How to Protect Workers from Falls—With or Without OSHA

OSHA sets the baseline for fall protection—but is that really enough? As fall-related fatalities continue to rise, safety leaders must rethink their approach, with or without regulatory oversight.

• By Philip Jacklin
• Jun 30, 2025

It’s no secret that the current administration is making sweeping changes to the federal government and its institutions, with more changes likely to come. And while no one has a crystal ball and can say with certainty what the next changes will be, it does present us with an opportunity to reflect:  

If OSHA disappeared tomorrow, how would my organization’s safety policies change?”  

There are not necessarily any wrong answers to the question, but this thought exercise might illuminate the real driving force that goes into composing & implementing corporate safety policies. Since 1970, OSHA has been the governing body ensuring that employers meet minimum safety standards with the aim to provide every worker in the United States with a safe place to work.  

However, with many cuts being made across the board federally and the recent cuts to NIOSH (as of this writing in April 2025), many safety professionals have legitimate concerns that similar cuts may be made to OSHA, greatly diminishing the agency's ability to enforce minimum safety regulations.  

These concerns are met with the grim reality that, despite OSHA’s best efforts, falls continue to be one of the leading causes of injury & fatality in the workplace. Falls are the most common cause of injury to occur on construction sites and the third leading cause among general industry workers. In 2023, 885 workers died from falls, an increase from 865 in 2022 (which was also an increase from 850 in 2021). In fact, in the past thirty years, there has been a 17 percent overall increase in the number of workplace fall deaths that occur annually, according to the U.S. Bureau of Labor Statistics (BLS).  

This article will highlight the importance of organizations adapting their fall protection programs to continue protecting workers, with or without the existence of legal mandates. The enforcement of legacy fall protection requirements should be irrelevant to the pursuit of providing a safe workplace for workers, but only if organizations are willing to prioritize moral obligations to protect their workers over any legal obligations—while they still exist.  

Current OSHA Fall Protection Requirements 

Per the federal OSHA General Industry 1910 standard, employers must provide fall protection to workers when exposed to a fall of four feet or greater. In the construction industry, the OSHA 1926 standard requires fall protection once workers are exposed to a fall of six feet or greater. OSHA defines fall protection as “guardrail, a personal fall protection system, or safety netting,” and employers are encouraged to pursue the most practical & feasible fall protection methods available.  

While OSHA’s minimum fall protection requirements provide a helpful starting point, their vagueness makes it difficult for many employers, at least at first glance, to understand how to effectively protect their employees from fall hazards. Providing fall protection equipment to prevent injuries is not necessarily synonymous with preventing falls. Logically, the most effective way to prevent injuries from falls would be to prevent falls from occurring altogether. Luckily, there exists an objective method in providing effective fall protection solutions to workers completely independent of OSHA. Enter the Hierarchy of Fall Protection Controls.  

The Hierarchy of Fall Protection Controls  

Adapted from the original Hierarchy of Controls first introduced by the National Safety Council (NSC) in 1950, decades before OSHA existed, the Hierarchy of Fall Protection Controls provides employers & building owners with a systematic approach to identifying solutions that can keep workers as safe as possible. Applying this hierarchy of controls to the decision-making process of evaluating solutions puts the worker’s safety top-of-mind. Descending the Hierarchy increases the worker’s exposure to the fall hazard but with further personal protective measures to hopefully prevent injuries. The Hierarchy proceeds as follows, in order of increasing potential risk of injury to the worker:  

If more organizations sought to change the nature of tasks to eliminate hazards, perhaps the culture shift would equate to lives being saved. Aside from saving lives and not risking the quality of life for workers at height, this culture shift could also have significant fiscal benefits for companies as well. According to a 2022 report from the NSC, falls have the third leading worker's compensation payouts, with an average of $50,000 per incident. That does not include other potential direct costs like OSHA citation penalties and litigation fees. Some sources estimate that further indirect costs, like decreased worker productivity, cost to replace injured or deceased workers, retraining new hires, and lost business due to damaged reputations, can equal up to four times as much as direct costs!  

The effectiveness of passive fall protection solutions is often understated, with the most common example being guardrail. Guardrail’s effectiveness lies in its simplicity. It requires no input from the user to protect themselves with fall protection. If a rooftop is outfitted with a perimeter guardrail solution, almost all the fall hazards on that rooftop are instantly mitigated. Active travel restraint is also, technically, a way to prevent users from reaching unprotected edges, but there is more potential for user negligence that can circumvent the system’s effectiveness.  

Active fall protection systems, including active travel restraint, require the user to don a full-body harness and connect to a 5,000 lb-rated anchorage while working above the minimum fall clearance required of their connection device. Super straightforward, right? While active fall protection systems are very commonly used, it’s important to acknowledge that since a fall is not being prevented, employers rely exclusively on diligent user compliance to lessen the severity of injury incurred. An ill-fitting harness, insufficient anchorage, or incompatible connection device can give an illusion of safety but still expose the worker to a fall without much means of protection. The Center for Construction Research & Training (CPWR) found that 60 percent of fatal falls occurred while workers were using fall protection equipment, according to a survey conducted in 2021.  

The last thing an employer should want is for an employee to get injured or killed while on the job. The next worst thing would be wasting resources on ineffective solutions that still don’t properly protect a worker from injury or death.  

Alternate Authorities in the Fall Protection Industry  

Aside from OSHA regulations, most safety professionals refer to the ANSI Z359 Fall Protection Standard to create a robust, comprehensive fall protection program. This ANSI standard is sponsored by the American Society of Safety Professionals (ASSP), which is the oldest professional safety organization in the world.  

The ANSI Z359 committee comprises manufacturers, engineers, and end-user organizations that have been involved in the fall protection industry for decades. The committee aims to provide employers with vital information to offer insight on best practices when using equipment and supports existing industry consensus solutions. Most of the information contained in manufacturer instruction manuals is derived directly from the ANSI Z359 standard. Over the years, many OSHA regulations have also been heavily influenced by the ANSI standard.  

As a rule of thumb, many people consider OSHA to dictate “where” and “when” fall protection equipment is required; ANSI can help determine “what” equipment is most appropriate for the application and “how” to properly use that equipment. If OSHA suddenly disappeared tomorrow, the ANSI standard would be the next logical authority for employers & building owners seeking guidance for their fall protection programs.  

Many trade & safety associations also exist that can provide valuable resources for organizations seeking guidance on building robust fall protection programs, and many of them are already heavily involved in the fall protection industry. For example, the International Safety Equipment Association (ISEA) sponsored the ANSI/ISEA Dropped Object Prevention Standard in 2018, which aims to protect workers from the dangers of falling equipment. Other associations like the Scaffold & Access Industry Association (SAIA) or the International Powered Access Federation (IPAF) advocate for the safety of workers using niche elevated work equipment, like scaffolds, scissor lifts, boom lifts, and more. Organizations like ASSP connect safety professionals nationwide to corroborate on their safety goals and share ways to protect workers everywhere.  

Moral Obligation to Provide Worker Safety  

None of us know what the future holds, but we know that we are currently facing a crisis regarding protecting workers at-height. As previously discussed in this article, the number of people suffering injuries & fatalities from falls is increasing each year. And while companies spend many resources to provide equipment, train workers, and increase awareness, it is increasingly important to ensure that only the most effective solutions are being provided to workers.  

If employers wish to continue asking workers to be exposed to fall hazards, then those employers hold a moral obligation to provide a safe means to perform those jobs. With or without OSHA’s presence & legal mandates, every worker deserves the chance to go home safely at the end of the day.  

This article originally appeared in the June 2025 issue of Occupational Health & Safety.