Companies that strive to meet highest standards and listen to customers are best positioned for safety and innovation.
Working at height is a hazardous job that can expose aviation maintenance professionals to unplanned falls resulting in severe injuries, such as fractured bones and head trauma, or even death. Falling is a top aviation maintenance error worldwide, and it is among the most common causes of serious work-related injuries and deaths, according to the U.S. Occupational Safety and Health Administration (OSHA).
In fact, falls compose more than 20% of all workplace fatalities in the United States, with 850 workers across all industries — including but not limited to aviation — dying from falls, slips, or trips in 2021, according to the U.S. Bureau of Labor Statistics.
Injuries and fatalities from such incidents are relatively rare, perhaps lulling some workers into a false sense of security. OSHA has named fall protection as its most-cited violation each year since 2011.
Companies that design and manufacture aviation maintenance structures and equipment such as platforms, stands and ladders, where technicians work at height, are constantly improving and innovating their products in order to meet the needs of their customers while also meeting the industry’s ever-evolving safety regulations and consensus-based standards.
Standards and Customers Driving Improvements
In 2017, OSHA issued its final rule on Walking-Working Surfaces and Personal Fall Protection Systems under 29 CFR Part 1910 to better protect workers in aircraft maintenance and other industries from these hazards by updating and clarifying standards and adding training and inspection requirements.
Over the last decade, the American National Standards Institute (ANSI) and the American Society of Safety Professionals (ASSP) have also released many updates to the ANSI/ASSP Z359 Fall Protection and Fall Restraint Standards to address fall protection equipment and systems for climbing, work positioning, fall arrest, rescue, evacuation and other fall hazards. These consensus-based standards also address training, and how to identify and abate hazards to prevent injuries when working at height.
“Most of the advances in what we do come from changes in regulation or changes in consensus standards,” said Kevin Kelpe, continuing education manager at Diversified Fall Protection, a full-service fall protection integrator based in Ohio.
“For example, one of the updates to the OSHA 1910 standard that in recent years has had the biggest impact on companies designing and manufacturing lifts, platforms, work stands and scaffolding for aviation maintenance work performed at elevated heights, is the rule prohibiting workers from going within 15 feet (4.6 meters) of a leading edge in general industry workplaces where they are elevated 4 feet or more without using some kind of fall protection,” Kelpe said.
“In the environments that we’re talking about — aircraft maintenance — those workers are always exposed to falls,” he said. “There’s nowhere for them to stand where they not exposed to a hazard, according to OSHA,” he added, noting that most of what’s developed and designed to protect aviation maintenance workers are active systems, meaning they have to use a harness or a lanyard for fall protection.
The 1910 standard put forth requirements for the testing and certification or recertification of equipment both at the point of installation and later intervals; the training of authorized and competent individuals to use and train people on using the equipment; and the annual inspection of the equipment, as well as the inspection of certain types of equipment per each use.
“All those rewrites and changes related to training inspections, and to some degree fall protection equipment, really drove the development of new products for us,” Kelpe said.
The enhanced requirements are significant because before being codified in OSHA 1910, “these requirements weren’t always clearly articulated in the law,” explained Kelpe. “They’ve always been part of the consensus standard, but now they’re part of the law, which means if an OSHA inspector’s on a job site and doesn’t find a PPE (personal protective equipment) inspection log showing that the equipment was inspected at required intervals, not only can the inspector fine the employer but they also have the power to stop work,” he said.
Diversified Fall Protection regularly helps its customers implement evolving fall protection regulatory requirements to bring existing structures up to code, said Kelpe. For example, the company is currently helping customers incorporate new self-retracting lanyards (SRLs) into longer-span truss systems to comply with 2021 ANSI safety standard changes under Z359.14 for self-retracting devices (SRDs) used in personal fall arrest and rescue systems.
Since American and European regulatory requirements are widely considered to be the highest available safety standards for countries to aspire to, companies like Madrid-based Alufase, international manufacturer of aluminum aircraft maintenance platforms, will often fulfill regulatory requirements for a given country by using European standards or American standards to ensure the local region’s safety standard is exceeded, according to the company’s sales manager David Donado.
“Regulatory compliance is complex,” he said. “Aviation is one of the safest places to work, so you have to go with the highest standards or you are out. Even if you go to different countries and they have their own standards, they can usually accept European standards or American standards, depending on where they are, because those standards are more globally common, and this is something they will find as an understandable solution.”
Simpson Aerospace Services (SAS), an Indiana-based company providing aircraft maintenance stands for commercial and military aviation, recently has taken a different approach to fall protection with its latest maintenance stand used to install Wi-Fi and Satcom equipment on the top of narrow- and wide-body aircraft. Having gone from concept to market within the last 18 months, SAS’s new stand offers a number of innovations, including a completely enclosed working area, that eliminate the need for a worker to be tethered.
“We have engineered and are building stands that allow mechanics and tech crews to safely access the top of the plane and install, repair, or maintain those components, while giving them a safe, confident feeling and allowing them to work more efficiently. That cage, or work pen, also has metal shields preventing tools or equipment from falling, a common hazard that can result in damage to a fuselage, wing, or, worse still, someone on the ground,” said Bill Medley, SAS representative.
SAS relies heavily on customer input to guide its designs and ensure safety. “We worked with our customers and brought them in and had them actively give us feedback on the design,” said Medley. “For example, even the size of the step, the height of the step, and the broadness of the step. You think about people carrying things up the steps to get up to the aircraft, and there can be simple little injuries — things we kind of dismiss but they’re real. A slip on a step can cause a lot of damage to somebody and that’s what you don’t want,” he said.
“Airlines are looking for maximum utility with stands,” Medley said. “They want to be efficient because time on the ground is money, and airlines are sensitive to that. They know planes have to be maintained properly, but they also have to keep those aircraft in the air to make money.”
Kansas-based LockNClimb, which provides ergonomic ladders for MROs, is another company that views customer feedback as essential in designing the safest products for aviation mechanics who need to reach elevated areas. “Our ladders are developed with input from airline safety directors, management and mechanics. We take the prototypes onto the flight line, and the mechanics study them and tell us how we can improve them,” said president and CEO Jeff Green.
The company’s special-purpose ladders offer specialized safety features requested by mechanics that help prevent trips, slips and falls, including extra-wide treads and safety handrails. The ladders are also designed to ensure that the user is facing the work they’re doing instead of turning sideways, and also keeping their body inside of the rails of the ladder, per OSHA requirement.
Alufase image.
Training for a Safety-First Culture
Maintenance technicians who don’t adhere to the highest safety standards when working at height risk not only fines and company reprimands, but also their own lives. Manufacturers can be a part of creating and encouraging a culture of safety in aviation for these workers.
“You’re putting men and women 30 feet up in the air, it’s dangerous work. Those of us who provide equipment to do that start with a position of safety first,” said Medley.
“We look at the standards and we want to be better than them,” he explained. “Whether that’s a grade of steel or aluminum, or whether it’s involved with a step or an angle, a lot of it is keeping people from doing things when they shouldn’t be doing them. Everything that’s on that stand is purposeful, not only for the function it’s doing, but also in what it won’t do.”
Training is more important than ever in light of aviation maintenance staffing shortages, according to Medley. “It’s very important that you can build a safe stand, but just as important is teaching how it works and how you use it,” he said.
“Most airlines, I’m sure, would tell you, there’s a tremendous change of staffing right now. All of our clients see a real need for more people, more technicians and trained people in this business, and that means an accelerated level or need for good training on all aspects of their job — and that includes safety,” Medley said.
In ensuring safe use of ladders or other platforms for maintenance workers, Green likewise emphasized the need for companies to have a training component as part of their services. “When our customers use our training videos in conjunction with the ladders, it drastically reduces falls and accidents,” he said. “In one company, we prevented 90% of their cost of ladder falls in one year just by using our training with the ladders.”
“It’s part of our responsibility to train people in a proper way that maybe they aren’t used to,” Donado said. “Regardless of country, if a company doesn’t have higher standards in terms of safety and they require trained people to use the equipment, we offer this to the customer and most of them appreciate it. It’s on us to get the people involved in this part of it, and create a safety-focused community, so we’re all safety first.”
When doing a cost-benefit analysis, most companies know they’re going to have to spend money to create a safe working environment, and they look to the law and the standard for the minimum level of safety, according to Kelpe. Yet, fall protection is still the number one safety violation 12 years running. “It’s hard for me to imagine that anyone who works in safety wouldn’t know how common the violation issues are,” he said. “It goes to show you how common it is to meet the minimum requirement and stop spending money.”
Kelpe chalks it up to an opportunity to educate people, so they know that the minimum level of safety has been raised for fall protection standards. “Our services department works really hard keeping up with everyone’s inquires and calls asking to recertify equipment and train people. OSHA 1910 has been in effect since 2017 but now that citations are flying, people are trying to become compliant,” he said.
According to a recent ASSP survey, some of the top reasons for falls had to do with errors around using the equipment and being properly trained. “It’s not that companies don’t have fall protection programs in place, but people aren’t current on the standards, so they’re using the wrong equipment, or using the equipment wrong, or their manager isn’t training them. It’s something we have to be vigilant about — training and retraining and staying on top of it to prevent those things from happening,” he said.
“In our practice, we’re inclined to teach people the minimum and also teach them what we see as best practice for protecting workers and saving lives,” Kelpe concluded. “Everything tends to converge to the strictest standard, so we teach that, too. It’s alarming to think how catastrophic one accident can be.”