benefits

Before assuming the existing guardrail on a mezzanine level can be considered adequate fall protection, we must confirm the guardrail meets minimum OSHA requirements. Compliant guardrail will be a minimum of 42” tall and have a midrail installed midway between the top rail and the walking working surface. The top rail & midrail must be capable of withstanding forces of 200lbs & 150lbs in any direction, respectively. Toeboards are required if there will be workers walking underneath the mezzanine to protect them from debris overhead.

Guardrail is one of the most effective means of fall protection and is often referred to as fall prevention equipment as it “prevents” the user from physically reaching the fall hazard. Additionally, it requires no annual inspection or user training. It will work as long as people stay on the correct side of the guardrail. However, as mentioned earlier, when some work operations require guardrail panels to be removed temporarily to complete a task, we must ensure equipment & procedures are in place to protect workers while they temporarily remove the guardrail. A dormant fall hazard can quickly become an active fall hazard, and the risk of injury suddenly increases.

Fall Protection Options When Removing Guardrail

Before the worker can remove guardrail panels to accommodate material loading or equipment movement, we must protect the worker against falling from the newly exposed edge of their walking working surface.

Option #1 – Travel Restraint 

First, we could consider a travel restraint system to prevent the user from reaching the exposed edge. Restraint systems require an anchorage, full body harness for the worker, and a connection device shorter in length than the distance from the anchorage to the exposed edge—typically a fixed-length fall restraint lanyard. These systems are reliant upon the user to fully comply with the written fall protection program and can prove cumbersome to workers who must perform other tasks out-of-reach (so to speak) of their restraint lanyard.

Option #2—Fall Arrest 

If a travel restraint system is not feasible for the application, we could consider a fall arrest system for the worker. Fall arrest systems also require an anchorage and full body harness for the worker, but they can utilize a plethora of connection devices of various lengths. The most popular option is a self-retracting lifeline (SRL) as they allow for freedom of movement and typically require less fall clearance underneath, as opposed to shock-absorbing lanyards which typically require 18-20ft of fall clearance to arrest a fall successfully.

When using a fall arrest system, installing the anchorage overhead of the work area is ideal. Overhead anchorages help decrease the amount of freefall a worker will experience, regardless of whether their connection device is a shock-absorbing lanyard or SRL, and allow for more freedom of movement for the worker. Since workers must stay within 15 degrees of their anchorage, the higher up the anchorage the larger their safe working area will grow. If the fall arrest anchorage must be located on the walking working surface, a Class 2 SRL must be utilized, according to the ANSI Z359.14-2021 standard and manufacturer’s instructions.

Fall Rescue Requirements

Whenever a worker is performing tasks at heights, no matter the safeguards in place to protect the worker, rescue solutions should be considered. However, OSHA has certain requirements whenever fall arrest equipment is used. Organizations are required to have the means to “self-rescue” an employee if a fall occurs. While 911 should be called whenever a fall occurs so the worker can be medically evaluated, waiting for emergency services to perform the rescue can lead to further injury to the fall victim and will likely result in an OSHA citation.

Fall rescue plans do not inherently have to be complicated; they just have to be effective. The goal is to safely remove the worker from suspension as quickly as possible. This can be accomplished using ladders, lifts, rescue-retrieval rope kits, or many other equipment available to rescue the worker.

Employers must train their workers on the rescue plan and document the process in their fall protection program. Additionally, many workers would benefit from discussing fall rescue options before beginning work at heights and ensuring those options are currently viable and ready to perform. If the previously decided rescue solution is unavailable for whatever reason, elevated work should not continue until another solution is provided.

Conclusion

Falls are one of the leading causes of injury and fatality in the workplace, with 885 fatal falls occurring in 2023 according to the U.S. Bureau of Labor Statistics (BLS). Not only is a fall fatality a tragedy for the worker’s family but it can be detrimental to employee morale and end up being quite expensive for the liable organization. The National Safety Council estimates nearly $50,000 in the average Worker’s Compensation payout for a fall incident, and that does not include the additional legal fees, potential OSHA citations, and other indirect costs that will likely occur.

Learning the requirements for providing fall protection on mezzanine levels is simple. Providing effective & practical solutions for workers and preventing fall injuries is not always simple. Employers should utilize all available resources, such as consultants, vendors, or fall protection providers, like Diversified Fall Protection, to verify their facility’s compliance with OSHA requirements and ensure their workers will be protected from falls. Benjamin Franklin once said, “An ounce of prevention is worth a pound of cure,” so there is much to be gained from prioritizing worker safety & preventing falls in your facility.

Philip Jacklin is Continuing Education Program Manager for Diversified Fall Protection. He is an AIA continuing ed provider, QSSP certified, OSHA-30 trained, and has been a partner to the fall protection industry since 2018. Philip has a background in worker advocacy, team leadership, and fostering camaraderie among peers. He enjoys playing music, writing, and spending time in the sunshine with his family in Virginia Beach, VA. Visit: https://www.fallprotect.com/