Falls are among the most common causes of serious work related injuries and deaths, and employers must take measures in their workplaces to prevent employees from falling. Occupational Safety and Health Administration (OSHA) requires employers to provide working conditions free of known hazards which are likely to cause serious injury or death. Fall protection must be provided at elevations of four feet in general industry workplaces covered under OSHA 1910 standards, and six feet in the construction industry covered under OSHA 1926 standards. Fall protection must also be provided when working over dangerous equipment and machinery, regardless of the fall distance1.

David Michaels, the assistant labor secretary who heads the U.S Labor Department’s OSHA, emphasizes the importance of saving lives by planning, training employees and providing the right equipment for fall protection. He also states in his stand-down address that the “lack of fall protection” is the most frequently cited OSHA violation2.

Employers are responsible for enforcing these regulations and water tank owners are no exception. Tank owners are required to maintain their tanks in accordance with all federal, state and local regulations that apply to each tank. The National Fire Protection Association (NFPA), American Water Works Association (AWWA) and OSHA have devised codes, timetables and standards that must be followed to help maintain tanks safely and prevent accidents.

Maintain the Tank

Tanks must be maintained in a safe and structurally sound condition to remain in compliance. Regulatory inspections, standard repairs and necessary upgrades are needed. Inspect tanks, structural attachments and the structures sites should be inspected regularly for any and all defects or hazards. Address defects such as leaks, metal loss, damaged structural support, equipment failure or environmental damage promptly to prevent further damage and greater risk of liability.

All tanks should be equipped with an access ladder and necessary fall protection and prevention devices legally required to reduce possible injuries and eliminate fall related deaths. All ladders, stairs, platforms, rails, access openings, and safety devices shall comply with OSHA standards3. Fixed ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats or steps, broken or split rails, or corroded components, shall be withdrawn from service until repaired4. Ladders shall not interfere with the opening of the hatch cover and shall not incline outward from the vertical at any point. For pedestal-supported tanks, the ladder shall be placed inside the riser which extends through the center of the tank5.


Protecting the Public and Personnel

Tank owners must protect themselves from unauthorized access. Install ladder guards, a fence and a security system with warning signs to help prevent trespassing. Tank owners should verify that those hired to perform tank services are properly trained and qualified to safely perform the needed. They must be equipped with proper fall protection and trained in the use and operation of the fall arrest equipment. OSHA requires that employers provide training. Personal fall arrests and associated equipment must be covered in formal training before the use of such equipment can be utilized by an employee. The equipment must also be inspected before each use, maintained in good condition and used properly in accordance with company policy, manufacturers’ recommendations and federal regulations6.

All components required by OSHA are necessary to have a complete and adequate fall protection system. The anchor points, full body harnesses, and connecting devices must all be used together and correctly for an effective system. If any component is defective or not used correctly, the whole fall protection system is at risk to fail. Anchor point height, lanyard length, lanyard elongation and the worker’s height should be added together along with a three-foot safety factor to find the proximal distance an employee may fall. The normal distance an employee typically falls is 18½ feet and if this distance is calculated incorrectly or if an obstruction exists in the path of the fall, the worker could still be seriously injured or killed.

Just a few years ago, a worker was killed when he fell 50 feet inside a New Jersey water tank. He was wearing a full body harness, but he did not employ the proper fall distance calculations and fell from the scaffolding, coming to rest on a solid platform between the scaffold and the ground7.

Address Safety

All job locations must be carefully planned and the crew’s foreman is required to have a Job Safety Analysis (JSA) completed by the company’s safety department before a job begins. The JSA and fall protection plan should be developed specific for each site and must be maintained and updated as needed throughout the job. Update the JSA will need to be updated if new hazards are identified, if changes to the scope of work occur, if equipment is used on site or if environmental stresses develop.

Supervisors should also hold daily toolbox meetings and weekly safety meetings at the job site to inform and focus the crew of the day’s plans, review the JSA and site documents, identify other potential hazards, and address concerns. A tank owner or other authorized person knowledgeable of the site and scope of work should be available to answer questions concerning site procedures, proper contacts and local emergency services if required.

Rescue Plan

Contractors hired by the tank owner should have a written rescue plan established before commencing work. The rescue plan should include all emergency contact information: tank owners, supervisors, local EMS agencies, and any other local or county agencies that may be of help in an emergency. The foreman is also required to identify the closest fire rescue service station and make contact with them on the nature of the job being performed, possible hazards for responders and other risk factors. All contact numbers should be posted at the job site for all employees to see.

Tank owners should also know the layout of their tanks, and the rescue plan should illustrate the capability of getting an injured or ill worker out of the tank promptly from any position on the tank. Just last year, a worker fell thirty feet inside a 150,000 gallon elevated water tank in Kansas. The worker was wearing a safety harness, but hit the side of the tank when the end of the fall protection was reached. He had to be removed from a 15-inch riser pipe hatch8. Removing an injured person out of a manhole less than 30 inches wide can be extremely difficult, so take measures prevent such a task. The location and size of all manholes and roof hatches should be addressed in the rescue plan. All manholes and roof openings should be installed in accordance with NFPA, AWWA and OSHA standards, and an OSHA-compliant standard railing should be placed around all roof manholes and other accessories that require access9.


Maintain a safe environment to protect the owner’s property, the public and those working on the tank. Fall protection equipment and devices should be inspected before each use for defects and possible malfunctions. JSA’s, fall protection plans and emergency rescue plans should be established, maintained, reviewed, and updated regularly to protect workers and assure compliance with safety rules and OSHA regulations. The tank site should also be subjected to random and periodic safety inspections to insure continued compliance.

Tank owners who do not hire a drug free workforce with qualified and competent contractors increase their risk of experiencing a fall or injury on their property. Meeting these expectations is not only a moral obligation but one that makes good business sense. C Erika Henderson is director of research for Pittsburg Tank & Tower Group. Visit their website at www.watertank.com.


1 United States Department of Labor, Occupational Safety & Health Administration. Safety and Health topics-Fall Protection.

2 Raum, Tom. 2 June, 2014. Yahoo News. Obama administration emphasizes fall protection.

3 AWWA, 2011. D100 Welded Carbon Steel Tanks for Water Storage: Section 7.

4 Access. 4 OSHA Standards, 1991. Construction Industry (29 CFR 1926) Section 1053, Ladders.

 5 NFPA 22, 2008 Edition. Standard for Water Tanks for Private Fire Protection: Section 5.7.4 Ladders-General.

6 OSHA Standards, 1991. General Industry (29 CFR 1910) Section 132 General Requirements: Personal Protective Equipment.

7 Zdan, Alex. 29 July 2010. New Jersey Times. Worker Falls to Death during Construction of Water Tower.

8 Metz, Greg. November 2013. Kansas Lifeline. Rescue From Elevated Water Storage Tank is a Reminder for Safety and Emergency Training.

9 NFPA 22, 2008 Edition. Standard for Water Tanks for Private Fire Protection: Section 4