Construction Safety Week is here again and we’re reclaiming the hierarchy of fall protection.
While the industry has made progress, there’s still a glaring truth we can’t ignore: when it comes to fall safety, we’ve lost site of how the hierarchy of fall protection is meant to work.
“Falls are still the largest cause of fatalities in construction. It’s good that we dedicate time to it—but we should do more. The stats are still bad. In fact, they’re horrible,” says Deb Hilmerson, President & CEO of Hilmerson Safety.
And while the industry continues to introduce new technologies and gear, we often lose sight of the most effective solution: removing the hazard entirely.
“You give everybody a harness and you think that’s safety,” says Hilmerson. “That doesn’t work. That doesn’t eliminate anything.”

The Fall Protection Hierarchy of Controls
Instead of focusing only on reactive gear and training, we need to reorient ourselves around the hierarchy of fall protection and work from the top down, not the bottom up.
What Is the Hierarchy of Fall Protection?
OSHA’s hierarchy of controls is a five-step model for protecting workers from hazards—ranked from most effective to least:
- Elimination – Remove the hazard entirely.
- Substitution – Replace the hazard with something safer.
- Engineering Controls – Isolate the worker from the hazard.
- Administrative Controls – Change how the work is performed.
- Personal Protective Equipment (PPE) – Equip workers with gear.

Unfortunately, in construction, the hierarchy often gets flipped on its head.
“The hierarchy feels like it’s upside down,” says Hilmerson. “Everyone thinks PPE is the solution. They hand you a harness in a can and say, ‘Here you go—go to work.’ That doesn’t cut it.”
Let’s break it down—one level at a time—and see how leading-edge fall protection, particularly guardrail systems like the Hilmerson Safety Rail System™, fit into this framework.
1. Elimination: Stop the Hazard at the Source
“Number one, the first and foremost thing is the hierarchy: eliminate fall hazards,” says Hilmerson. “That’s the number one job as a safety professional.”
In the real world, that might mean doing as much work as possible on the ground before lifting it into place.
“Think about building trusses,” says Hilmerson. “If we can build something on the ground instead of 60 feet up and lift it, that’s huge. Now you’ve got two guys up there instead of 20.”
Elimination takes planning. It means asking upfront questions:
- Can we build this component offsite?
- Can equipment, not people, do the dangerous part?
- Can we redesign the task to keep workers away from the edge?
“If they don’t have the right tools and equipment, they can’t get the job done,” says Hilmerson. “Then they’re gonna take a shortcut. And that leads to a fatality.”
Too many fall protection conversations start at the bottom—at PPE. Elimination is where they should begin.
2. Substitution: Choose a Safer Option
In some cases, the hazard can’t be removed—but it can be swapped for something less risky.
In chemical safety, it’s easy to understand: trade out a harsh solvent for a safer alternative. In fall protection, substitution might look like this:
“Going from a non-engineered guardrail to an engineered system like ours. That’s a better, safer product.”
Deb points to the outdated reliance on wooden guardrails or wire rope systems:
“Wire rope cable? It’s got to be flagged every six feet, can’t be more than three inches give or take, needs constant tensioning—and it doesn’t come with a toe board. That’s a lot of maintenance.”
Compare that to a pre-engineered guardrail system that’s designed for quick deployment, minimal maintenance, and high durability.


3. Engineering Controls: Build Protection Into the Jobsite
This is where Hilmerson’s solution comes in strongest.
“Engineering is the guardrail,” says Hilmerson. “You’re isolating people from the hazard. You set it at the base, put in the rail, drop in the pin. Done.”
Unlike PPE—which requires every worker to be trained, outfitted, and connected properly—engineering controls passively protect anyone in the area. You don’t need to remember to clip in or double-check a lanyard. The safety is built in.

Especially at leading edges, like rooftops or elevated decks, this kind of system ensures everyone—plumbers, HVAC techs, inspectors—can do their jobs safely, even if they’re not fall protection experts.
“Mechanical guys go up once a month to change a filter on a hospital rooftop. They shouldn’t have to gear up like they’re climbing Everest.”
A permanent or reusable guardrail system is not just smart—it’s sustainable safety.
4. Administrative Controls: The Plan Behind the Protection
Administrative controls are about policies, training, signage, and documentation. They’re important—but they’re often oversold as a fix. That said, good admin controls have a place—especially in pre-job planning and hazard identification.
Deb emphasizes the importance of accountability and pre-planning:
“You can talk all you want, but if there’s no accountability and you don’t give people the right tools, it doesn’t work.”
Effective administrative controls include:
- Onsite, applied training (not just computer modules)
- Daily inspection checklists
- Jobsite-specific hazard briefings
- Preventive maintenance routines
But none of these replace physical protection. They’re the backup, not the barrier.

5. PPE: The Last Line of Defense
Personal protective equipment—harnesses, lanyards, helmets—is necessary. But it’s the least effective form of protection. It requires the worker to do everything right, every time, under pressure.
“You’ve got to connect yourself,” says Hilmerson. “That’s why we call it active fall protection. But if you’re not up 18 feet, your lanyard won’t even help. You’ll hit the ground and break your legs.”
Even with good training, gear can be misused, misunderstood, or forgotten—especially when workers are moving fast to hit schedules.
“A lot of people still think fall protection is: go to Home Depot, grab a harness in a can, and call it good. It’s not even close.”
PPE has its place—but we’ve relied on it for far too long while ignoring better options further up the hierarchy.
Putting It All Together: The Hierarchy of Fall Protection
Construction isn’t going to stop working at height. But how we prepare for height, how we plan for height, and how we protect people from it—that’s what will change the numbers.
“This is the most important part of fall protection education: getting people to stop thinking a harness is the solution,” says Hilmerson. “Eliminate where you can. Control where you can’t. Then protect.”
During Construction Safety Week, you’ll see the usual drop-test demos. You’ll hear about clearance distances and self-retracting lifelines. But the real opportunity is to shift the narrative back to the top of the pyramid.
Let’s stop defaulting to the bottom rung of safety and start designing jobs that don’t require a lifeline to begin with.
“Set them up for success,” says Hilmerson. “People want to do the right thing. Just get them the right equipment.”
Ready to Work from the Top Down?
If you’re looking for a better way to protect your crew at the leading edge, guardrails are your first line—not your last resort.
Start with elimination. Engineer for control. And only use PPE when it’s truly the only way.
The Hilmerson Safety Rail System™ was built by people who’ve been on the beam, clipped in, and seen how bad it can go. That’s why it’s engineered to make safety simple, reusable, and ready to deploy—without the guesswork.

About Hilmerson Safety
Hilmerson Safety® is a full-service safety product design and manufacturing company serving the construction industry. Since 2001 Hilmerson Safety® has been working with construction industry leaders and contractors to develop safe, lean, construction-grade™ products and solutions that add to the company’s bottom line.
For more information email us or call (952) 239-0125