# Policy - Working at Heights

> Fire Service Safety Management System, version 0.3.3 (2026-10-25). The Human Factor. Document FSSMS-POL-16.
>
> Canonical: https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights
>
> Licence: CC BY-NC-SA 4.0 with the Adopting Agency Grant (https://creativecommons.org/licenses/by-nc-sa/4.0/)
>
> General information only, not legal, medical or other professional advice. Verify every requirement against the current official text of the law, standards and manufacturer instructions that apply to you. Obtain your own legal review and consult your joint health and safety committee before adopting anything. You adopt, adapt, implement and rely on this material entirely at your own risk and on your own responsibility. Full terms: Terms of Use, thehumanfactor.ca.

> **Warning: Adoption without implementation increases legal exposure**
>
> Adopting this policy without the training, equipment, supervision, verification and resources to carry it out as written increases municipal and command liability in a regulatory investigation or a fatality inquiry. See [00a Copyright, Licence and Legal Notices](https://thehumanfactor.ca/library/fire-service-safety/copyright-licence-and-legal-notices).

> **Warning: Before adoption**
>
> This model policy requires review by the department’s legal counsel and against every applicable collective agreement and volunteer agreement before adoption. It is general information, not legal advice. Where it conflicts with a statute, a regulation or an agreement, the statute, regulation or agreement governs. Standard and regulation references are cited as of 2026-10-23; confirm each clause and section before the policy is signed.

## How to use this model

**Format.** Adopt as a policy approved by the fire chief (or the council or board where the municipality’s framework requires it), or restate as a standard operating guideline or directive. Keep the numbering either way, because the program, the procedures, the forms and the audit checklist refer to it.

**Drafting conventions.** **Shall** is mandatory. **Should** is expected unless a documented reason exists. **May** is permitted. Placeholders in double curly braces, such as `{{Department}}`, are completed by the department. Drafting notes sit in callouts and are removed before adoption.

**Keep intact.** The position that fall protection law applies at incidents and that any relief is narrow, conditional and for emergency response only (5.1, 5.2); the training-is-not-an-emergency rule (5.2.3); the hierarchy of controls (5.3); the heel-or-tie rule and the ladder service test (5.5); the belt-or-harness, operator-at-the-controls and no-movement-without-confirmation rules for aerial devices (5.6); the roof no-go rules (5.7); the post-use harness inspection (5.9.3); the no-fall-arrest-without-rescue rule (5.10); and the speak-up and learning firewall clauses (4(e) to 4(h), 5.12). **Adapt** the titles, the electrical clearance, the intervals where the manufacturer or the applicable provincial regulation is stricter, the records system and the reporting lines.

| Policy header |  |
|:---|:---|
| Title | Working at Heights |
| Number | {{Policy number}} |
| Approved by | {{Fire Chief}} (role) |
| Effective date | {{Effective date}} |
| Next review date | {{Review date}} (12 months after adoption, then every three years) |
| Policy owner | {{Deputy Chief}}, operations, through the program manager who leads the Technical Rescue Program Improvement Team |
| Consulted | {{JOHSC}}; {{Union}}; {{Volunteer Association}}; fleet services; facilities; legal counsel |

## 1. Purpose

1.1 To state {{Department}}’s commitment that members who work at height come home: every height task has a written method that crews actually use, the protection the method requires is worn and attached, every ladder, aerial device and item of fall protection equipment is inspected and tested, every member who works at height is trained and can show it, and a member suspended after a fall is rescued before the suspension does harm.

1.2 To assign accountability for that commitment to the line: the health and safety officer verifies it, and the joint occupational health and safety committee is consulted at each step.

## 2. Scope and application

2.1 This policy applies to every member of {{Department}}, career, volunteer and paid-on-call, including recruits and instructors, and to mutual aid members working at height under the department’s command.

2.2 It applies to every task where a member could fall: climbing and working from ground ladders; riding, climbing and working from aerial ladders, platforms, ladder platforms, buckets and water towers; roof operations and vertical ventilation; work on apparatus tops and hose beds; evolutions on training towers, roof props and elevated props; rope rescue edge work; station and facility maintenance at height; and work at docks, embankments and dry hydrant pits.

2.3 It applies at incidents, in training, in stations and wherever members do the department’s work. The applicable fall protection regulation applies to all of this work ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)); clause 5.2 states the only relief the department relies on.

2.4 Exclusions: the design and operation of rope rescue systems, which [Rope Rescue Program](https://thehumanfactor.ca/library/fire-service-safety/rope-rescue-program) governs (this policy keeps the edge tie-in rule and the code of practice link); and contractors working at height on department premises, who work under their own employer’s fall protection program, which must meet or exceed this policy ([Policy - Contractors and Mutual Aid](https://thehumanfactor.ca/library/fire-service-safety/policy-contractors-and-mutual-aid); [Contractor and Mutual Aid Safety Program](https://thehumanfactor.ca/library/fire-service-safety/contractor-and-mutual-aid-safety-program)).

## 3. Definitions

- **Anchorage:** a secure point of attachment for a lanyard, lifeline or restraint system, rated to the minimum the applicable regulation sets ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)) or engineered (CSA Z259.16:21).
- **Competent person:** a person qualified by knowledge, training and experience to do the assigned work, and familiar with the applicable law and with the hazards of the work.
- **Control zone:** a marked area kept back from an unprotected edge, inside which no member works without fall protection.
- **Emergency response:** the department’s response to an incident in progress. Training, drills, hose loading, station maintenance and equipment checks are not emergency response, even when they imitate it.
- **Fall arrest:** a system that stops a fall already under way: full-body harness, energy-absorbing connection, rated anchorage and a rescue plan (CSA Z259.17:21).
- **Fall protection plan:** the written, site-specific document required for work areas at or above the plan threshold the applicable regulation sets ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), covering the hazards, the systems, clearance and swing fall, inspection and rescue.
- **Fall protection procedure:** the written, task-specific method for work below that plan threshold.
- **Fall restricting (work positioning):** a system that limits a fall to a short distance while the member works with both hands, such as a ladder belt hooked to a rung.
- **Learning firewall:** the rule that information gathered for learning is never used as the basis for discipline, and that conduct concerns are handled by a separate process run by different people ([Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program); The Human Factor, 2026a).
- **Member:** any person who performs work for the department, paid or unpaid.
- **Near miss:** an event that could have caused a fall or an injury from a fall but did not, including any moment when a member was at height without the protection the method requires.
- **Psychological safety:** the shared belief that it is safe to speak up, ask, admit error and challenge [(Edmondson, 1999)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-edmondson-1999).
- **Rope access code of practice:** the written code for work supported by rope. In this policy set, [SWP - Rope Rescue Systems Rigging and Inspection](https://thehumanfactor.ca/library/fire-service-safety/swp-rope-rescue-systems-rigging-and-inspection) serves as the department’s code.
- **Service test:** the periodic load and function test of a ground ladder to the NFPA ground ladder standard [(NFPA 1930, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1930).
- **Travel restraint:** a system that keeps the member from reaching an edge, so a fall cannot start.
- **Work-as-done:** how a task is actually performed under real conditions, as distinct from work-as-imagined [(Hollnagel, 2014)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-hollnagel-2014).

## 4. Principles

1.  **The height is the hazard, so remove it first.** The department chooses the control for each task in the order the fall protection standard sets: eliminate the height, guard the edge, restrain, restrict, arrest, and only then rely on a control zone (CSA Z259.17:21).

2.  **The law applies at the fire.** Fall protection law applies to the department as an employer at emergencies and otherwise. The department relies on any relief its jurisdiction gives only narrowly, only on its conditions and only during emergency response, even where the relief is wider ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), and it earns the relief by writing procedures and training to them.

3.  **Training is not an emergency.** Habits learned on a tower go to the fireground, so every evolution runs with full fall protection.

4.  **No fall arrest without a rescue.** A member caught by a harness is still in danger until rescued.

5.  **People are the solution we build around, not the problem to fix.** Members’ judgment, adaptations and reports are the program’s main source of safety; this policy supports that judgment rather than replacing it.

6.  **Procedures describe work as done, written with the people who do it.** Every height procedure starts from a learning-team description of how the task is really done and is revised with the crews who do it.

7.  **Learning comes before blame, and learning information is never used for discipline.** Near-miss reports, after-action reviews, learning teams and post-incident analyses sit behind the learning firewall.

8.  **Psychological safety is a condition of safety, so speaking up is expected and protected.** Any member may stop a climb, a roof assignment, an aerial movement or a hose-loading job; the officer acknowledges, acts and reviews later; nobody is questioned for a concern raised in good faith.

> **Information: Drafting note**
>
> Citations are kept out of the policy statements so the policy reads as policy. The standards and regulations behind each clause are in section 11, in the Jurisdiction requirements table and in [Working at Heights and Fall Protection Program](https://thehumanfactor.ca/library/fire-service-safety/working-at-heights-and-fall-protection-program) section 3.

## 5. Policy statements

**5.1 Written position and fall hazard inventory (S1).** The department shall record in its adopted program how the applicable fall protection regulation ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)) applies to emergency response, training and station work, and the fall protection procedure shall cite that position. 5.1.1 The department shall keep a fall hazard inventory listing every recurring height task with its typical fall distance, the surface below, the control chosen, the procedure that governs it and the rescue method. 5.1.2 The Technical Rescue Program Improvement Team shall review the inventory annually and after any change in apparatus, stations, props or services. *Accountable: the deputy chief, operations; the program manager for the inventory.*

**5.2 Emergency operations relief (S1).** Where the applicable regulation gives emergency services any relief from fall protection requirements ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), the department shall rely on it only as this clause allows. 5.2.1 The relief is used only during emergency response and only from the requirement the regulation names; the duty to protect members from falls remains. 5.2.2 The department shall keep the written fall protection procedure and the rope access code of practice the relief depends on, train members to both, and require members to follow them and standard emergency protocols. 5.2.3 Training, drills, hose loading, station maintenance and equipment checks are not emergency response; the full regulation applies to them, including any written plan the work requires. *Accountable: the fire chief for the position; incident commanders at incidents.*

**5.3 Hierarchy of controls (S1).** For each task in the inventory the department shall choose the highest practicable control: eliminate the height; guardrails and fixed protection; travel restraint; fall restricting; fall arrest with a rescue plan; and, only where no edge protection is possible, a marked control zone with a monitor. 5.3.1 Where a lower control is chosen, the reason shall be recorded in the inventory. 5.3.2 Ground-level hose loading is the default, and no member shall ride on an apparatus top or rear step or stand on a moving apparatus. *Accountable: the program manager; company officers for daily practice.*

**5.4 Written procedures and plans (S1).** The department shall maintain a written fall protection procedure for every recurring task below the plan threshold the applicable regulation sets, and a written fall protection plan for every work area at or above it, including training towers, aerial training positions, roof props and station roofs. 5.4.1 Each plan shall cover the hazards, the system for each location, anchorages and their rating, fall arrest clearance, swing fall, the equipment inspection schedule, the competent person, weather limits and the rescue procedure for a suspended member. 5.4.2 Procedures and plans shall be written with the crews who do the work, consulted with {{JOHSC}} before adoption, and reviewed after any fall, near miss or change. *Accountable: the program manager.*

**5.5 Ground ladders (S1).** Every ground ladder shall be designed, used, maintained and service tested to the NFPA ground ladder standard. 5.5.1 A ladder shall not be climbed unless it is heeled or tied off, and a member who works with both hands shall first apply a leg lock or a ladder belt hooked to a rung. 5.5.2 The company shall inspect each ladder monthly and after every use at a fire, and each ladder shall be service tested annually and after heat exposure, overloading, impact or suspected damage. 5.5.3 A ladder that fails an inspection or a test shall be tagged out and removed from service until it is repaired and retested, or retired. 5.5.4 Any relief the applicable regulation gives firefighters from the general ladder-positioning rules during structural firefighting or rescue ([J15 Equipment Inspection, Ladders and Aerial Devices](https://thehumanfactor.ca/library/fire-service-safety/j15-equipment-inspection-ladders-and-aerial-devices)) does not relieve the duty to secure the member on the ladder. *Accountable: company officers for use and inspection; fleet services for the service test.*

**5.6 Aerial devices (S1).** 5.6.1 Every member on an aerial ladder shall wear a ladder belt, or a harness with a short positioning lanyard, attached so that a fall is limited to about 30 cm; travel restraint shall not be used as the system on an aerial ladder. 5.6.2 Every member on an aerial platform or bucket shall wear a full-body harness attached to the labelled platform anchor before the platform leaves the bed, and stay attached until it returns. 5.6.3 A qualified operator shall stay at the lower controls, in sight and in voice or radio contact, whenever a member is on the device, and the device shall not move with a member on it until the operator and that member have both confirmed. 5.6.4 Rated loads, stabilizer set-up and the department’s electrical clearance of {{Minimum electrical clearance}} shall be respected through the whole arc of movement. 5.6.5 Every aerial device shall have a third-party inspection and non-destructive test, with a written certificate, at intervals not exceeding 12 months, and again after any collision, overload, structural repair or suspected damage before it returns to service. 5.6.6 Anchor points shall be labelled for restraint or arrest by the manufacturer or an engineer. *Accountable: incident commanders and company officers; aerial operators; fleet services for testing.*

**5.7 Roof operations (S1).** No member shall go to a roof at a fire until the incident commander and the roof officer have sized up the construction, the roof system, the burn time and the location of the fire. 5.7.1 No member shall work over fire-involved lightweight truss or engineered roofs, and a roof of unknown construction shall be treated as lightweight. 5.7.2 Whenever members are on a roof, a roof officer shall be assigned, members shall sound ahead of every step and work from the roof ladder, the aerial or a sound part of the deck, and two means of egress shall be in place, one of them other than the route of access. 5.7.3 Thermal imagers are used to locate fire, never to judge roof strength. *Accountable: incident commanders; roof officers.*

**5.8 Training towers, props and station work (S1; S2 for the engineered anchor program).** 5.8.1 Every evolution on a training tower or prop shall use full fall protection, with rated and labelled anchors inspected before the evolution, and the training safety officer shall stop any evolution with an unprotected exposure. 5.8.2 Training structures shall have an engineer’s structural inspection on the cycle the department sets ({{Training tower inspection interval}}). 5.8.3 Station maintenance at height shall use a fixed stair, platform lift or scaffold before a ladder, a second person for any ladder, and fall arrest to a rated anchor or a guardrail within reach of a roof edge, skylight or hatch. *Accountable: the training officer for 5.8.1 and 5.8.2; company officers and facilities for 5.8.3.*

**5.9 Fall protection equipment (S1).** Every harness, belt, lanyard, energy absorber, self-retracting device, connector, anchor connector and lifeline shall meet the CSA Z259 part the applicable regulation calls up ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), or the NFPA life safety harness requirements where the regulation accepts them, and shall be compatible with the components it is used with. 5.9.1 Every item shall be in the equipment inventory with its standard, class, serial number, date in service and service life. 5.9.2 The user shall inspect each item before every use. 5.9.3 A harness worn for firefighting or rescue shall be inspected by a competent person before it is used again. 5.9.4 A competent person shall inspect all in-service equipment at least every six months, or more often where the manufacturer or the fall protection plan requires, and record it on [Form - Fall Protection Equipment Inspection Card](https://thehumanfactor.ca/library/fire-service-safety/form-fall-protection-equipment-inspection-card). 5.9.5 Any item that has arrested a fall, taken an impact load, been exposed to heat, flame or chemicals, failed an inspection or raised a doubt shall be removed from service, tagged and quarantined; items are retired at the manufacturer’s service life or on condition, whichever comes first. *Accountable: the program manager; competent-person inspectors; members for 5.9.2.*

**5.10 Rescue after a fall (S1; S2 for the timed drill).** Fall arrest shall not be used at any location without a written rescue procedure for a suspended member at that location. 5.10.1 The aerial crews and the rope rescue team are the designated rescue capability for suspended members on apparatus, towers and at incidents. 5.10.2 Every member who uses fall arrest shall be trained to use suspension relief steps where the harness carries them. 5.10.3 Each aerial and rope crew shall complete a timed suspended-member rescue drill at least annually. *Accountable: the program manager; aerial and rope crew officers.*

**5.11 Training, competency and cards (S1).** No member shall work at height without fall protection training delivered before first exposure and repeated at the interval the applicable regulation sets, and at least every three years ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), by a competent instructor, with a written and practical evaluation, and a card or certificate signed by the instructor that is available at the workplace. 5.11.1 Members shall also hold the task training their assignment needs (ground ladders, roof operations, aerial operation, aerial riding and suspended-member rescue) on the cycles in section 10. 5.11.2 A member who cannot show a current card does not ride an aerial device or work on a tower until they can. *Accountable: the deputy chief responsible for training.*

**5.12 Reporting, learning and speaking up (S1).** 5.12.1 Every fall, arrested fall, aerial device moved with an unattached member, conductor contact, ladder or anchor failure and near miss shall be reported before the end of the shift and reviewed through the learning system at the tier [Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program) sets. 5.12.2 Any member may stop a height task by stating the hazard and the action; the officer shall acknowledge, act and review it later for learning, never argue it on the spot. 5.12.3 Every member who raises a working-at-heights concern shall receive an answer from the program team lead within 15 days saying what was decided and why. 5.12.4 Learning information shall never be used as the basis for discipline; conduct concerns shall be handled by a separate process run by different people. 5.12.5 No member shall suffer reprisal for a report, a stop-work call or a concern raised in good faith. *Accountable: the fire chief.*

**5.13 Program, consultation and review (S1; S3 for the independent review).** The department shall maintain [Working at Heights and Fall Protection Program](https://thehumanfactor.ca/library/fire-service-safety/working-at-heights-and-fall-protection-program) as the written program this policy requires, consult {{JOHSC}} on the program and on every safety-sensitive change before adoption, evaluate the program annually and have it independently reviewed every three years. *Accountable: the fire chief.*

## 6. Roles and responsibilities

Only the differences from [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities) are stated here.

| Clause | Role | Duties under this policy |
|:---|:---|:---|
| 6.1 | Fire chief | Approves this policy and the written position under 5.1 and 5.2; answers JOHSC recommendations on working at heights in writing within the time the applicable statute sets ([J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative)); receives the annual program appraisal |
| 6.2 | Deputy chief, operations (policy owner) | Accountable for the program’s outcome; approves the fall protection procedure and plans; owns every open corrective action for the program through the program manager |
| 6.3 | Program manager, Technical Rescue | Leads the Program Improvement Team; keeps the inventory, procedures, plans and equipment inventory current; names the competent-person inspectors in writing; presents the quarterly update and the annual appraisal |
| 6.4 | Health and safety officer | Verifies the program against law and standards; samples ladder, aerial and inspection-card records quarterly; observes aerial, roof and tower evolutions; runs the annual internal audit |
| 6.5 | Incident commanders | Apply 5.2, 5.6 and 5.7 at incidents; assign the roof officer, and the incident safety officer on the [Emergency Operations Safety Program](https://thehumanfactor.ca/library/fire-service-safety/emergency-operations-safety-program) triggers |
| 6.6 | Company officers | Confirm the control on every height task; run the monthly ladder inspection; see that harnesses worn at a fire get the post-use inspection; check members’ cards; answer every stop-work call under 5.12.2; pass every concern on the same day |
| 6.7 | Aerial operators | Stay at the lower controls whenever a member is on the device; move it only on confirmation; complete the daily and weekly device checks; report every overload, impact or contact |
| 6.8 | Competent-person inspectors | Inspect equipment on schedule and after use for firefighting or rescue; remove and quarantine items under 5.9.5; keep the inspection cards |
| 6.9 | Training officer and training safety officers | Deliver the training and keep the cards and records; run the pre-evolution inspection; stop any evolution with an unprotected exposure |
| 6.10 | Fleet services | Deliver the ground ladder service test and the aerial device inspection and test under a written service level; keep certificates for the life of the apparatus |
| 6.11 | Facilities | Maintain anchors, guardrails, hatch covers and platform lifts in stations; bring contractors under [Contractor and Mutual Aid Safety Program](https://thehumanfactor.ca/library/fire-service-safety/contractor-and-mutual-aid-safety-program) |
| 6.12 | Members | Inspect their equipment before use; attach as the method requires; keep their card current and available; report every near miss and defect; speak up and stop work when something is wrong |
| 6.13 | {{JOHSC}} | Designates a standing consultant to the Technical Rescue team; is consulted before any safety-sensitive change, including hose bed railings and covers; checks ladders, anchors and cards during station inspections; receives the quarterly update and the corrective action register |

## 7. Program and procedures this policy requires

- [Working at Heights and Fall Protection Program](https://thehumanfactor.ca/library/fire-service-safety/working-at-heights-and-fall-protection-program) (FSSMS-PRG-14) with its implementation toolkit: hazard inventory, procedure and plan templates, ladder, aerial and equipment records, training sign-off and indicator worksheet.
- [SWP - Ground Ladder Operations](https://thehumanfactor.ca/library/fire-service-safety/swp-ground-ladder-operations); [SWP - Aerial Device Operations](https://thehumanfactor.ca/library/fire-service-safety/swp-aerial-device-operations); [SWP - Roof and Vertical Ventilation Operations](https://thehumanfactor.ca/library/fire-service-safety/swp-roof-and-vertical-ventilation-operations); [SWP - Fall Protection on Apparatus and at Heights](https://thehumanfactor.ca/library/fire-service-safety/swp-fall-protection-on-apparatus-and-at-heights); [SWP - Training Tower and Prop Inspection](https://thehumanfactor.ca/library/fire-service-safety/swp-training-tower-and-prop-inspection), shared with [Training Safety and Live Fire Program](https://thehumanfactor.ca/library/fire-service-safety/training-safety-and-live-fire-program).
- [SWP - Rope Rescue Systems Rigging and Inspection](https://thehumanfactor.ca/library/fire-service-safety/swp-rope-rescue-systems-rigging-and-inspection), owned by [Rope Rescue Program](https://thehumanfactor.ca/library/fire-service-safety/rope-rescue-program), which is also the department’s rope access code of practice.
- Forms: [Form - Ladder and Aerial Inspection and Test Record](https://thehumanfactor.ca/library/fire-service-safety/form-ladder-and-aerial-inspection-and-test-record); [Form - Fall Protection Equipment Inspection Card](https://thehumanfactor.ca/library/fire-service-safety/form-fall-protection-equipment-inspection-card).
- Audit: [Checklist - Working at Heights and Fall Protection](https://thehumanfactor.ca/library/fire-service-safety/checklist-working-at-heights-and-fall-protection).

## 8. Records, confidentiality and disclosure

8.1 The records this policy creates are the written position, the fall hazard inventory, procedures and plans, ladder inspection and service test records, aerial device certificates and after-event test records, the equipment inventory and inspection cards, training records and cards, drill records with times, near-miss and incident reports, the concern reply log, the quarterly updates and the annual appraisal. They are kept in {{Records system}} on the retention schedule in [Working at Heights and Fall Protection Program](https://thehumanfactor.ca/library/fire-service-safety/working-at-heights-and-fall-protection-program) section 10. 8.1.1 Test records follow the item: ladder records for the life of the ladder, aerial certificates for the life of the apparatus, and inspection cards for the life of the item plus one year.

8.2 Every record is written on the assumption that it may be disclosed under freedom-of-information legislation. Records identify people by role wherever the purpose allows; training records name the member and carry no health information.

8.3 Near-miss reports, learning-team write-ups and post-incident analyses are de-identified before they are shared and are never placed in a personnel file.

## 9. Reporting

9.1 To the fire chief: the quarterly indicator update; every fall, arrested fall, and Tier 2 or Tier 3 event within 24 hours; the annual program appraisal; the corrective action register at management review.

9.2 To {{JOHSC}}: the quarterly update; the corrective action register monthly; every aerial device taken out of service and every pattern of failed ladder tests; every learning review outcome; the annual audit result.

9.3 To council or the governing board: working-at-heights indicators within the annual health and safety report ([03 Accountability and Reporting](https://thehumanfactor.ca/library/fire-service-safety/accountability-and-reporting)).

9.4 To the regulator and the workers’ compensation board: as the applicable statute requires. In some jurisdictions a fall, or an arrested fall, from a work area where fall protection is required is reportable even when nobody is hurt ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)).

## 10. Training requirements

| Role | Minimum training | Refresh |
|:---|:---|:---|
| Every operational member | Fall protection to the topic list the applicable regulation sets ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)), with hands-on donning, adjustment, connection and inspection; signed card issued | The interval the applicable regulation sets, and at least every three years |
| Every operational member | Ground ladder job performance requirements and the department’s ladder procedure | Annual skills check |
| Members assigned to roof work | Roof operations: construction recognition, sounding, egress, saw safety, the no-go rules | Annual refresher on a prop |
| Aerial operators | Manufacturer’s training; aerial operator job performance requirements; set-up, electrical clearance, load charts | Annual proficiency on each device type |
| Members who ride aerial devices | Belts, harnesses and anchors on each device; communication with the operator | Annual |
| Aerial and rope crews | Suspended-member rescue; suspension relief steps | Annual timed drill |
| Company officers | Supervising height work: the inventory, the controls, the post-use inspection duty, the response to a stop-work call | Within six months of appointment; every three years |
| Competent-person inspectors | Equipment inspection, removal and retirement criteria, records | Every three years |
| Training safety officers | Pre-evolution inspection, anchors, the rescue plan, stop authority | Every three years |
| {{JOHSC}} members | Orientation to this policy, the program’s records and the inspection points | At each policy revision |

## 11. Legal and standards basis

11.1 The applicable occupational health and safety statute and regulations, which differ by province and territory: the employer’s general duty ([J02 Duties of Employers, Supervisors, Workers and Contractors](https://thehumanfactor.ca/library/fire-service-safety/j02-duties-of-employers-supervisors-workers-and-contractors)); the fall protection threshold, written procedure and plan requirements, anchorage, equipment and training rules, any emergency services relief, and the firefighter rules for aerial harnesses and rope ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)); the inspection and testing rules for equipment, ground ladders and aerial devices ([J15 Equipment Inspection, Ladders and Aerial Devices](https://thehumanfactor.ca/library/fire-service-safety/j15-equipment-inspection-ladders-and-aerial-devices)); any fire-service OHS rules ([J12 Fire Service OHS Rules and Fireground Operations](https://thehumanfactor.ca/library/fire-service-safety/j12-fire-service-ohs-rules-and-fireground-operations)); the reporting of falls ([J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation)); and the duty to consult the committee on procedures and plans ([J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative); [J06 Written Procedures and Committee Consultation](https://thehumanfactor.ca/library/fire-service-safety/j06-written-procedures-and-committee-consultation)). The Jurisdiction requirements table at the end of this policy lists what to confirm for your province or territory.

11.2 CSA Z259.17: the written fall protection program, hierarchy, selection and compatibility, training, inspection, removal from service and rescue after a fall (CSA Z259.17:21). CSA Z259.16: design of anchorages and complete systems on towers, props and station roofs (CSA Z259.16:21). CSA Z259.12 (CSA Z259.12:16) and the other Z259 equipment parts the applicable regulation calls up ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)).

11.3 NFPA 1930, which consolidates the ground ladder standards with the standards for fire hose and appliances, rescue tools, thermal imagers and portable radios: ground ladder design, use, maintenance and service testing, carried forward from NFPA 1931 and 1932 [(NFPA 1930, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1930).

11.4 NFPA 1910: annual aerial device inspection and testing and after-event testing within the in-service apparatus program [(NFPA 1910, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1910). NFPA 1900: handrails, steps, hose beds and walking surfaces on new apparatus [(NFPA 1900, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1900).

11.5 NFPA 2500: life safety harness, rope and hardware requirements for rescue [(NFPA 2500, 2022, ch. 24 to 28)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-2500).

11.6 NFPA 1010: ladder, ventilation and aerial operator job performance requirements [(NFPA 1010, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1010). NFPA 1550: the occupational safety and health program, risk management and the incident safety officer [(NFPA 1550, 2024)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-nfpa-1550).

11.7 Benchmarks adopted where the department’s own jurisdiction is silent: the 30 cm fall limit on aerial ladders, the 12-month aerial test interval and the operator at the lower controls, which firefighting provisions elsewhere in Canada write into law ([J15 Equipment Inspection, Ladders and Aerial Devices](https://thehumanfactor.ca/library/fire-service-safety/j15-equipment-inspection-ladders-and-aerial-devices); [J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)); travel restraint unsuited to aerial ladders, and anchor labelling (MLITSD, n.d., GN 4-11); roof operations and falls from apparatus (MLITSD, n.d., GN 6-14, GN 6-29); and the reading that a firefighting exemption does not extend to training ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)).

11.8 Lessons built in: falls through fire-weakened truss roofs during ventilation [(NIOSH, 2003a, F2003-18)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-niosh-2003a) and the recurring falls from aerial tips, apparatus and ground ladders in fatality investigations (NIOSH, n.d.-b).

11.9 The Criminal Code: the duty of everyone who directs work to take reasonable steps to prevent bodily harm [(Criminal Code \[CA\], 1985, s. 217.1)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-criminal-code-ca); see [01 Roles and Responsibilities](https://thehumanfactor.ca/library/fire-service-safety/roles-and-responsibilities).

11.10 Accreditation: apparatus maintenance by trained technicians to manufacturer and provincial requirements, and the occupational health and safety program [(CPSE, 2019, criteria CC 6D.1, CC 6D.5, 11A.1, 11A.2, 11A.3, CC 11A.5)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-cpse-2019).

## 12. Review and approval

12.1 This policy is reviewed 12 months after adoption and every three years after that, and sooner after any fall-related death, critical injury or Tier 2 event; after a change in the applicable regulation or a new edition of CSA Z259.17, NFPA 1930, NFPA 1910 or NFPA 2500; on a written request of {{JOHSC}}; or when the annual audit or appraisal recommends it.

12.2 Every revision is consulted with {{JOHSC}}, {{Union}} and {{Volunteer Association}} before approval, and the consultation record is filed with the policy.

## 13. Adoption checklist

| Step | Lead | Done |
|:---|:---|:---|
| 1\. Complete every placeholder and the policy header | Policy owner |  |
| 2\. Counsel and collective agreement review | Fire chief; counsel |  |
| 3\. Record the written position on emergency operations for your province or territory, from [J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access) (5.1, 5.2) | Fire chief; program manager |  |
| 4\. Complete the fall hazard inventory with the crews who do the work | Program manager; company officers |  |
| 5\. Adopt the four procedures, the plan for towers and aerial training, and the rope access code of practice | Program manager |  |
| 6\. Build the ladder, aerial and equipment inventories; book every overdue test | Program manager; fleet services |  |
| 7\. Name the competent-person inspectors in writing and train them | Program manager |  |
| 8\. Confirm aerial anchor labels with the manufacturer and the electrical clearance with the utility | Program manager; fleet services |  |
| 9\. Check every operational member’s fall protection card; schedule anyone not current | Training division |  |
| 10\. Consult the JOHSC, the union and the volunteer association; file the record | Fire chief; JOHSC co-chairs |  |
| 11\. Charter the Technical Rescue Program Improvement Team; hold a learning-team session on hose loading and roof decisions | Deputy chief, operations |  |
| 12\. Brief every crew on the heel-or-tie, belt-or-harness, operator-at-the-controls and roof no-go rules and on the response to a stop-work call | Company officers |  |
| 13\. Start the quarterly indicator update and the concern reply log | Team lead |  |
| 14\. Diarize the 12-month review | Policy owner |  |

## 14. Consulting the JOHSC and bargaining agents

Consult early, before the policy is in final form, and put the outcome in writing. The committee and the bargaining agents will ask these questions; the honest answers follow.

| They will ask | Honest answer |
|:---|:---|
| Does fall protection law really apply on the fireground? | Yes. Where a jurisdiction gives a relief it is conditional, and the department uses it only during emergency response: one model removes only the site-specific plan, only during emergency response, and only if the department has written procedures and trains to them; another lets the incident commander depart from the general rules only where compliance is impracticable or creates a greater hazard, with the aerial and rope rules still in force ([J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access)). Training and station work get no relief under this policy. |
| Will a member be disciplined for working unattached at a fire? | Not for the event itself. It is reviewed for learning behind the firewall, and the review asks what made that choice sensible at the time [(Dekker, 2016)](https://thehumanfactor.ca/library/fire-service-safety/policy-working-at-heights#ref-dekker-2016). Deliberately disabling equipment or falsifying a record is a conduct matter handled separately. |
| Will ground-level hose loading slow us down after a call? | Sometimes, by minutes. Falls from apparatus tops are one of the recurring injuries this program answers. Where a station cannot load from the ground, the team will look at platforms, bed design and railings with the JOHSC. |
| Who pays for harnesses and belts, and will they fit over turnout gear? | The department pays. Members try models before purchase, because a harness nobody wears protects nobody. |
| How do volunteers keep up with the training cycle? | The recurrent training fits a training night or a Saturday morning on the department’s own apparatus. A volunteer without a current card does not ride the aerial until they have one. |
| Can a member refuse a roof assignment? | Yes. The member states the hazard; the roof officer answers with the reason or changes the plan. The right to refuse and stop-work authority are in [Policy - Right to Refuse Unsafe Work and Stop-Work Authority](https://thehumanfactor.ca/library/fire-service-safety/policy-right-to-refuse-unsafe-work-and-stop-work-authority). |
| What if the aerial is overdue for its test? | It does not elevate members until it is tested. The gap goes to the [Corrective Action Register](https://thehumanfactor.ca/library/fire-service-safety/corrective-action-register) with a date, and the test cost goes into the five-year budget worksheet. |
| How will we know the policy works and is not just written? | The indicators (card currency, ladder test currency, aerial certificate currency, drill observation), the HSO’s quarterly sample, the JOHSC’s inspections, the annual audit, and the stop-work and near-miss counts, which should rise before injuries fall. |

Where the parties disagree, record the disagreement, adopt what can be adopted, and review at 12 months.

## 15. Customization and sector variants

> **Note: Customize**
>
> Complete the header table and every placeholder. Record the department’s written position for its province or territory (5.1, 5.2) after reading its section of [J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access). Decide the electrical clearance with the local utility, which anchor points on each aerial device are for restraint and which for arrest, who the competent-person inspectors are, whether ladder service testing is done in house or contracted, and the training tower inspection interval. Departments without aerial devices delete 5.6 and the aerial rows; departments without a training tower adapt 5.8 to the props they use. The policy text is generic across Canada: check each row of the Jurisdiction requirements table against your province’s or territory’s section of the topic page, and where your law sets a stricter threshold, interval or rule, adopt it.

> **Tip: Volunteer and composite departments**
>
> Keep the policy as written; change the scheduling. Hold the recurrent training on a training night, with the hands-on work on the station’s own apparatus and ladders, and keep the cards at the station, not at home. A volunteer officer who directs work at height is a supervisor under this policy and carries clause 6.6 in full; whether volunteers are workers and supervisors in law depends on your jurisdiction ([J11 Volunteer Firefighters](https://thehumanfactor.ca/library/fire-service-safety/j11-volunteer-firefighters)).

> **Information: Delivery note**
>
> Walk the JOHSC through section 14 and clause 5.2 before the first draft is circulated. The relief clause is the one most often misread, in both directions: some departments believe the law does not apply at fires, others believe it forbids roof work. Neither is right.

**Disclaimer.** This model policy is general information for the use of {{Department}} in building its own policy. It is not legal advice. The applicable statute, regulation and collective agreement govern on any conflict. Confirm every cited clause and section with counsel before adoption.

*End of model policy.*

## Jurisdiction requirements

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

| Topic | What to check in your jurisdiction | Page |
|:---|:---|:---|
| Duties of Employers, Supervisors, Workers and Contractors | The employer’s general duty, which carries the height hazards no specific rule names, and the duties of officers who direct work at height | [J02 Duties of Employers, Supervisors, Workers and Contractors](https://thehumanfactor.ca/library/fire-service-safety/j02-duties-of-employers-supervisors-workers-and-contractors) |
| Joint Committee and Health and Safety Representative | The deadline for answering the committee’s recommendations on working at heights, and the committee’s inspection role | [J05 Joint Committee and Health and Safety Representative](https://thehumanfactor.ca/library/fire-service-safety/j05-joint-committee-and-health-and-safety-representative) |
| Written Procedures and Committee Consultation | Whether written fall protection procedures and plans are required, and the duty to consult the committee on them | [J06 Written Procedures and Committee Consultation](https://thehumanfactor.ca/library/fire-service-safety/j06-written-procedures-and-committee-consultation) |
| Incident Reporting and Investigation | Whether a fall, or an arrested fall, from a work area where fall protection is required must be reported to the regulator even when nobody is hurt, and how fast | [J08 Incident Reporting and Investigation](https://thehumanfactor.ca/library/fire-service-safety/j08-incident-reporting-and-investigation) |
| Volunteer Firefighters | Whether volunteers are workers under the OHS statute, and whether a volunteer officer who directs work carries a supervisor’s duties | [J11 Volunteer Firefighters](https://thehumanfactor.ca/library/fire-service-safety/j11-volunteer-firefighters) |
| Fire Service OHS Rules and Fireground Operations | Any fire-service OHS rule on aerial devices, ladders, roof work or fall protection at incidents | [J12 Fire Service OHS Rules and Fireground Operations](https://thehumanfactor.ca/library/fire-service-safety/j12-fire-service-ohs-rules-and-fireground-operations) |
| Equipment Inspection, Ladders and Aerial Devices | The design and service-testing standards named for ground ladders and aerial devices, any test interval, any firefighter relief from the general ladder rules, and equipment inspection and its records | [J15 Equipment Inspection, Ladders and Aerial Devices](https://thehumanfactor.ca/library/fire-service-safety/j15-equipment-inspection-ladders-and-aerial-devices) |
| Fall Protection and Rope Access | The fall protection trigger height, when a written procedure or a site-specific plan is required, anchorage and equipment standards, the training interval, any emergency services relief, and the firefighter rules for aerial harnesses and rope | [J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access) |

## References

Center for Public Safety Excellence \[CPSE\]. (2019). *Fire and emergency service self-assessment manual* (10th ed.). Commission on Fire Accreditation International. <https://cpse.org/wp-content/uploads/2019/08/10th-Edition-FESSAM-Strikethrough-Underline-v.4.pdf>

Criminal Code, R.S.C. 1985, c. C-46 (Canada; consolidated to 2026-09-30; ss. 22.1, 22.2 and 217.1). <https://laws-lois.justice.gc.ca/eng/acts/c-46/>

CSA Group. (2016). *CSA Z259.12:16 (R2026), Connecting components for personal fall-arrest systems (PFAS)*. <https://www.csagroup.org/store/product/Z259.12-16/>

CSA Group. (2021). *CSA Z259.16:21, Design of active fall-protection systems* (3rd ed.). <https://www.csagroup.org/store/product/CSA%20Z259.16:21/>

CSA Group. (2021). *CSA Z259.17:21, Selection and use of active fall-protection equipment and systems* (2nd ed.). <https://www.csagroup.org/store/product/CSA%20Z259.17:21/>

Dekker, S. (2016). *Just culture: Restoring trust and accountability in your organization* (3rd ed.). CRC Press.

Edmondson, A. C. (1999). Psychological safety and learning behavior in work teams. *Administrative Science Quarterly, 44*(2), 350–383. https://doi.org/10.2307/2666999

Hollnagel, E. (2014). *Safety-I and Safety-II: The past and future of safety management*. Ashgate.

National Fire Protection Association. (2022). *NFPA 2500, Standard for operations and training for technical search and rescue incidents and life safety rope and equipment for emergency services* (consolidates NFPA 1670, 1858 and 1983). <https://www.nfpa.org/codes-and-standards/nfpa-2500-standard-development/2500>

National Fire Protection Association. (2024). *NFPA 1010, Standard on professional qualifications for firefighters* (consolidates NFPA 1001, 1002, 1003 and 1005). <https://www.nfpa.org/codes-and-standards/nfpa-1010-standard-development/1010>

National Fire Protection Association. (2024). *NFPA 1550, Standard for emergency responder health and safety* (consolidates NFPA 1500, 1521 and 1561). <https://www.nfpa.org/codes-and-standards/nfpa-1550-standard-development/1550>

National Fire Protection Association. (2024). *NFPA 1900, Standard for aircraft rescue and firefighting vehicles, automotive fire apparatus, wildland fire apparatus, and automotive ambulances* (consolidates NFPA 414, 1901, 1906 and 1917). <https://www.nfpa.org/codes-and-standards/nfpa-1900-standard-development/1900>

National Fire Protection Association. (2024). *NFPA 1910, Standard for the inspection, maintenance, refurbishment, testing, and retirement of in-service emergency vehicles and marine firefighting vessels* (consolidates NFPA 1071, 1911, 1912 and 1925). <https://www.nfpa.org/codes-and-standards/nfpa-1910-standard-development/1910>

National Fire Protection Association. (2024). *NFPA 1930, Standard on fire and emergency service use of thermal imagers, two-way portable RF voice communication devices, ground ladders, rescue tools, fire hose, and fire hose appliances* (consolidates NFPA 1931, 1932, 1961, 1962, 1963, 1964 and 1965, among others). <https://www.nfpa.org/codes-and-standards/nfpa-1930-standard-development/1930>

National Institute for Occupational Safety and Health \[NIOSH\]. (n.d.-b). *Fire Fighter Fatality Investigation and Prevention Program* \[Program website and investigation reports\]. Centers for Disease Control and Prevention. <https://www.cdc.gov/niosh/firefighters/fffipp/index.html>

National Institute for Occupational Safety and Health \[NIOSH\]. (2003a). *Fire fighter fatality investigation report F2003-18* (truss roof collapse; summary consulted). Centers for Disease Control and Prevention. <https://www.firehouse.com/lodds/news/10508223/death-in-the-line-of-duty>

Ontario Ministry of Labour, Immigration, Training and Skills Development \[MLITSD\]. (n.d.). *Firefighter guidance notes* (Section 21 Advisory Committee; individual notes revised to 2026). <https://www.ontario.ca/document/firefighter-guidance-notes>

The Human Factor. (2026a). *After the Call, Manual 02: The three tiers and event triage* \[Unpublished manuscript\].