STAC Responds to Government Consultation on Proposed Fall Protection Regulations

In a milestone “first” for the Structure, Tower & Antenna Council, a team of STAC Members submitted last month a formal response to a government consultation on proposed new fall protection regulations.

The four-page response submitted to Employment and Social Development Canada (ESDC) in April followed the federal government’s March launch of a consultation on significant amendments that it said would help “modernize” the section on fall protection systems within the COHS Regulations.

STAC – working within the government’s 30-day consultation period – formed a project team consisting of members of STAC’s Workplace Health & Safety Committee, members of which reviewed the proposed amendments and worked together to identify and develop constructive feedback to help ensure the new regulations are both safe and practical.

“For most of us, this is probably the only time in our working careers that we’ll get a chance to help shape the government’s fall protection regulations,” said Clay Parchewsky, lead of the STAC WHS Committee and co-lead of the COHS Regulations Project. “So it’s really important that we help them get this right.”

In a notice posted in the Canada Gazette on March 18, the government said it planned to change COHS fall protection regulations, including by:

  • Updating equipment storage, maintenance and inspection requirements;
  • Requiring employers to develop fall-protection plans in consultation with a workplace committee or health and safety representative;
  • Updating the regulations to require application of the most recent version of published CSA standards;
  • Increasing the height at which a fall protection system is required (increasing from 2.4 m to 3 m);
  • Permitting the use of either CSA or ANSI approved head protection;
  • Requiring that fall-arrest systems “be designed to prevent a person from hitting the ground or an object or level below the work area during a fall.”

The proposed amendments would apply to all companies under federal regulation if they are passed into law. Importantly, because the proposed new regulations are not yet law, federally-regulated employers are still required to provide fall protection systems to employees working at 2.4 meters or higher.

The STAC working group review the proposed regulations and worked together to develop positions on each proposed change before drafting its submission to the government consultation. STAC submitted its response to ESDC on April 17 – the final day of the consultation period.

STAC would like to take this opportunity to thank everyone who got involved in this project, particularly given the tight deadlines the entire project team was forced to operate under.

The working group was led by STAC Workplace Health and Safety Committee Lead Clay Parchewsky (WesTower) and by Justin Sousa (Gravisys). Additional participants include representatives from the following companies:

  • Dave Ramdeane (Bell)
  • Owen Crabbe (Canadian Forces)
  • Gordon Lyman (eSystem Training Solutions)
  • Fabrice Blanchet and Herve Landreville (GRAVI-T ZERO)
  • Marco Simard and Craig McLellan (Nouvelle Hauteur)
  • Carm Cirillo, Sam Fadlallah and Asma Arefeen (Rogers)
  • Scott Connor (Team-1 Academy)
  • Dan Renaud (Telecon)
  • Adam Gale and Walter Wannamaker (Vertical Specialties).

STAC expects that ESDC will take several months to review the submissions it received during the consultation period and will amend its proposed changes to the COHS Regulations accordingly. STAC will provide an update to all STAC Members once the final regulations have been released, or if there are any additional consultations relating to these regulations.

In the meantime STAC’s final submission in its entirety can be viewed online here.