Don’t call me a control zone: ESDC to adopt “fall hazard zone system” name under new regs


New fall protection regulations expected for release this spring will adopt a new name for control zone systems in order “to align with the modern OHS terms,” Employment and Social Development Canada (ESDC) says.

In responses to questions posed by the STAC Rooftop Fall Protection Project Team, a representative of the ESDC Labour Program said the federal department will replace the term “control zone systems” with “fall hazard zone systems” in the new regulations.

“The term ‘control zone’ when referring to the system … will be changed to ‘fall hazard zone system’ to align with the modern OHS terms of ‘hazard’ and ‘control’,” the ESDC representative said in a February 8 email to STAC. “When only referring to the area, the term ‘fall hazard zone’ will be used.”

The email responses also indicated that the yet-to-be-finalized new regulations are being modelled after similar regulations in B.C.

“Importantly, the fall protection provisions of Part XII were modeled after the WorkSafeBC OHS regulation,” the representative said.

Below are the complete ESDC answers to the questions posed by the STAC Rooftop Fall Protection Project Team, which queried the department about the proposed requirement for “control zone monitors” (now to be called “fall hazard zone monitors”), as first proposed in a March 2017 consultation on proposed new fall protection regulations.
Additional information about the proposed new fall protection regulations can be found at the following links:
New Fall Protection Regs Coming Next Spring (Oct. 11, 2018)
STAC Responds to Government Consultation on Proposed Fall Protection Regulations
(May 8, 2017)

ESDC Responses to STAC Questions:*

*Note: ESDC reminds STAC all regulatory amendments are still being developed and are not finalized.

When utilizing a control zone system, when will the use of a fall-protection monitor be required?

Anytime any work is being completed anywhere on the rooftop site?
No, control zones are suited to rooftop work where the roof is flat and several employees are working at the same. It is unnecessary to have a control zone for one employee working on an HVAC system in the middle of the roof since this worker is not working in the control zone or for window washers working on a suspended swing stage. In fact you cannot use control zones on a temporary platform due to the small dimensions. The term “control zone” when referring to the system that includes the monitor will be changed to “fall hazard zone system” to align with the modern OHS terms of “hazard” and “control”. When only referring to the area, the term “fall hazard zone” will be used.

Importantly, the fall protection provisions of Part XII were modeled after the WorkSafeBC OHS regulation.

Anytime work is being completed within the control zone only?
Yes and when crossing a fall hazard zone to get to or from a work area.

“12.09(3) If a person needs to carry out an activity in a fall hazard zone or cross a fall hazard zone to get to or from a work area,
(a) the employer must ensure the presence of a fall hazard zone monitor whose exclusive duties are to
 (i) keep watch over the fall hazard zone whenever an activity is being carried out there, and
 (ii) ensure that the requirements of the fall protection plan are respected;
(b) the employer must install, along the border between the fall hazard zone and any other work area, a visually demarcated raised line that is not less than 900 mm but not more than 1100 mm high;”

Are individuals who carry out work activities in the control zone/red zone required to use additional fall protection?
Yes, individuals who carry out work activities in the fall hazard zone must use a personal fall protection system.

“12.09(3) If a person needs to carry out an activity in a fall hazard zone or cross a fall hazard zone to get to or from a work area … (c) the employer must ensure that a personal fall-protection system is used.”

Can individuals complete work alone under a control zone system (ie: only one person on the rooftop site)?
Yes, only if the worker does not enter the fall hazard zone, then a monitor is not needed. It is unnecessary to have a fall hazard zone system (that includes a monitor) for one worker working on an HVAC system in the middle of the roof since this worker is not working in the fall hazard zone (within 2m of an unguarded edge). This can be the case if the worker gains access to the flat roof in a manner so that they do not cross a fall hazard zone. An example is a roof access stairway in the middle of the flat roof. Another example is a ladder that reaches the flat roof and there is a short section of guardrail on both sides of the top of the ladder.