How to Write a Fall Protection Program That Passes RAVS Review

If you have workers performing tasks at heights of six feet or more in construction — or four feet in general industry — OSHA requires a written fall protection program. ISNetworld's RAVS (Review and Verification Service) auditors look at this document closely, and it's one of the most common reasons contractors receive an F grade on ISNetworld.

This guide walks through exactly what a RAVS-compliant fall protection program looks like, which OSHA regulations it must address, and the most common reasons programs get rejected. If you're new to RAVS, start with our overview of what RAVS is and how it works.

The Governing Standard: 29 CFR 1926.500 Series

Your fall protection program must be built around the OSHA construction fall protection standards — specifically:

• 29 CFR 1926.500 — Scope, application, definitions
• 29 CFR 1926.501 — Duty to have fall protection (triggers at 6 feet in construction)
• 29 CFR 1926.502 — Fall protection systems criteria and practices (guardrails, safety nets, personal fall arrest systems)
• 29 CFR 1926.503 — Training requirements

Reference these by number in your program. RAVS auditors specifically check that your written program cites applicable standards — a generic program that says "we follow OSHA" without referencing specific subparts will likely be returned for revision.

The 8 Sections Every RAVS Fall Protection Program Must Include

1. Purpose and Scope

State clearly that the program applies to all employees exposed to fall hazards of 6 feet or more above a lower level (construction) or 4 feet (general industry). Name the company and state that the program is developed in accordance with 29 CFR 1926.501 and 1926.502. Include an effective date and a revision history.

2. Roles and Responsibilities

Identify by job title (not by name) who is responsible for:

• Designating a Competent Person for fall hazard assessments (required by 1926.502(k))
• Conducting pre-task hazard analyses
• Inspecting fall protection equipment before each use
• Ensuring employee training is current
• Investigating fall incidents and near-misses

The Competent Person designation is non-negotiable. OSHA defines this as someone capable of identifying existing and predictable hazards and authorized to take corrective measures. State their qualifications in the program.

3. Fall Hazard Identification

List every category of fall hazard your workers may encounter. This typically includes:

• Unprotected floor holes and openings (covers required per 1926.502(j))
• Leading edges during steel erection or decking
• Roofing work on low-slope and steep roofs
• Scaffolding and elevated platforms
• Ladders (fixed and portable)
• Excavations and trenches
• Wall openings and skylights

Be specific to your trade. A mechanical contractor's hazard list looks different from a structural steel contractor's. RAVS reviewers notice when the hazard list doesn't match the contractor's scope of work.

4. Acceptable Fall Protection Methods

Describe each fall protection system your company uses and the conditions under which each is appropriate, per 1926.502:

5. Equipment Inspection and Maintenance

State your procedure for inspecting fall protection equipment before each use. Include:

• What to look for during harness inspection (stitching, webbing, hardware, labels)
• What constitutes a "damaged" piece of equipment requiring removal from service
• Post-fall equipment retirement policy (any harness or lanyard that has arrested a fall must be removed from service immediately)
• Storage requirements
• Inspection documentation frequency (annual third-party or competent person)

6. Fall Protection Plan for Unprotected Leading Edges

If your work involves situations where conventional fall protection is not feasible (e.g., certain steel erection activities), you must have a written, site-specific Fall Protection Plan per 1926.502(k). This is separate from your main program and must be prepared by a Qualified Person. This is an area where many contractors are rejected — they say conventional fall protection "isn't always feasible" but don't include the required alternative plan language.

7. Training Requirements

Per 29 CFR 1926.503, each employee exposed to fall hazards must be trained by a Qualified Person on:

• The nature of fall hazards in the work area
• The correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems
• The use and operation of personal fall arrest systems, warning line systems, and controlled access zones
• The role of each employee in the fall protection plan

Your program must state training frequency (initial, annual retraining, and after any fall incident). Include your recordkeeping requirement — RAVS auditors want to know training records are maintained.

8. Incident Reporting and Investigation

Describe how fall incidents and near-misses are reported and investigated. Include the corrective action process and how findings are incorporated back into the program. This section signals to reviewers that your program is a living document, not a one-time exercise.

The Most Common RAVS Rejection Reasons

Before You Submit to RAVS: A Quick Checklist

Free Fall Protection Program Template

PrequalPilot's safety program library includes a RAVS-ready Fall Protection Program template that covers all eight sections above, pre-populated with the correct OSHA citations and signature blocks. Available to all subscribers in the Safety Programs section of your dashboard.