Falls from heights are the leading cause of death and critical injury on Ontario construction sites. Working at Heights (WAH) training is mandatory for any construction worker who may use a method of fall protection on a project. This guide covers the regulatory requirements, fall protection systems, equipment inspection procedures, and HCMI-specific policies for working at heights safely.
In This Guide
1. Legal Basis & When WAH Training Is Required
Working at Heights training requirements are established under Ontario Regulation 213/91 (Construction Projects), sections 26.1 through 26.9. Under these provisions:
- Every worker on a construction project who may use a method of fall protection must successfully complete a WAH training program approved by the Chief Prevention Officer (CPO) of the Ministry of Labour, Immigration, Training and Skills Development
- The training must be delivered by a CPO-approved training provider
- Training is valid for three years — workers must complete refresher training before their certification expires
- Employers must verify that workers hold a valid WAH training completion certificate before allowing them to use fall protection on a construction project
Under O. Reg. 213/91, section 26.1(1), fall protection is required when a worker is exposed to a fall of 3 metres (10 feet) or more, or when a worker is exposed to a fall of any height into operating machinery, water, or another hazard where the fall itself would not be the primary cause of injury.
Regulatory Note: The 3-metre threshold applies to construction projects under O. Reg. 213/91. However, HCMI policy is more conservative — see the HCMI-Specific Policies section below. Also note that some specific tasks (e.g., work on suspended platforms, boatswain's chairs) have additional requirements beyond general WAH training.
2. The Fall Protection Hierarchy
Ontario's Construction Regulation establishes a hierarchy of fall protection methods. You must use the highest level of protection that is practicable for the work being performed:
- Elimination — Can the work be done at ground level or from a permanent structure? This is always the preferred approach.
- Guardrail systems — Physical barriers that prevent a worker from reaching the fall hazard.
- Travel restraint systems — A system that prevents the worker from travelling to the edge or opening where a fall could occur.
- Fall arrest systems — A system that stops a falling worker before they hit the ground or a lower level. This is the last resort before safety nets.
- Safety nets — Used when other methods are not practicable.
The hierarchy exists because passive systems (like guardrails) are inherently more reliable than active systems (like fall arrest harnesses) that depend on correct worker use. Always default to the highest feasible level of protection.
3. Guardrail Systems
Guardrails are the preferred fall protection method on HCMI sites wherever they can be installed. Under O. Reg. 213/91, sections 26.3 and 26.4, guardrail systems must meet these requirements:
- Top rail: Between 0.9 m (36 in) and 1.1 m (43 in) above the work surface
- Mid rail: Installed midway between the top rail and the work surface (or toe board)
- Toe board: At least 89 mm (3.5 in) high at the floor level to prevent materials from falling off edges
- Strength: The top rail must be capable of resisting a point load of 890 N (200 lbs) applied in any direction at any point along the top rail
- Posts: Spaced no more than 2.4 m (8 ft) apart
Guardrails must be installed at all open edges, floor openings, shafts, stairways without permanent railings, and any other location where a worker could fall 3 metres or more. Temporary removal of guardrails to move materials is permitted only when alternative fall protection is in place and the guardrail is replaced immediately after.
4. Travel Restraint Systems
A travel restraint system prevents the worker from reaching the fall edge. Unlike fall arrest, the system does not need to absorb a fall — it simply keeps the worker from getting to a position where a fall is possible. Components include:
- Full body harness: CSA Z259.10 approved (the same harness used for fall arrest)
- Lanyard or restraint line: Adjusted so that the worker cannot reach the fall hazard — the length is critical
- Anchor point: Must be capable of supporting a static load of 2 kN (450 lbs) for travel restraint (lower than fall arrest requirements because no dynamic fall forces are involved)
Travel restraint is often used on flat roofs where the worker can be connected to a roof anchor with a lanyard short enough to prevent reaching the roof edge. The key advantage is that no fall arrest plan or rescue plan is required, because a fall cannot occur. However, the system must be properly adjusted — if a worker can reach the edge, it is not a travel restraint system.
5. Fall Arrest Systems
A fall arrest system is designed to stop a worker who has already begun to fall. It is used when guardrails and travel restraint are not practicable. A compliant fall arrest system under O. Reg. 213/91, section 26.4 includes:
Required Components
- Full body harness: CSA Z259.10 approved. The only acceptable body holding device for fall arrest in Ontario construction. Body belts are not permitted for fall arrest.
- Connecting device: A lanyard with an energy absorber (shock absorber) — CSA Z259.11 approved. The energy absorber limits the arrest force on the worker's body to no more than 8 kN (1,800 lbs). Alternatively, a self-retracting lifeline (SRL) — CSA Z259.2.2 approved.
- Anchor point: Must be capable of supporting a static load of at least 8 kN (1,800 lbs) for each worker attached, or be designed by a professional engineer as part of a complete fall arrest system.
- Lifeline (if applicable): A vertical or horizontal lifeline — CSA Z259.2.1 (vertical) or engineered (horizontal). Only one worker per vertical lifeline unless engineered otherwise.
Fall Distance Calculation
Before using a fall arrest system, you must calculate the total fall distance to ensure the worker will not strike the ground or a lower level. The total fall distance includes:
- Free fall distance (maximum 1.2 m / 4 ft with a shock-absorbing lanyard, or 0.6 m / 2 ft with an SRL)
- Shock absorber deployment distance (up to 1.07 m / 3.5 ft)
- Harness stretch and shift (approximately 0.3 m / 1 ft)
- Worker's height below the D-ring (approximately 1.5 m / 5 ft)
- Safety margin (minimum 0.6 m / 2 ft recommended)
For a standard 1.8 m (6 ft) shock-absorbing lanyard with a D-ring connection at the back, the minimum clearance below the anchor point is approximately 5.5 m (18 ft). If less clearance is available, use an SRL or a shorter lanyard, or choose a different fall protection method.
Critical Safety Point: A fall arrest system that allows the worker to hit the ground is worse than no system at all — it gives a false sense of security. Always calculate fall distance before tying off. If you are unsure, ask your supervisor before proceeding.
6. Safety Nets & Other Methods
Safety nets are used when other fall protection methods are not practicable, such as during structural steel erection or bridge work. Safety nets on HCMI projects must:
- Be installed as close as practicable below the work surface — no more than 6 m (20 ft) below
- Be designed, installed, tested, and maintained by a competent person
- Extend sufficiently beyond the edge of the work area to catch a falling worker
- Be inspected before each use and after any event that could damage the net
Other fall protection methods that may be used in specific circumstances include control zones (for leading-edge work by trained workers), warning barriers (limited applications), and safety monitors (not commonly accepted on Ontario construction projects as a standalone method).
7. Anchor Points & Structural Requirements
The anchor point is the most critical component of any fall protection system. An inadequate anchor can result in a complete system failure. Requirements include:
- Fall arrest: 8 kN (1,800 lbs) per worker, or designed by a professional engineer
- Travel restraint: 2 kN (450 lbs) per worker
- Location: At or above the D-ring height whenever possible. Lower anchor points increase free fall distance and arrest forces.
- Independence: The anchor must be independent of the work platform or structure being assembled or dismantled
- Certification: Engineered anchor systems (e.g., permanent roof anchors) must be installed and certified according to the engineer's design and CSA Z259.16
Important: Never tie off to a vent pipe, conduit, rebar, temporary bracing, or any structural member whose capacity you have not verified. When in doubt, consult with your supervisor or the HCMI Safety Department before proceeding. An anchor point failure means the fall protection system does not exist.
8. Equipment Inspection
All fall protection equipment must be inspected before each use. Remove any equipment from service that shows signs of damage, wear, or defect. The following inspection checklist applies:
Full Body Harness Inspection
- Check all webbing for cuts, fraying, abrasion, burns, chemical damage, or UV degradation
- Check stitching for pulled, cut, or broken threads
- Check buckles, D-rings, and grommets for cracks, corrosion, deformation, or sharp edges
- Check labels for legibility — if the manufacturer's label is not readable, the harness must be retired
- Confirm the harness has not been involved in a fall arrest event — any harness that has arrested a fall must be immediately removed from service and destroyed
Lanyard and Energy Absorber Inspection
- Check the lanyard rope, webbing, or cable for cuts, fraying, kinking, or corrosion
- Check snap hooks for proper gate closure, locking mechanism, and deformation
- Check the energy absorber pack for any signs of deployment (stitching torn or pack elongated) — if deployed, destroy immediately
- Check carabiner gates for smooth operation and auto-locking function
Self-Retracting Lifeline (SRL) Inspection
- Check the housing for cracks, dents, or corrosion
- Pull out the cable or webbing and check for damage, then allow it to retract — it should retract smoothly under slight tension
- Test the braking mechanism by pulling sharply — it should lock immediately
- Check the snap hook or carabiner at the end for proper function
- Verify that annual recertification by the manufacturer or qualified service centre is current
9. Rescue Planning
Every work activity that involves fall arrest must have a rescue plan. Under O. Reg. 213/91, the constructor must develop and implement written rescue procedures before any fall arrest system is used on a project. This is not optional — it is a legal requirement.
Rescue planning must address:
- Suspension trauma: A worker suspended in a harness after a fall arrest can develop suspension trauma (orthostatic intolerance) within minutes. Blood pools in the legs, leading to loss of consciousness and potentially death. Rescue must be effected as quickly as possible — industry best practice is within 6 minutes.
- Rescue method: How will the worker be reached and brought down? Options include aerial work platforms, ladders, self-rescue devices, rope rescue by trained personnel, or emergency services. Relying solely on calling 911 is not an acceptable rescue plan — response times are too variable.
- Equipment: Rescue equipment must be on site, accessible, and in good condition before elevated work begins.
- Training: Workers involved in rescue must be trained in the specific rescue procedures for the site and equipment in use.
- Communication: A reliable means of communication (radio, phone) must be available to summon help immediately.
Critical: "Call 911" is not a rescue plan. If a worker is suspended in a harness 12 metres above the ground, emergency services may not have the equipment or access to reach them in time. HCMI requires a site-specific rescue plan that can be executed by trained on-site personnel within minutes.
10. HCMI-Specific Policies
HCMI maintains the following company policies for working at heights, which in some cases exceed the minimum regulatory requirements:
- Height threshold: HCMI requires fall protection for any work at heights of 3 metres (10 feet) or more, consistent with the Construction Regulation. However, supervisors may require fall protection at lower heights where site conditions warrant (e.g., fall to a lower level with obstructions, work near open excavations).
- 100% tie-off: Workers using fall arrest must maintain 100% tie-off at all times when at height. This means workers must use a dual-lanyard system or SRL with a secondary connection to ensure continuous attachment during transitions.
- Training verification: Supervisors must verify WAH training certification for every worker before authorizing elevated work. A copy of the worker's WAH card must be on file in the site trailer. Expired certifications are not accepted — no exceptions.
- Pre-task planning: Before any elevated work begins, the supervisor and workers must complete a pre-task hazard assessment that specifically addresses fall hazards, fall protection method, anchor points, fall distance clearance, and rescue procedures.
- Equipment standards: Only CSA-approved fall protection equipment in good condition may be used. Equipment must bear a legible manufacturer's label. Workers may not use personal fall protection equipment unless it has been inspected and approved by the HCMI site supervisor.
- Ladder safety: Ladders are for access only — not as a work platform. If work at height requires both hands or the use of tools, a scaffold, aerial platform, or other work platform with appropriate fall protection must be used.
- Scaffolding: All scaffolding on HCMI sites must be erected, modified, and dismantled by competent persons. Scaffolding must be inspected by a competent person before each work shift and after any event that may have affected its structural integrity (e.g., wind storm, impact).
- Incident response: Any fall arrest event (a worker's fall is arrested by the system) is treated as a critical incident. Work stops immediately, the worker is rescued, the equipment is removed from service and destroyed, the incident is reported, and a root cause investigation is conducted.
11. Working at Heights Checklist
Before beginning any elevated work on an HCMI site, confirm the following:
- I hold a valid WAH training certificate (not expired — valid for 3 years from date of completion)
- A copy of my WAH card is on file in the site trailer
- A pre-task hazard assessment has been completed for this specific work activity
- The fall protection method has been selected following the hierarchy (elimination, guardrails, travel restraint, fall arrest)
- I have inspected my harness, lanyard/SRL, and all connectors before use today
- The anchor point has been verified as adequate for the type of fall protection being used
- Fall distance has been calculated and there is adequate clearance below
- A written rescue plan is in place and I know the rescue procedure
- Rescue equipment is on site and accessible
- I will maintain 100% tie-off at all times while at height
- I know how to communicate an emergency from my work location
- Weather conditions are acceptable for elevated work (no high winds, lightning, ice, or heavy rain)
HCMI Policy: Working at Heights certification must be renewed every 3 years through a CPO-approved refresher program. HCMI tracks certification expiry dates and will notify workers 60 days before expiry. Workers with expired certifications will not be assigned to elevated work. Contact the HCMI Safety Department at office@churchbuilder.ca to schedule refresher training.