6.1 Comprehensive Fall Protection Planning (CR 10 Requirements)
Key Takeaways
Construction Regulation 1 defines fall risk as any potential exposure to falling from, off or into; CR 10 has no 2-metre threshold.
CR 10(1) requires the contractor to designate a competent person to prepare the fall protection plan, keep it implemented, amended and maintained, and ensure continued adherence; CR 10(3) requires the construction manager to hold the latest version.
CR 10(2) requires the plan to cover a risk assessment per location, medical fitness evaluation, training, equipment inspection and maintenance, and a rescue plan that is implemented immediately after a fall.
CR 10(4)(a) requires openings and edges to be guarded or barricaded, and CR 10(4)(d) allows fall arrest equipment only where fall prevention equipment is not reasonably practicable.
CR 10(5) adds roof work conditions: planning, competent erectors, no work in inclement weather, strong covers, support over fragile material, and guardrails, barriers and toe-boards.
1. Statutory Architecture and Hazard-Based Scope of Construction Regulation 10
Falls from height are a leading cause of fatal and permanently disabling injuries in South African construction. Construction Regulation 10 (CR 10) governs all work where a fall risk exists, and its definitions in CR 1 are deliberately hazard-based rather than height-based:
- "Fall risk" means any potential exposure to falling either from, off or into. There is no 2-metre trigger in CR 10: a worker beside an unprotected 1.4-metre trench edge or an open riser shaft is exposed to a fall risk just as a steel erector at 30 metres is.
- "Fall protection plan" means a documented plan that includes and provides for (a) all risks relating to working from a fall risk position, considering the nature of the work; (b) the procedures and methods to be applied to eliminate the risk of falling; and (c) a rescue plan and procedures.
- "Fall prevention equipment" prevents persons from falling from a fall risk position: guardrails, screens, barricades and anchorages, but also personal equipment such as a body harness, lanyards and lifelines when used in restraint.
- "Fall arrest equipment" arrests a person in a fall: harnesses, lanyards, deceleration devices, lifelines or similar equipment.
Other instruments overlap: the General Safety Regulations prohibit work in an elevated position unless it is performed safely, SANS 10085-1 requires guardrails and toeboards on scaffold platforms from which a person could fall more than 2 m, and CR 18 requires a site-specific fall protection plan before any rope access work.
2. The Contractor's Duties under CR 10(1) and 10(3)
Under CR 10(1) a contractor must:
- (a) designate a competent person to be responsible for the preparation of a fall protection plan;
- (b) ensure that the plan is implemented, amended where and when necessary, and maintained; and
- (c) take steps to ensure continued adherence to the plan.
CR 10(3) adds that the contractor must ensure that the construction manager appointed under CR 8(1) is in possession of the most recently updated version of the plan. The person designated under CR 10(1)(a) must meet the CR 1 definition of competence: task-specific knowledge, training, experience and, where applicable, registered qualifications, plus familiarity with the Act and Regulations. Generic plans imported from another project fail the definition's first element, because they do not address "all risks relating to working from a fall risk position" on this site.
3. The Five Required Contents of the Plan (CR 10(2))
| CR 10(2) | The plan must include | What this looks like on site |
|---|---|---|
| (a) | A risk assessment of all work carried out from a fall risk position, and the procedures and methods to address all the risks per location | Floor-by-floor and task-by-task assessment: slab edges, shafts, roofs, scaffolds, precast placement, wind and rain limits |
| (b) | The processes for evaluating employees' medical fitness to work at a fall risk position, and the records | Annexure 3 certificates (CR 7(8)) stating fitness for work at height, issued by an occupational health practitioner; tracking of expiry dates and restrictions |
| (c) | A training programme for employees working from a fall risk position, and the records | Accredited fall arrest or restraint training, harness fitting, anchor selection, rescue drills; training matrix |
| (d) | The procedure for inspection, testing and maintenance of all fall protection equipment | Pre-use checks by the user, periodic documented inspections by a competent person, withdrawal of equipment that has arrested a fall |
| (e) | A rescue plan detailing the procedure, personnel and suitable equipment needed to rescue a person after a fall incident, so that rescue is implemented immediately | Rescue kits at the workface, trained rescuers on every shift, drills, and EMS contact as back-up rather than the plan itself |
Medical fitness (CR 10(2)(b)): the regulation requires a process and records, and CR 7(8) supplies the instrument. The occupational health practitioner decides fitness; conditions typically considered include vertigo and balance disorders, epilepsy or other causes of sudden loss of consciousness, uncontrolled hypertension or diabetes, and visual impairment. The CHSM's role is to ensure that certificates are specific to work at height and that restrictions (for example "fit, ground level only") are enforced.
Rescue (CR 10(2)(e)): a plan that says "call the fire brigade" does not ensure that rescue is implemented immediately after the fall, because public responders may take far longer than a suspended worker can tolerate. Section 7.1 explains suspension intolerance and the practical rescue methods.
4. Specific Precautions under CR 10(4)
Whatever the plan says, CR 10(4) requires the contractor to ensure that:
- (a) all unprotected openings in floors, edges, slabs, hatchways and stairways are adequately guarded, fenced or barricaded, or that similar means are used to prevent anyone falling through;
- (b) no person is required to work in a fall risk position unless the work is performed safely as contemplated in the plan;
- (c) fall prevention and fall arrest equipment is approved as suitable and of sufficient strength for the purpose and load, and is securely attached to a structure or plant that is itself suitable and strong enough to support the equipment and any person who could fall; and
- (d) fall arrest equipment is used only where it is not reasonably practicable to use fall prevention equipment.
Paragraph (d) is the regulatory form of the hierarchy of controls for work at height: eliminate the fall (design, prefabrication at ground level), then prevent it (guardrails, covers, platforms, mobile elevating work platforms, restraint), and only then arrest it.
5. Roof Work (CR 10(5))
Where roof work is performed, the plan must also show that:
- (a) the roof work has been properly planned;
- (b) the roof erectors are competent;
- (c) no employee is permitted to work on roofs during inclement weather or other hazardous conditions;
- (d) all covers to openings and fragile material are strong enough to withstand any imposed loads;
- (e) suitable platforms, coverings or similar means of support are provided so that the weight of anyone crossing or working on fragile material is supported; and
- (f) suitable guardrails, barriers and toe-boards prevent, as far as reasonably practicable, the fall of any person, material or equipment.
Fragile roofs (aged asbestos-cement, fibre-cement and translucent sheeting) cause fall-through fatalities from low heights, so crawl boards spanning purlins and protection beneath are normal controls.
6. Reviewing and Amending the Plan
Because CR 10(1)(b) requires the plan to be amended where and when necessary, the designated person should revise it whenever site conditions or the structure change, new access equipment or methods are introduced (climbing formwork, cantilever platforms, rope access), trade sequencing changes, or a fall, near-miss or inspection reveals a weakness. Each revision must reach the construction manager (CR 10(3)) and be briefed to the affected workers.
7. Fall Prevention vs Fall Arrest
| Parameter | Fall Prevention (including restraint) | Fall Arrest |
|---|---|---|
| Philosophy | Stops the fall happening | Accepts the fall and stops it safely |
| Protects | Collective systems protect everyone; restraint protects the user | Only the attached worker |
| Examples | Guardrails, toe-boards, covers, catch platforms, MEWPs, restraint lanyards | Harness with energy-absorbing lanyard or self-retracting lifeline to a certified anchor |
| Dependence on behaviour | Low for collective systems | High: correct fitting, anchoring and continuous tie-off |
| Clearance needed below | None | Several metres (see Section 7.1) |
| Rescue demand | Ordinary first aid | Immediate rescue of a suspended person (CR 10(2)(e)) |
| Regulatory position | Required first (CR 10(4)(a), (d)) | Only where prevention is not reasonably practicable (CR 10(4)(d)) |
8. The CHSM's Role
The Construction Health and Safety Manager audits the plan against CR 10(2) and (4), checks that the person designated under CR 10(1)(a) is competent, verifies that medical certificates, training records and equipment inspection records exist for every worker in a fall risk position, and confirms through drills that the rescue plan actually works on each part of the site.
A structural steel contractor is erecting roof trusses 9 meters above ground on a logistics warehouse in Midrand. A newly hired rigger presents a general construction medical certificate of fitness from a local general medical practitioner (GP). However, the contractor's Fall Protection Plan requires specialized clearance under Construction Regulation 10(2)(b). What is the legal requirement for medical fitness certification for workers in fall-risk positions?
The GP certificate is legally acceptable provided the general practitioner has at least five years of clinical experience in treating sports injuries and occupational wounds.
The contractor may waive the medical certificate if the rigger signs a voluntary indemnity declaration confirming that they do not suffer from acrophobia.
An Annexure 3 certificate for work at height, and a fitness evaluation process recorded in the fall protection plan (CR 10(2)(b)).
Medical fitness certification is only legally required under CR 10 if the working height exceeds 15 meters or if work occurs over open water or deep excavations.
A contractor's fall protection plan for roof sheeting work states only: 'In the event of a fall, call the municipal fire department.' The nearest station reports a typical response time of 30 to 45 minutes. When auditing the plan against Construction Regulation 10(2)(e), what should the CHS Manager conclude?
The plan is compliant provided every roofer carries a mobile phone and the site has a first aid box at ground level.
The plan is non-compliant only if the roof is higher than 15 metres; below that height external rescue is acceptable.
The plan is compliant, because CR 10(2)(e) only requires the plan to name an external rescue service and its telephone number.
Non-compliant: CR 10(2)(e) requires a rescue plan that can be implemented immediately after a fall.
A contractor is replacing sheeting on an old factory roof made of weathered asbestos-cement sheets. The fall protection plan covers harnesses and edge protection at the eaves but says nothing else about the roof surface. Which additional matters must the plan show under Construction Regulation 10(5)?
Nothing further, because CR 10(5) applies only to new roofs and not to maintenance or replacement work on existing roofs.
Planned work, competent erectors, no work in bad weather, supported crossings of fragile material, and edge protection.
Only that the roof erectors have signed indemnity forms accepting the risk of working on fragile material.
That the roof sheets will be painted with a high-visibility coating so that workers can see where they are stepping.
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