Representatives from across the warfare communities and Marine Corps comprise the Navy’s Fall Protection Working Group, which met at the Naval Safety Command July 18-20 to review current policies in place for the Fall Protection Program and propose updates to Chapter 13 of OPNAV M-5100.23. Additionally, the working group reviewed and updated the Department of the Navy’s Fall Protection Guide.

Falls from height are the second-leading unintentional fatal workplace event, according to the National Safety Council. Workers in the construction industry are most at risk, with the most nonfatal cases involving days away from work and 20% of all nonfatal fall-from-height cases each year.

In its first year, NAVSAFECOM’s local area assessments noted 168 fall protection discrepancies, ranging from poorly maintained handrails to a lack of a unit fall protection program. Since 2017, the Navy has incurred four fatal falls, of which three could have been mitigated under the Fall Protection Program, based on data from the Risk Management Information safety reporting system.

These statistics underscore the importance of the working group’s purpose. During the first two days, the working group conducted a comprehensive review of OPNAV M-5100.23, Chapter 13, and OPNAVINST 5100.19F, Chapter 13 in an effort to update the chapters to reflect changes in regulatory requirements.

“The intent is to eventually merge these two chapters into one cohesive chapter that encompasses all fall protection requirements for all warfare areas, providing the end user a singular document for all fall protection requirements,” said Charles Gum, Shore Directorate deputy director, NAVSAFECOM. Requirements that are specific to a particular warfare area or community will be added as an addendum to the singular chapter.

Forming one, cohesive fall protection chapter across all warfare communities will make it easier to understand and allow people to access just one place to find policy, said Gum.

Before the group got started, Gum provided a quick refresher of the current safety and occupational health hierarchy:
 

• Department of Defense Instruction (6055.01-SOH)
  • DoN Safety Program (SECNAVINST 5100.10)
    • Navy Safety Program Manual (5100.23)
      • Community-Specific Safety Guidance (OPNAVINST 5100.19, 3750, etc.)
        • Headquarters/Immediate Superior in Command (ISIC) Guidance, Local Standard Operating Procedures and Instructions

Gum noted OPNAV M-5100.23 provides the “what” in the regulatory requirements. The instruction outlines the Echelon 1 perspective and is specific in some areas only to ensure consistency and uniformity.

The Headquarters, ISIC and local instructions describe the “how, what and who” performs the requirements spelled out in the OPNAV instruction. Every organization executes its processes a bit differently. These local instructions allow organizations to tailor their processes in a way that works best for them, as long as they meet the requirements, said Gum.

“The 5100.23 is the Navy’s top-tier instruction,” said Gum. “One of the reasons we’re merging is to alleviate the end user from having to find multiple instructions; 5100.23 will be the one instruction. No longer will people say, ‘I’m from the afloat community, so I’m only going to read the afloat instruction.’”

Gum noted there was a time when 5100.23 was named the ashore manual. It no longer says that in order to reinforce it is the Navy’s overarching Occupational Safety and Health Manual that all other safety manuals across all warfare areas should align to.

The working group also focused on removing duplicative or obsolete information from the instructions. Proposals were made to clarify and remove ambiguous phrasing and ensure processes were up to date and aligned with current policy. For example, the working group removed the mandatory minimum cumulative training-hour requirements for various positions within the fall protection program and replaced them with training syllabus topics required for the position to allow commands more flexibility in training their personnel.

The last two days of the meeting were spent revising the Fall Protection Guide, which was last updated three years ago.

“There’s been a misunderstanding that the guide is actually policy, and it is not,” said Gum. “There is guidance in the front of the guide that leads people to believe it is policy. It was intended to be designed as a guide – not to mimic policy. That understanding has been blurred.”

To correct this perception, the group updated the glossary and removed obsolete and duplicate definitions. Proposed comments were made throughout the document to remove any language that was directive in nature.

The group also clarified sections and terminology throughout, tightening the verbiage and ensuring consistency.

“The guide is an important asset for Sailors and Marines, and we believe the updates will enhance their fall protection programs and serve as a complement to the OPNAV policy,” said Gum.

The updated Fall Protection Guide is expected to be released to the naval enterprise in late September 2023. The updated Chapter 13 of OPNAV M-5100.23 will be released next year due to the time it takes for all stakeholders to concur on content.