Fall protection remains the most cited OSHA violation year after year. In 2024, federal OSHA investigated 189 fatal falls, and general fall protection requirements led to 6,827 violations. For those working in grain facilities, feed manufacturing plants and construction sites, understanding proper fall protection is critical for compliance and ensures that every worker gets home safely.
At the American Feed Industry Association’s (AFIA) 2025 Equipment Manufacturers Conference, Zac Jabor, environmental health, safety and quality manager, WL Port-Land Systems, emphasized that effective fall protection goes beyond regulations.
“You can give everybody the regulation text,” Jabor said. “But really, it’s about how it connects with each and every individual on your job site.”
While noting the importance of an organization’s safety culture, Jabor’s presentation also delved into common fall protection pitfalls he’s observed in feed and grain facilities and offered tips to prevent them.
DO: Follow the hierarchy of fall protection
The most effective approach follows a clear hierarchy. The first choice is hazard elimination.
“In a perfect world, we’d eliminate the hazard — the ideal response to mitigating any potential fall,” Jabor said.
When hazards can’t be eliminated, the second-best option is to implement passive fall protection, like guardrails and hole covers. Third, use fall restraint systems that prevent workers from reaching hazardous edges. Fourth, employ fall arrest systems that stop falls in progress. Administrative controls like warning lines should be used as a last resort.
“Fall restraint is more ideal than a fall arrest system because it prevents you from reaching the fall hazard in the first place,” Jabor said.
While both require harnesses and training, restraint systems avoid exposing workers to dangerous fall arrest forces.
DON'T: Rely on administrative controls alone
Warning lines, safety talks and written procedures have their place, but they shouldn’t be primary protection methods. Jabor said relying on administrative controls means “we are placing all trust in that whatever you say is going to be followed.”
A warning line on a roof is only effective if workers respect it — and in moments of urgency or distraction, that’s not guaranteed.
DO: Inspect equipment daily and document formally
Every harness should be inspected before each use. Workers should check for cuts, abrasions and damage, particularly when harnesses are stored in gang boxes where tools might be thrown on top of them. Jabor said when borrowing harnesses, workers must inspect them thoroughly before wearing — their lives depend on it.
Beyond daily checks, OSHA requires formal, documented inspections of fall protection equipment every six months. These records must be readily available to provide a critical safety net for the company, should an incident occur.
“Some companies lose sight of this paper trail because people don’t love paperwork, but it’s there to prevent any potential issues,” Jabor said.
DON'T: Take shortcuts, even when in a hurry
Jabor shared a cautionary tale about a young worker eager to prove himself. The worker did many things right: he identified the need to tie off, went to the next level, wrapped his strap around a beam and connected his retractable. But he then made a critical error — instead of using a ladder 30 feet away, he climbed across equipment to reach his work location while tied off.
He fell, swinging between two pieces of equipment. After sustaining deep contusions from the fall, he was unable to return to work for a week and a half.
“All because he was in a hurry,” Jabor said. “Sometimes we can lose sight of good judgment.”
DO: Secure removable guardrails properly
Removable guardrails serve important functions in facilities where materials need to be received at elevated levels. However, they require securing mechanisms, like pins or locks to prevent inadvertent removal. Chains are acceptable as guardrails if they meet the 200-pound pressure requirement, but the system must ensure rails are replaced after removal.
Self-closing gates on ladderways are required for a reason.
Jabor said he once encountered a facility where “every single ladderway had the self-closing gate tied open.”
While convenient for frequent passage, it’s a dangerous practice that defeats the purpose of the feature.
DON'T: Assume one size fits all
Harnesses are never universal despite what the packaging claims. The right choice depends on D-ring placement, which varies based on the work being performed. Chest D-rings are suited for positioning work and ladder climbing. Side D-rings and back D-rings serve different functions, with back-mounted rings being standard for fall arrest. Having multiple options ensures proper protection for various tasks.
Similarly, safety gates and fall protection systems require matching to specific applications. Sliding gates, overhead gates, booster gates and pivot gates each solve different problems. While there’s a broad range of costs for each option, the expense is minimal compared to an injury.
DO: Proper personnel training
OSHA distinguishes between competent and qualified persons. Competent persons gain expertise through experience, while qualified persons have educational backgrounds and certifications. Only qualified persons should train employees on fall protection systems, Jabor said.
Training must cover identifying and minimizing fall hazards, proper use of personal fall arrest and restraint systems, and maintenance, inspection and storage procedures. Workers should automatically look for fall hazards and have a rescue plan before starting elevated work.
Portable ladder safety training tips
Ladders are the No. 3 most-cited OSHA standard, with around 2,700 total violations in 2024. Ladder standard violations include failure to extend three feet above the working platform, working from the ladder’s top step and not meeting proper training requirements.
Portable ladders are one of the most commonly used ladders in feed and grain workplaces. For portable ladders, OSHA requires fall protection to be used when workers cannot maintain three points of contact at four feet above the walking-working surface.
Jabor’s presentation highlighted some key elements of portable ladder safety training, as failure to train could result in injuries and OSHA citations.
- OSHA requires employers to provide training on:
- Identifying hazards associated with ladder
- Proper selection of ladders (extension, A-frame, step
- Maximum intended loads and capacities
- Proper placement, set-up and use
- Inspection procedures and defect recognition
Furthermore, employers must repeat portable ladder training if there are changes in procedure or ladder types, when an employee demonstrates inadequate knowledge, or if there is an incident or near-miss at a worksite.
Technical systems and regulations matter, but safety depends on workers making good decisions moment by moment. Following these dos and don’ts can create an environment where good decisions become second nature and everyone conducts their jobs safely.
“Ultimately, what it comes down to with fall protection is your people,” Jabor said.
