Fall-Protection Systems for Vehicles, Loads, and Rolling Stock - IPG-064

On this page

1. Subject

Interpretation of sections 12.06,12.07 and 14.1 of the Canada Occupational Health and Safety Regulations when working on vehicles, loads and rolling stock.

2. Issue

In accordance with section 12.06 of the Canada Occupational Health and Safety Regulations (COHSR), if there is a risk of injury due to falling in a circumstance described in section 12.07, the employer must, before any work activities begin, develop a fall-protection plan in consultation with the local committee or health and safety representative, and ensure that a copy of the plan is readily available in the work place for consultation.

In accordance with section 12.07 of the COHSR, the employer must provide or install a fall-protection system where work is performed on a vehicle at a height of 3 meters or more, or less than three meters where the surface on which the employee might fall would result a greater risk of injury than a solid flat surface.

3. Statement

Determine the measures that the employer must implement to ensure the protection of its employees regarding health and safety at work and to comply with subsection 12.07(2) of the COHSR, when the employer finds itself in a situation where it is not feasible to provide or put in place a fall protection system

4. Background

Where there is a risk of injury due to falling, the employer must, before any work activities begin, develop a fall-protection plan in consultation with the local committee or health and safety representative, and ensure that a copy of the plan is readily available in the work place for consultation.

On the other hand, they must provide or implement a fall protection device when the employee is working at a height of three meters:

  • On a vehicle,
  • On a load, or
  • On rolling equipment.

The same application applies if an employee is working from a height less than three meters if the surface on which the employee might fall would present a greater risk of injury than a solid flat surface.

In the event that the employee is working on a vehicle and it is not feasible to provide or put in place a fall protection system, the employer is required to submit a written report to the Head. The employer must clearly demonstrate that genuine efforts have been made to find alternative solutions.

Note: Regardless of the height at which work is performed, if there is a risk of impalement, the employer must protect people from falling onto objects that present a risk in the fall zone.

5. Sources of Hazards

Protecting employees working at heights requires, among other things, a thorough knowledge of the vehicles, loads or rolling stock combined with the conditions prevailing at the work site. Examples include:

  • Vehicles: type, configuration;
  • Loads: type, size, stowage, securement requirements;
  • Rolling Stock: type, terms of use;
  • Work Sites: customer pick-up/delivery locations not under the control of the employer, remoteness and yard configuration;

6. Selecting Fall-Protection Systems

To provide an acceptable level of fall protection, various work processes and systems can be considered. When selecting a system, the factors mentioned below should be taken into consideration.

  • Minimizing the duration and frequency of work at height;
  • Avoiding situations that are known to cause falls such as slippery surfaces for hands or feet;
  • Avoiding awkward or uncomfortable positions;
  • Avoiding tools/equipment that are not easily used; and
  • Preferring the use of fixed or portable fall-protection systems that are easy to use.

To prevent hazards and protect the health and safety of employees, section 122.2 of the Canada Labour Code provides an order of priority for preventative measures. For fall-protection systems, preventative measures include:

1. Eliminate the need to work at heights

This is the best and safest way to prevent any risk of injury from falls.

2. Modify the work site or work method

Employees can perform their duties without having to climb on the vehicle, loads or rolling stock. Locations such as terminals, inspection stations and bulk loading/unloading facilities could be equipped with raised platforms or other similar systems.

The fall-protection system can be part of an independent structure, such as. horizontal lifelines over vehicles, or platforms (retractable or collapsible) with guardrails enabling safer access to an area where there is a risk of falling.

3. Install Safety Systems on Vehicles

Employees should perform their job safely on the vehicle, load or rolling stock while it is stationary and stable. Using passive fall-protection systems such as walking platforms, guardrails, or ladders can afford protection when personal fall-protection systems are not required.

4. Use Personal Fall-Protection Systems

Employees working on elevated surfaces can be protected by fall-restraint or fall-arrest systems. The first one is designed and configured to prevent the employee from approaching an unguarded edge, while the latter is designed to arrest free falls. These systems include a wide range of protective equipment that are manufactured and installed to attach the employee to an anchor. A fall-arrest device is used when a fall-restraint device would prevent the person from being able to carry out the work.

*Fall-restraint systems should be prioritized whenever it can be implemented. *

Each fall-protection system has advantages and disadvantages. Choosing the appropriate one depends on the type of vehicles, loads and rolling stocks, as well as the circumstances in which they are used. In any event, employers and employees should consider the challenges and the options available to them.

7. Fall-Protection Plan

Per the regulation, where there is a risk of injury from a fall in a work place, the employer, in consultation with the work place committee or health and safety representative, must develop a fall protection plan as follows:

1. Analyze Job Safety

Employers must specify the hazards observed in each work area and for each task to be performed. Hence, all locations and conditions in which the employee must climb onto the vehicle, load or rolling stock must be considered. Detailed guidelines for performing a job safety analysis can be found from the Canadian Centre for Occupational Health and Safety (CCOHS). Similar job safety analysis processes are acceptable.

2. Select Fall-Protection Systems

Based on the observed hazards, the employer, in consultation with the work place health and safety committee or representative, must select the fall-protection systems that would provide the most safety. Selection can be based on the principles outlined in section VI of this IPG

For more information, consult section IX of this IPG, Fall-protection systems for different situations.

More than one system may be required depending on the vehicle, load, rolling stock and working conditions.

When a personal fall-protection system is selected, the required anchorage must be in the plan. For a fall-arrest system, the plan must specify the clearance distance below each work area.

3. Take into account the manufacturer's Instructions

Manufacturer's instructions regarding the maintenance, storage, inspection, fitting, installation, usage and dismantling of all fall-protection system components must be specified. When they aren't, the employer must prepare the instructions.

4. Plan Rescue Procedures

The steps to be taken to rescue the person who falls must be included.

5. Establish Instruction and Training

Instructions regarding the use of fall-protection equipment must be given by a qualified person to any person who is granted access to the workplace and who uses this equipment.

The qualified person is not required to be an employee of the employer responsible for the workplace. The employer is, however, responsible for ensuring that the instructions are given by a qualified person, which could, for example, be a clause in the service contract between an employer and a contractor.

Employees who use fall-protection equipment must be provided with both instruction and training in the use, operation and maintenance of this equipment from a qualified person.

If a fall-protection plan has been developed for a workplace, each employee who is engaged in work for the employer at that workplace must receive training from a qualified person in relation to that plan. This obligation only applies to employees of the employer, and not to people for whom the employer granted access to its workplace. However, the employer must ensure that a summary of the instruction and training are recorded in writing and easily accessible for consultation purposes to employees and people granted access.

Training will cover the various components of fall-protection systems and their proper usage.

Training must include the following:

  • the observed hazards related to working on a vehicle, a load or rolling stock, considering the work environment of the activity to be performed;
  • any tasks in the workplace that require fall protection;
  • the type of fall-protection system required for the task being performed;
  • the anchorage to be selected for the personal fall-protection system;
  • the clearance under each work area if a fall-protection system is used; and,
  • the appropriate procedures for storing, maintaining, inspecting, testing, adjusting, installing, using, and dismantling fall-protection systems, in addition to the procedures for keeping fall-protection systems in proper condition.

8. Report to the Head

When an employer determines that it is not feasible to provide or put in place a fall-protection system where an employee is required to work on a vehicle, the employer must submit a written report to the Head, providing the following information:

  • Circumstances
    Explanation as to how the employer came to this conclusion (subsection 12.07(2) of the COHSR). The employer must clearly demonstrate that it has made a real effort to find an alternative.
  • Job Safety Analysis
    It must be carried out in consultation with the policy committee or, if there is no policy committee, the work place committee or the health and safety representative (subsection 12.07(2) of the COHSR).
  • Training and Instruction
    Description as required by the COSHR;
  • Any Additional Information
    To support the employer's position.

Job safety analysis, instructions and training must be reviewed every two years.

9. Fall-Protection Based on Different Situations

1. Working on Vehicles or With Regular Loads

When employees use "conventional" vehicles or carry "conventional" loads, such as tanker trucks or regular trailers, the systems mentioned below may be considered for use separately or in conjunction:

  • Ladders
    • Ladders should preferably be fixed to the vehicle and be continuous from bumper height to the top of the vehicle or to the highest level required for the task.
      • Side rails or hand holds shall be continuous and extend to the highest level required to maintain a three-point hand/foot position.
      • Rungs shall be spaced away from the vehicle to allow placement of the feet including the heel and provide a flat, non-slip surface.
      • The width and spacing of the steps shall be sufficient to allow employees to safely ascend/descend without loss of balance or position.
    • Portable ladders may be considered for use if they meet the above requirements and are secured against movement.
  • Walking Platforms
    • Walking surfaces on vehicles and rolling stock must be fixed and constructed of a material that provides a continuous, non-slip surface in all weather conditions. The width shall be sufficient to allow worker movement without loss of balance.
    • Where there is a risk of falling, such platforms shall be equipped with fixed or folding guardrails. If the platform is not on top of the vehicle, the guardrail must be located at the outer edge of the platform. If the platform is located on top of the vehicle or rolling stock, the guardrail must be located on both sides of the platform.
  • Guardrails
    • Where feasible, all walking platforms should be equipped with guardrails designed to withstand a minimum horizontal force of 890 N. The height of the guardrail in the vertical position should not be less than 900 mm and there should be a horizontal cross member in between. If there is a danger of tools or other objects falling off the walking platform, toe-boards are required.
  • Horizontal Lifeline
    • As much as possible, the horizontal lifeline should be arranged so that it provides a fall-restraint system (i.e., to restrict rather than arrest a potential fall).
    • Its positioning along the centerline of the vehicle used in combination with a lifeline and safety harness provides better protection than if it is attached to either side of the vehicle, since the free fall distance will be greater in the latter case and the strength of the anchor points and lifeline must be higher. Preference should be given to systems that allow a shorter fall distance.

2. Unusual Vehicles/Loads

Some employees operate vehicles with non-standard designs while others carry non-standard loads. Here are some examples of fall protection measures based on the following vehicles:

  • Auto haulers
    • The nature of the work requires drivers to load and unload vehicles using ramps. They enter and exit vehicles in various configurations. The loading and platform configuration can be varied to accommodate if needed.
    • All of these variables make it difficult to adopt standard fall-protection systems. However, a system of fixed ladders, vertical or horizontal hand holds, and platforms that allow employees to maintain a 3-point hand-foot position while ascending or descending or traversing to/from the auto hauler and vehicle transported will normally be considered adequate.
  • Bulk Carriers
    • Employees may be required to work inside a bulk or on top of a load. When there is a risk of falling outside the perimeter of the bulk or load, fall protection must be provided.
    • A fall-restraint system should be considered first, and a fall-arrest system should only be used if it is impossible to prevent the fall from occurring.
  • Flatbed Trailers
    • Transporting irregularly shaped loads on flatbed trailers (logs, pipes, machinery, etc.) can be dangerous. The rounded, sloped or different types of surfaces, including irregular or slippery surfaces of the loads, increase the risk of falls, especially in the winter and on uneven ground. In addition, loading/unloading activities often take place in areas where there are no permanent installations. Also, the securing and handling of irregularly shaped loads often requires employees to stand on top of the loads, which increases the risk of falling. Employees may use static lines along the centerline of the load or work from a fixed platform. At all times, employees must be protected from falls if they are working at a height of 3 m or more above the nearest safe permanent level or at a height of less than 3 m, if the surface on which the person could fall would result in a greater risk of injury than a solid flat surface.

3. Aerial Device

According to subsection 12.09 (8) of the COHSR, the employer must ensure that each person uses a fall-restraint system when working on an aerial device, which is intended to position personnel and their tools and materials at elevated work locations. The anchorage must be specified by the manufacturer or determined by an engineer and that meets the requirements set out in CSA Group Standard Z259.16. Here are some examples of aerial devices:

  • Elevating Platform
    • This work platform is attached to an extendible or articulating support.
  • Vehicle-Mounted Elevating Platform (bucket truck)
    • This boom-type elevating platform is connected to an extendible or articulating support that is mounted on a vehicle. The elevating functions of the aerial platform are typically controlled from the platform, often with a secondary "overriding" set of controls in the vehicle, whereas the mobile functions of the vehicle are typically controlled only from the vehicle.
  • Scissor Lift Platform
    • This equipment with an integrated mobile power source and extendible supports is connected to an elevating platform, which can be elevated vertically but cannot be positioned completely beyond the base of the equipment. The mobile and elevating functions of the equipment are typically controlled from the platform.
  • Boom-Type Elevating Work Platform (boom lift)
    • This equipment with an integrated mobile power source and extendible support is connected to an elevating platform, which can be positioned completely beyond the base of the equipment. The mobile and elevating functions of the equipment are typically controlled from the platform.

10. Materials Handling Equipment Under Section 14.1 of the COHSR

Materials handling equipment consists of support structures, auxiliary equipment and rigging. It is used to transport, lift, move or place persons, materials, goods or objects. This definition excludes elevating devices permanently installed in a building, but includes mobile devices used to lift, hoist or place persons, materials, goods or objects.

The employer shall ensure that any person working on materials handling equipment (for example, a forklift equipped with a lifting platform for employees) at a height of three metres or more, or at a height of less than three metres, where the surface on which the person could fall would result in a greater risk of injury than a solid, flat surface, shall be protected by a fall protection system in accordance with the fall protection plan.

Page details

2026-07-13