HOW TO WRITE A FALL PROTECTION PLAN FOR ONTARIO CONSTRUCTION PROJECTS

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Every Ontario construction project where workers may be exposed to a fall hazard requires a written fall protection plan. It is not optional. Under Ontario Regulation 213/91 (Construction Projects), employers and constructors must develop site-specific plans that detail how workers will be protected from falls. A well-written fall protection plan does more than satisfy a legal requirement — it forces you to think through every elevated task on the project, identify the hazards, and choose the right controls before anyone sets foot on a scaffold, roof, or open edge.

This guide walks through the essential components of a compliant fall protection plan and offers practical advice for getting it right on your next project.

Why You Need a Written Plan

Ontario Regulation 213/91 requires that fall protection measures be in place whenever a worker is exposed to a fall of three metres or more, or where a fall from a lesser height could result in injury due to the surface or conditions below. The regulation does not use the phrase "fall protection plan" as a single defined term, but the combined requirements of sections 26, 26.1, and 26.2 effectively require a documented plan that addresses hazard identification, equipment selection, rescue procedures, and worker training.

Ministry of Labour inspectors routinely ask to see fall protection documentation during site visits. If you cannot produce a written plan that matches the conditions on site, you risk orders, fines, and stop-work directives. More importantly, a plan that exists only in someone's head is a plan that fails the moment that person is off site.

Step 1 — Conduct a Hazard Assessment

Before you can write a fall protection plan, you need to walk the site and identify every location and task where a fall hazard exists. This assessment should be documented and should include:

• Roof edges and open sides — any unguarded edge where a worker could fall three metres or more requires fall protection. This includes flat roofs, sloped roofs, and partially completed floor decks.
• Floor and wall openings — elevator shafts, stairwell openings, mechanical chases, and any opening in a floor or wall through which a worker could fall must be identified and addressed.
• Scaffolding and elevated platforms — all scaffolding over a certain height requires guardrails or personal fall protection. The plan should specify which scaffolds are on site and what protection is in place.
• Ladders and access points — ladder use itself is a fall hazard, particularly when transitioning from a ladder to a roof or platform. The plan should address safe access and egress.
• Excavations and grade changes — while often overlooked, a fall into a trench or excavation can be just as dangerous as a fall from height. The plan should account for excavation edges adjacent to work areas.
• Fragile surfaces — skylights, fibreglass panels, corroded metal decking, and other surfaces that may not support a worker's weight must be identified and either protected or avoided.

The hazard assessment is not a one-time exercise. As the project progresses and conditions change — new floors are added, temporary guardrails are moved, scaffolding is reconfigured — the assessment and plan must be updated to reflect current site conditions.

Step 2 — Apply the Hierarchy of Controls

Ontario's regulatory framework follows a hierarchy of fall protection, and your plan must demonstrate that you have applied it. The hierarchy, in order of preference, is:

• Elimination — can the work be done at ground level? Pre-assembling components on the ground before lifting them into place eliminates the fall hazard entirely. This is always the preferred approach.
• Passive fall protection (guardrails) — guardrails, covers over openings, and safety nets protect workers without requiring any action on the worker's part. They are the next best option after elimination.
• Travel restraint — a system that physically prevents the worker from reaching the fall hazard. The worker wears a harness connected to an anchor, but the lanyard is short enough that they cannot reach the edge.
• Fall arrest — a full-body harness, shock-absorbing lanyard, and suitable anchor point that will stop a worker's fall after it begins. Fall arrest is effective but introduces additional risks, including suspension trauma and the need for prompt rescue.
• Administrative controls — warning lines, designated signallers, and controlled access zones. These are the least reliable because they depend on human behaviour. They should only be used when higher-level controls are not reasonably practicable.

Your plan must justify the chosen control for each identified hazard. If you are using fall arrest instead of guardrails, the plan should explain why guardrails were not practicable at that location.

Step 3 — Specify Equipment and Anchor Points

For every location where personal fall protection equipment is required, the plan must specify:

• Type of equipment — full-body harness, shock-absorbing lanyard, self-retracting device (SRD), travel restraint lanyard, or horizontal lifeline system. The plan should list the specific equipment to be used at each location.
• Anchor point locations and capacities — every anchor point must be capable of supporting the loads specified in the regulation. For fall arrest, this typically means a capacity of at least 22.2 kN (5,000 lbs) per worker attached. The plan should identify anchor points by location and confirm their adequacy.
• Fall distance calculations — for fall arrest systems, you must calculate the total fall distance to ensure adequate clearance exists below the worker. This includes free fall distance, deceleration distance, harness stretch, and a safety margin. If the clearance is insufficient, fall arrest cannot be used at that location.
• Inspection requirements — the plan should state that all fall protection equipment must be inspected by a competent worker before each use, and that damaged or defective equipment must be removed from service immediately.

Step 4 — Develop a Rescue Plan

This is the component most often missing from fall protection plans, and it is the one that matters most when something goes wrong. Ontario Regulation 213/91 requires that a rescue procedure be in place before any work at heights begins. A worker suspended in a harness after a fall arrest can develop suspension trauma — a potentially fatal condition — within minutes.

Your rescue plan should address:

• Method of rescue — how will a suspended worker be reached and lowered to safety? Options include aerial work platforms, rescue descent devices, ladder-based rescue, and self-rescue techniques.
• Rescue equipment on site — the plan should list the specific rescue equipment available and its location. If a man-rated aerial platform is the primary rescue method, it must be on site and operational during work at heights.
• Trained rescuers — workers designated as rescuers must be trained in the rescue procedure and familiar with the equipment. The plan should identify these workers by name or role.
• Emergency communication — how will a fall be reported? The plan should specify how to contact rescuers, call 911, and communicate the worker's location on a large or complex site.
• Maximum response time — industry best practice recommends rescue within 6 minutes of a fall to minimize the risk of suspension trauma. Your plan should establish a target response time and demonstrate that it is achievable with the resources on site.

Step 5 — Communicate the Plan to Workers

A fall protection plan sitting in a trailer filing cabinet protects no one. Workers must be informed of the plan's contents and trained on the specific procedures that apply to their tasks. Communication should include:

• Site orientation — every worker arriving on site for the first time should receive an orientation that covers fall hazards, fall protection requirements, anchor point locations, and rescue procedures.
• Toolbox talks — regular toolbox talks should reinforce fall protection procedures, particularly when conditions change or new elevated work begins.
• Posted copies — key sections of the plan, particularly rescue procedures and emergency contacts, should be posted in visible locations on site.
• Language considerations — on diverse Ontario construction sites, critical safety information may need to be communicated in multiple languages or using visual aids to ensure all workers understand the plan.

Step 6 — Review and Update the Plan

Your fall protection plan is a living document. It must be reviewed and updated whenever site conditions change, when new fall hazards are introduced, when there is a near miss or incident involving a fall, or when the project moves to a new phase. At a minimum, review the plan:

• At the start of each project phase — as work moves from foundation to structure to envelope to interior, the fall hazards change. The plan must change with them.
• After any incident or near miss — if a fall or near fall occurs, the plan should be reviewed to determine whether the controls in place were adequate and what corrective actions are needed.
• When new subcontractors arrive on site — each subcontractor brings new workers, new tasks, and potentially new fall hazards. The plan should be reviewed to ensure it covers their scope of work.
• At least monthly on long-duration projects — even if conditions appear unchanged, a monthly review helps catch gaps that develop gradually as the project evolves.

Document every review, including the date, the reviewer's name, and any changes made. This documentation demonstrates due diligence in the event of an inspection or incident investigation.

Documentation and Record Keeping

Keep copies of the fall protection plan on site and at your main office. Records should include the current plan, all previous versions, hazard assessments, equipment inspection logs, worker training records (including Working at Heights certificates), and records of plan reviews and updates. These documents should be readily available for Ministry of Labour inspectors and should be retained for at least the duration of the project plus any applicable limitation period.

A well-documented fall protection plan is your strongest evidence of due diligence. It shows that you identified the hazards, selected appropriate controls, trained your workers, planned for rescue, and kept the plan current as conditions changed. That is exactly what the regulation demands — and exactly what keeps your workers safe.