Prevent Dropped Objects (PDO) Framework

American Wind Energy Association I www.awea.org

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Prevent Dropped Objects (PDO) Framework

Our purpose:

This framework is designed to help companies assess their current PDO program and achieve continuous improvement in the prevention of dropped objects using a risk-based approach to identify and assess vulnerabilities, prevent drop object incidents, enhance training and program capabilities, and improve employee practices.

Prevention of Dropped Objects Framework:

This framework is based on Deming’s PLAN, DO, CHECK, ACT cycle which is familiar to many organizations and has the benefit of being both practical and effective in delivering improved organizational performance.

We recognize that many, if not all, companies already have some type of PDO program in place. Thus, the intention is not to introduce another one. The underlying purpose of this framework is to provide guidance and enable companies to review their own position. This framework has been written to provide flexibility to companies on how it is implemented. One company may use it directly while another may enhance it with more detailed implementation guidance which reflects additional needs of their business or may simply use it to measure their existing program. This approach provides good flexibility while still providing a common framework.

Implementation of the PDO Framework:

This PDO framework has been written with the expectation that it will help companies, of all sizes, advance their existing dropped objects program or introduce one if they do not have one. The framework supports companies in defining their own dropped object policy, objectives, priorities and performance targets.

The PDO Framework is composed of the seven elements listed below. Each element contains one or more activities.

1. Leadership & Commitment 2. Team

3. Analysis 4. Program5. Equipment Selection 6. Training

7. Measuring

Measurement is an important aspect of developing, maintaining and improving a PDO program. Each of the elements listed above and the elements activities are provided in a measurable format to allow companies to assess their progress in controlling dropped items.

Scoring Elements:

This framework incorporates PDO best management practices. It enables companies to evaluate and improve their PDO programs. The framework provides a means to perform a self-assessment and allow a company to score elements of their PDO program.

Elements are scored on a scale of one to four. Each number representing the following:

0. Not Applicable (NA) – the element is not applicable to the type of activity being performed by the organization.

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1. Evaluating Element (EE) – planning implementation of the element.

2. Implementing Element (IE) - in the process of putting the element in place. This includes writing the policies, training employees, procuring equipment.

3. Element in Place (EP) - the element is implemented, has been audited at least once and has a corrective actions process to fill any gaps.

4. Assessing Element (AE) - the element is a mature standard practice, audited annually and continuous improvement to the element is documented.

For each element, check the box you feel most represents your organization’s progress in that particular element. Your checkmark represents your score for that element. For example if you are scoring element 1.2 and you checked the third box to the right of that element. You are in the process of Implementing Element (IE) which equals two (2) points. You score elements 1.1 through 1.5 in the same manner. Check only one box per element. Next, determine the average score for all elements in section 1, 1.1 through 1.5. Enter the average in the shaded box to the far right of the title of the element. You are now complete scoring element 1. Continue the same scoring method for all elements.

When marking an element not applicable, that element will be removed from the average of the elements in the section it is marked. For example, you score elements 1.1 through 1.4 and mark element 1.5 as not applicable (NA). To determine your average, take the total of the scores for elements 1.1 through 1.4 and divide that total by four (4) to determine your average for element 1.

Benchmarking:

The objective of this framework is for companies to understand and evaluate their existing PDO program in relation to the elements forthcoming and to identify areas and means of performance improvement.

Benchmarking involves looking outward, outside a particular company to the industry, region or country in which they operate to examine how other wind industry companies achieve their PDO performance levels and to understand the processes they use. When the lessons learnt from a benchmarking exercise are applied appropriately, they can facilitate improved performance.

Benchmarking is an integral part of the continuous improvement cycle. Application of PDO benchmarking requires four key steps:

1. Analyze and understand in detail your existing PDO process using the elements below as a guide

2. Compare your own PDO process to the results of others who have used the same comparative elements contained in this framework

3. Implement the steps necessary to close any gap

PDO benchmarking is not a one-off exercise. To be effective, it must become an ongoing, integral part of a PDO improvement process with the goal of keeping abreast of ever-improving best practice.

Collecting Data:

Annually as part of its illness and injury data collection process AWEA will include a survey of the elements contained in this PDO framework for companies to respond too. The results of the survey will be published with the illness and injury data survey. A participant’s identity in the PDO survey will be handled in the same manner as in the injury/illness survey.

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1. Leadership & Commitment N/A (0) EE (1) IE (2) EP (3) AE (4)

1.1. Define the objectives including those for achieving improvement and/or for the management and control of risks associated with dropped objects (DOs).

1.2. Visibly support the achievement of the PDO programs, objectives and targets.

1.3. Employees have the opportunity to participate in the development, implementation and review of the PDO program.

1.4. Allocate the necessary resources to support and implement the PDO program.

1.5. Targets are set at all relevant levels of the company to deliver the objectives of PDO program.

2. PDO Team N/A (0) EE (1) IE (2) EP (3) AE (4)

2.1. Cross functional team is formed to establish expectations and program to ensure all personnel performing service and maintenance are protected from objects falling from above.

2.2. The PDO team includes all stakeholders, Safety, Operations, Management, Projects, Site Management, and Technicians

2.3. Develops and analyzes dropped object data.

2.4. Develops objectives and procedures to ensure all personnel performing work on wind turbines are protected from objects falling from above.

2.5. The PDO Team selects equipment to meet the needs of the work practices and work environment, based on the analysis of the available data.

2.6. Field trials of drop prevention tools by end users are conducted.

2.7. Approved list of DO equipment is created and budgeted.

2.8. PDO equipment is readily available to employees.

2.9. Develop training for the PDO program.

3. Analysis N/A (0) EE (1) IE (2) EP (3) AE (4)

3.1. Data on dropped object incidents is reported and recorded.

3.2. Data is analyzed by category: item dropped, item dropped location, work activity, cause, etc.

3.3. Hazards associated with dropped objects are identified: equipment, materials, work practices, procedures, work environment, etc.

3.4. An analysis of dropped object controls in place, if any,

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and which were lacking or failed at the time of the incident.

3.5. Conduct analysis (e.g., Pareto or similar) of data to determine program needs.

PDO Program

4.1 Scope N/A (0) EE (1) IE (2) EP (3) AE (4)

1.1.2.3.4.

4.1.1. The program applies to all personnel, including contractors.

4.1.2. The program covers activities during the construction, service and repair of wind turbine machinery or equipment in which there is an exposure to a dropped object.

1.2.3.4.

4.14.2 Program Responsibilities

N/A (0) EE (1) IE (2) EP (3) AE (4)

1.1.2.3.4.4.14.24.2.1 Managers ensure employees have understood the

PDO Program and completed associated training.4.2.2 Managers ensure employees adhere to the rules

and best practices contained within the PDO program.

4.2.3 Manager provides equipment needed to perform tasks safely and to prevent the occurrence of dropped objects.

4.2.4 Manager conducts a thorough investigation of all dropped object incidents.

4.2.5 The manager formulates corrective actions designed to eliminate dropped objects.

4.2.6 Employees complete training on PDO Program.4.2.7 Employees adhere to PDO Program requirements.4.2.8 Employees bring to site management’s attention all

unsafe or hazardous conditions or actions that may result in dropped objects that may cause injury or

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property damage before proceeding with their workplace activities.

4.2.9 The company has a process to maintain and update PDO Program as needed.

4.2.10 The company conducts a thorough investigation of all dropped object incidents and formulates corrective actions designed to eliminate dropped objects.

4.2.114.2.12 The company provides resources for the

development and delivery of training related to the program.

4.2.13 The company identifies and approves and provides resources for all equipment related to this program.

4.3 General Requirements N/A (0) EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.3.1. All employees, contractors, and visitors are made

aware of the hazards associated with dropped objects.

4.3.2. Before any task a Permit to Work and Job Safety Analysis must assess the possibility of dropped objects and eliminate or mitigate the hazards.

4.3.3. No person will position themselves below the work of others.

4.3.4. Persons performing work shall ensure others do not enter the area below where the possibility of dropped objects may exist.

4.3.5. All WTG hatches remain closed when not in use.

4.3.6. All personnel assess openings, activities, and conditions that create a hazard for dropped items and seek corrective actions to mitigate or eliminate those hazards.

4.3.7. All unnecessary items; including loose nuts, bolts, unused parts, tools, will be removed from the WTG.

4.3.8. All items stored within the WTG including parts, equipment, products, and tooling must be stored within a closed top container when not in use. Examples of closed top containers are lidded totes and closed top bags.

4.3.9. No items, including closed top containers, are stored closer than four (4) feet from open hatches

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or other unprotected opening that expose the object to a fall. This includes hatches, air vents, any other unprotected opening.

4.3.10. Tool, equipment and part security is addressed before beginning work in a Permit to Work or JSA

4.3.11. Unsecured tools, equipment, and parts shall be kept a minimum of four (4) feet away from any unprotected opening or edge. Unprotected openings and edges include; hatches, air vents, nacelle roof edges, cable ways, and other openings.

4.3.12. Radios are secured in a manufacturer or approved radio holster and tools are carried in approved closing pouches.

4.4. Practices N/A (0) EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.4.1. Do not use a tool tether with lower weight limits

than the tool being tethered4.4.2. Do not tether a tool that exceeds 10 lbs. to a

person. Anchor all tools weighing more than 10 lbs. to a structure.

4.4.3. Do not tether a tool to a person without verifying the impact on the person’s personal fall protection devices

4.4.4. Do not attach a tool tether to a structure without verifying the anchor point’s strength and shock-load capability

4.4.5. Do not use tethers or lanyards that require excessive force for full extension

4.4.6. Do not modify the tool lanyard in any way

4.4.7. Do not customize the tool lanyard with hardware that does not have the appropriate load ratings for the tool.

4.4.8. Do not assume that a tool tether is a foolproof device.

4.4.9. Do not use a tool lanyard as a personal fall protection lanyard.

4.4.10. Do not use tool tethers in situations where machinery entanglement is a concern.

4.4.11. Verify a tether’s integrity before use, looking for indications of excessive wear or fatigue.

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4.4.12. Always use a lanyard that is rated properly for the tool weight, provided that the lanyard is designed with a 25% additional margin for a full extension drop.

4.4.13. Verify the tool’s attachment point to ensure that it is strong enough to hold the tool for the full drop distance of the tether.

4.4.14. Weigh tools so that a properly rated lanyard is used for the application.

4.4.15. Use a quick-release tether when a group of small tools is being used.

4.4.16. Use a retractable tether to avoid entanglement issues when multiple tethers are needed.

4.4.17. Anchor all tools weighing more than 10 lb to a structure, not a person.

4.4.18. Use lanyards that have low stretch force at full extension as long as they have the proper degree of recoil for the tool and application.

4.4.19. Transfer shock loads from a person to a structure whenever possible.

4.5. Practices and Work Location – Tower Base N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.5.4.5.1. Vehicles are parked a minimum of sixty (60) feet

from the base of the turbine and parked upwind whenever possible.

4.5.2. Before entering this area communications must be established with tower personnel by radio or cell phone.

4.6. Practices During Hoisting Operations N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.5.4.6.

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4.6.1. Personnel are not allowed within a sixty (60) foot perimeter during hoisting operations.

4.6.2. Only load rated bags with top closure are permitted for use.

4.6.3. Non-rated items are placed in rated/closing bags or slings prior to hoisting to prevent failures.

4.6.4. Vehicles must exit the sixty (60) foot perimeter before hoist hatch is opened.

4.7. Practices in the Tower N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.5.4.6.4.7.4.7.1. Only one (1) person is allowed on an individual

ladder section at one time.4.7.2. No one is allowed within the tower at the base or

on section platforms when work is being performed on the ladder above.

4.7.3. All hatches must remain closed unless in use.

4.8. Practices in the Nacelle – Hoisting Operation N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.5.4.6.4.7.4.8.4.8.1. Remove any loose objects in the vicinity of the hoist

hatch prior to opening.4.8.2. Ensure hatch cover is either secured by tether or

moved to a safe distance (4 feet) from hatch opening.

4.8.3. Ensure load is free when hoisting through the hatch opening, do not attempt to pull free obstructed

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loads.4.8.4. After removing loads from hoist hook, move load a

minimum of four (4) feet from hatch opening or secure by lanyard

4.8.5. Close hatch after hoisting operations are completed.

4.9. Practices on the Top of the Nacelle N/A EE (1) IE (2) EP (3) AE (4)

4.9.1. All areas on top of the nacelle require safeguards against dropped objects.

4.9.2. When work is performed on top of the nacelle, including travel to and from the hub, no personnel or vehicles are allowed in a radius sixty (60) feet from the tower base.

4.10. Practices in the Hub N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.4.1.4.2.4.3.4.4.4.5.4.6.4.7.4.8.4.9.4.10.4.10.1. All areas while traveling to the hub and within the

nosecone are within four (4) feet of an unprotected edge or opening and all required safeguards must be implemented at all times.

5.6.7.8.8.1.8.2.8.3.8.4.8.5.8.6.8.7.8.8.8.9.8.10.8.10.1.

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8.10.2. All areas once within the hub structure should be considered to be greater than four (4) feet from an unprotected opening or edge and require no safeguards.

5. Equipment Selection – Attachment 1 provides examples of available DO equipment. N/A EE (1) IE (2) EP (3) AE (4)

5.1 PDO team uses DO assessment to determine equipment needs

5.2 Initial selection of multiple equipment solutions

5.3 Conduct field trials of DO equipment with employees

5.4 Source DO equipment

5.5 Tool/Equipment Bags, Pouches, and Holsters

5.6 Tool/Equipment Bungee Tethers

5.7 D- Rings/Quick Wrap

5.8 Magnetic trays

5.9 Radio Holsters

6. Training – attachment 2 is a sample PDO training program. N/A EE (1) IE (2) EP (3) AE (4)

6.6.1. PDO Team develops training modules6.2. Employee recognition of the types & frequency of

items dropped6.3. Identify common causes of dropped objects

6.4. Understand the hazards associated with dropped objects

6.5. Understand the requirements of the PDO Program

6.6. Become familiar with equipment and practices to prevent dropped objects

6.7. Training includes practical exercises reflective of field conditions (e.g., space constraints, similar tools, etc.)

6.8. Employee knowledge is tested and gaps addressed (use of graded tests is optional)

6.9. All new employees are trained on the PDO program and hazards of dropped items

6.10. Refresher training on dropped items occurs

7. Measurement - A PDO audit is primarily expected to quantify skill level, performance, and safety attitude, as these are the root elements of the safe work behavior that will lead to a reduction in the number and severity of dropped objects.

N/A EE (1) IE (2) EP (3) AE (4)

1.2.3.4.5.

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6.7.7.1. Field observations of compliance to PDO program

take place7.2. Employees who demonstrate compliant behavior

relating to PDO will be positively rewarded when observed

7.3. Employees who demonstrate non-compliant behavior related to PDO program will be given feedback and mentored in HSE expectations

7.4. PDO performance of all technicians observed is graded

7.5. PDO equipment is inspected and condition/availability is graded

7.6. An action plan for improving performance including corrective actions is maintained

7.7. Progress of action plan is tracked and is a key performance indicator for site management

Subject matter experts willing to assist:

Name Company Phone

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Attachment 1: Equipment

Tool bags, pouches, and holsters are used to secure tooling or other objects while not in use

Items not in use must be secured in bags, pouches, or holsters when working in the following areas:o Tower sections next to open hatches or other

unprotected openingso Climbing or working on laddero Nacelle when working next to open hoist hatch, vents,

or other unprotected openingso While working on top of the nacelleo While working in the nose coneo Any other location that creates the potential for tools or

other objects to be dropped

Tethers and lanyards are used in conjuncture with D-Rings or Quick Spins and are used to secure tooling while it is in use

Tools must be attached to lanyards or tethers when working in the following areas:o Tower sections next to open hatches or other

unprotected openingso Working while on laddero Nacelle when working next to open hoist hatch, vents,

or other unprotected openingso While working on top of the nacelleo While working in the nose coneo Any other location that creates the potential for tools in

use to be dropped

Magnetic trays must be used whenever small, metallic parts are being used within 4 feet of unprotected openings

Magnetic trays must be used when working in the following areas:o Tower sections next to open hatches or other

unprotected openingso Working while on laddero Nacelle when working next to open hoist hatch, vents, or

other unprotected openingso While working on top of the nacelleo While working in the nose coneo Any other location that creates the potential for small ,

metallic parts to be dropped

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Radio holsters must be used whenever radios are within 4 feet of unprotected openings and are not in use

Areas radio holsters must be used include:o Tower sections next to open hatches or other

unprotected openingso Climbing or working on laddero Nacelle when working next to open hoist hatch,

vents, or other unprotected openingso While working on top of the nacelleo While working in the nose coneo Any other location that creates the potential for radios

to be dropped

D-Rings and Quick Spins are fastened to hand tools and used to connect tools to lanyards and tethers

Tools must be fitted with D-Rings or Quick Spins and attached to lanyards or tethers when working in the following areas:o Tower sections next to open hatches or other

unprotected openingso Working while on laddero Nacelle when working next to open hoist hatch,

vents, or other unprotected openingso While working on top of the nacelleo While working in the nose coneo Any other location that creates the potential for hand

tools to be dropped

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