This document provides a template and guidance for units to develop a Fall Protection Plan (FPP) for working at heights on aids to navigation (ATON) structures and buoys. It outlines the purpose, goal, affected directives, key definitions, and responsibilities for establishing an FPP to prevent falls and ensure safety. The FPP aims to identify fall hazards, require fall protection equipment, provide training, and establish protocols for hazard assessment, equipment use, maintenance, and rescue procedures while working at elevated heights on ATON infrastructure.

1. Officer in Charge
United States Coast Guard
UNIT NAME
Address
Phone: ( xxx ) xxx-xxxx
Fax: ( )
Email:
UNITINST 5100.24
DATE
This template is designed as an aid to ATON Units in writing the fall protection program (FPP) for
working on ATON structures and buoys. Replace red ITALICIZED text with unit specific information
or delete. Additional comments in red provide GUIDANCE or EXPLANATION and should be deleted
once REVIEWED.
If you’re unit has IDENTIFIED other areas REQUIRING a fall protection plan, EXAMPLE – Climbing
a mast or working on a building, you will need to develop a “general” FPP for those areas. A template
is provided in the Fall Protection TTP. You may add THESE REQUIREMENTS to this
INSTRUCTION or establish separate instruction.
Units are responsible for ensuring that directives comply with the Coast Guard Directive Systems,
COMDTINST M5215.6 (series). If there is a discrepancy between this template and M5215.6, the
manual takes precedence.
UNIT NAME INSTRUCTION 5100.24
Subj: FALL PROTECTION PLAN – WORKING AT HEIGHT ON ATON STRUCTURES/BUOYS
Ref: (a) Safety and Environmental Health Manual, COMDTINST M5100.47 (series)
(b) Fall Protection TTP, CGTTP x-xx.x – needs to be added once promulgated
(c) Aids to Navigation Manual – Structures, COMDTINST M16500.25 (series)
(d) Occupation Safety and Health (OSHA) 29 CFR 1910 subpart “D”, General
maintenances/Walking-Working Surfaces
(e) Occupation Safety and Health (OSHA) 29 CFR 1926.500 subpart “M”, Fall Protection
Construction
(f) American National Standards Institute Fall Protection Code (ANSI) Z359 (series)
(g) Aids to Navigation Structure Climber Personnel Qualification Standard (PQS) Manual,
COMDTINST M16500.14 (series)
(h) Command Admin List, UNITINST 5420
1. PURPOSE. This instruction promulgates the scope, authority and responsibilities for working at
height on aids to navigation (ATON) structures and buoys. The objective of the Fall Protection Plan
(FPP) is to identify and evaluate fall hazards associated with working at height on ATON structures
and buoys and mitigate those risks.
2. ACTION. All hands shall review this instruction upon reporting and periodically thereafter to
ensure they comply and fully understand their roles and responsibilities.

2. UnitINST 5100.24
2
3. DISCUSSION. This command supports all members in their roll to maintain a safe working
environment; the ability to voice concerns related to risk and take corrective action. Working at
heights is inherently dangerous. Reference (a) requires the unit establish an FPP. This instruction
establishes the Coast Guard (unit name) FPP and establishes the minimum requirements for
assigning specific programmatic duties, conducting fall protection hazard surveys, selection, use,
care, and maintenance of fall protection equipment, and training requirements. Personnel must be
trained sufficiently to recognize hazards and implement the requirements of this program. If a
climber or any member of the team feels that a structure is unsafe to climb the activity shall be
halted and reevaluated.
4. GOAL. The goal of this FPP is to prevent the occurrence of falls from elevations of 4 feet or more
(general maintenance) or 6 feet or more (construction) above a lower level, this includes working
over water. This goal will be accomplished through effective education, engineering and
administrative controls, use of fall protection systems, and enforcement of the plan. This fall
protection plan will be continually improved upon and improved to prevent falls from occurring.
5. DIRECTIVES AFFECTED. This paragraph states what affects a directive has on previous or existing
directives – or write “None.”
6. DEFINITIONS.
a. Authorized/Competent Person (ATON Climber – Basic/Advanced): A person who has been
trained in the use of assigned Fall Protection equipment, including hands-on training and
practical demonstrations in a typical fall-hazard situations, and uses personal fall-arrest or
restraint/positioning equipment while performing work assignments at height. Follow all related
procedures and policies and bring to the competent person’s attention all unsafe or hazardous
conditions or actions that may cause injury to either them or any other authorized person before
proceeding with their workplace activates.
b. Competent Person (ATON Climber - Rescue): A person designated by the command to be
responsible for the immediate supervision, implementation and monitoring of the Fall Protection
program, who though training knowledge and expertise is capable of identifying, evaluating and
addressing existing and potential Fall-Hazards and in the application and use of personal fall-
arrest and rescue system, or any component thereof, and who has the authority to take prompt
corrective measures to eliminate or control the hazards of falling. Tasked with implementing
unit training program per reference (g).
NOTE – This definition is general to the FPP and is further defined in the instruction
c. Qualified Person: An individual, who by possession of a recognized degree, certificate, or
professional standing or who by extensive knowledge, training, and experience, has successfully
demonstrated his/her ability to solve or resolve problems relating to the subject matter, work, or
project.
d. Anchor Point – For an Arresting System: A secure point of attachment for lifelines, lanyards,
or deceleration devices. An anchor point must be capable of supporting at least 5000 lbs if non-
certified (3600 pounds if engineered/certified by a qualified person (documentation)) per person
and must be independent of any anchorage being used to support or suspend platforms.

3. UnitINST 5100.24
3
e. Calculated Clearance (Required Clearance): Using the standard formula provided by the
National Aids to Navigation School course ATON Structure climber this comes to 18 feet. This
is from the anchor point of the fall arrest system to the feet of the climber vertically in a fall
using 6’ energy absorbing lanyards.
f. Deceleration Device: Any mechanism, such as a rope grab, rip-stitch lanyard, a specially
woven lanyard, tearing or deforming lanyard, automatic self-retracting device, etc., which serves
to dissipate a substantial amount of energy/force during a fall arrest.
g. Deceleration Distance: The additional vertical distance a falling employee travels excluding
lifeline elongation and free fall distance, before stopping, from the point at which the
deceleration device begins to operate. It is measured as the distance between the location of an
employee’s body harness attachment point at the moment of activation of the deceleration device
during a fall, and the location of that attachment point after the employee comes to a full arrest
(stop).
h. Fall Arrest System: A fall arrest system is a combination of equipment and components
connected together to control a fall once a worker has fallen and stops the fall with minimum
impact on the employee; avoiding contact with a lower level. Fall arrest systems consist of an
anchorage system, body support, connecting means, and deceleration device (remember as A, B,
C, D).
i. Fall Restraint System: The prevention of a fall by using a tether (lifeline, lanyard or work
positioning) attached to a user’s harness or other system (hand rails or ladder safety climbing
system) that prevents him/her from reaching an unprotected edge or unprotected opening.
j. Free Fall: The act of falling before a personal fall arrest system begins to activate (apply force)
to arrest the fall.
k. Free Fall Distance: The vertical displacement of the fall arrest attachment point on the
employee’s body harness between the onset of the fall and just before the system begins to
activate (apply force) to arrest the fall. Free fall distance must not exceed 6 feet.
l. Full Body Harness: Webbing/straps which are secured about an employee’s body in a manner
that will distribute the fall arrest forces over the thighs, pelvis, waist, chest and shoulders.
Having means for attaching it to other components of a personal fall arrest system, preferably at
the shoulders and/or middle of the back.
m. Total Fall Distance: The maximum vertical change in distance from the bottom of an
individual’s feet at the onset of a fall, to the position of the feet after the fall is arrested. This
includes the climber’s height, free fall distance, the deceleration distance, harness stretch and a
2’ safety factor.
n. Guardrail System: A barrier erected to prevent employees from falling to lower levels. This
system includes a toe board, mid rail and top rail.

4. UnitINST 5100.24
4
o. Lifeline: A component consisting of a flexible line for connection to an anchorage at one end to
hang vertically (vertical lifeline). This serves as a means for connecting other components of a
personal fall arrest system to the anchorage, normally a rope grab.
p. Lower Level (29 CFR Sub Part M, 1926.500): Those areas or surfaces to which an employee
can fall. Such areas or surfaces include, but are not limited to, ground levels, floors, platforms,
ramps, runways, excavations, pits, tanks, material, WATER, equipment, structures, or portions
thereof.
q. Personal Fall Arrest System (PFAS): A system used to arrest (catch) an employee in a fall
from a working level. It consists of an anchorage location, connectors, a body harness, and may
include a lanyard, deceleration device, lifeline, or any combination of the before-mentioned
items.
r. Rescue – Suspended: This method involves the rescuer descending via a rescue rope down to
the victim, connecting themselves to the victim’s harness, than freeing the victim from their
lanyard and descending together the rest of the way down to safety.
s. Rescue – Assisted: This method involves the rescuer staying connected to the structure,
connecting a rescue rope to the victim and using a decent device to lower the victim to safety.
t. Rope Grab: A deceleration device, which travels on a lifeline and automatically, by friction and
gravity, engages the lifeline and locks to arrest the fall of an employee.
u. Snaphook: A connector comprised of a hook-shaped member with a closed keeper which may
be opened to permit the hook to receive an object and when released, automatically closes to
retain the object. Snaphooks must be self-closing with a self-locking keeper which remains
closed and locked until unlocked and pressed open for connection or disconnection, thus
preventing the opportunity for the object to “rollout” of the snaphook.
v. Work Positioning Lanyard (Restraint): A lanyard that has been manufactured or is adjustable
to a specific length, such that when coupled between a restraint anchorage and a user’s body
holding device, the user cannot reach an unprotected edge or opening. Also permits the user to
have both hands free while being supported on an elevated surface (positioning lanyard). When
used properly this system will not allow the worker to fall more than 2’.
7. RESPONSIBILITIES.
a. Executive Officer/Executive Petty Officer (XO/XPO) (Per Cutter regulations XO/XPO is
designated as Safety Officer) May be assigned to other appropriate department head). Shall
periodically review this instruction to ensure currency in unit policy and procedures. Coordinate
with this unit’s servicing Safety & Environmental Health Officer when needed to conduct
assessments or reassessments to identify fall hazards and other issues related to working on
ATON structures and buoys.
b. Assistant Unit Safety Officer (May be combined with XO/XPO or other Department Head).
Shall assist the XO/XPO in coordinating assessments and work with the unit’s designated Fall

5. UnitINST 5100.24
5
Protection Program Manager (FPPM) for working at height on ATON structures to address
safety related issues and ensure procurement of needed climbing safety equipment.
c. Fall Protection Program Manager (FPPM) (Units may combine with b above; ideally if units are
unable to span three individuals it should be a minimum of two). This person shall complete
formal training (NATON C School), be certified as ASC-Rescue (Competent Person Rescue
Trainer) at the unit and can serve as Safety Observer during climbs. Shall be assigned per
reference (h). In addition they shall carry out the following duties:
(1) Upon assignment or relief, the FPPM reviews the FPP to ensure compliance with current
policies and requirements and provides input to the XO/XPO in order to keep this instruction
current.
(2) Advise the Commanding Officer/Officer in Charge (CO/OIC) of problem areas within the
plan and unit’s climbing program.
(3) Inspection, maintenance, and documentation of all climbing equipment per reference (e) and
manufactures manuals. This inspection shall be logged and completed annually (units may
require more stringent cycle – semi-annually/quarterly/monthly - depending on
operations/use of equipment) per reference (f).
(4) Developing unit rescue plans. Providing training for and implementing rescue plans,
executing practice rescues, and/or coordinating and performing actual rescues.
(5) Developing and overseeing the unit’s climber training program per reference (g) to include:
(a) Track the progression of members seeking qualification.
(b) Sign off completed PQS tasks.
(c) Evaluate Basic and Advanced candidates; provide feedback and recommendations to the
CO/OIC for qualification and certification.
(d) Maintain awareness of the unit’s certified climbers and their currency requirements per
reference (g).
(e) Recertification of climbers per reference (g).
d. Supervisor/Department Head.
(1) The duties and responsibilities of a supervisor include the following:
(a) Ensure subordinate personnel are appropriately trained and certified prior to assigning or
allowing personnel to work in fall protection areas.
(b) Ensure subordinate personnel adhere to the requirements of the unit FPP.
e. Fall Protection Competent Person Rescue (FPCP-R) – ASC-Rescue.

6. UnitINST 5100.24
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(1) A competent person rescue is a willing volunteer who is certified and authorized in writing
by the CO/OIC to work in fall protection areas as a supervisor of fall protection competent
and authorized persons. The duties and responsibilities of the FPCP-R include the following:
(a) This person shall complete formal training (NATON C School), be certified as ASC-
Rescue (Competent Person Rescue Trainer) at the unit.
(b) Serve as the safety observer/rescue climber during all climbs.
(c) Assist the FPPM in the following tasks:
1. Supervise, implement, and monitor the FPP.
2. Identify hazardous and dangerous conditions in the work area and take prompt
corrective measures as needed.
3. Assist in training members and completing PQS task sign-offs per reference (g).
4. Evaluate Basic and Advanced candidates; provide feedback and recommendations to
the FPPM for qualification and certification.
5. Assist in conducting inspections and accident investigations.
(d) Will ensure proper equipment selection and usage during all climbing evolutions.
(e) Ensure end-users using fall protection equipment are adequately trained.
(f) Understand fall protection systems and equipment.
(g) Supervise Competent and Authorized Person in the performance of work in fall
protection areas.
(h) Understand fall protection regulations and standards.
f. Fall Protection Competent Person (FPCP) – ASC-Advanced.
(1) A competent person is a willing volunteer who is certified and authorized in writing by the
CO/OIC to work in fall protection areas under the supervision of an FPPM/FPCP-R. The
duties and responsibilities of the FPCP include the following:
(a) Complete required task per reference (g) under the supervision of the FPPM/FPCP-R.
(b) Authorized to climb ATON structures 20 feet and greater.
(c) Properly use, maintain, and inspect fall protection equipment using guidance provided by
the FPPM.
(d) Ensure compliance with and implementation of the FPP.

7. UnitINST 5100.24
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g. Fall Protection Authorized Person (FPAP) – ASC-Basic.
(1) An authorized person is a willing volunteer who is certified and authorized in writing by the
CO/OIC to work in fall protection areas under the supervision of an FPPM/FPCP-R. The
duties and responsibilities of an FPAP include the following:
(a) Complete required task per reference (g) under the supervision of the FPPM/FPCP-R.
(b) Authorized to climb ATON structures less than 20 feet.
(c) Properly use, maintain, and inspect fall protection equipment using guidance provided by
the FPPM.
(d) Ensure compliance with and implementation of the FPP.
8. PROGRAM EVALUATION.
(FP TTP will provide information on how these items will be used to evaluate the FPP)
a. This instruction will be evaluated periodically to determine its effectiveness. The following
criteria will be used:
(1) Applicable Mishap reports and near misses.
(2) Members’ compliance with this instruction.
(3) Review of onsite activities.
(4) User feedback.
(5) Equipment recalls.
(6) Changes to any references listed in this instruction.
(7) ALCOAST Messages affecting FPP or equipment.
(8) Equipment, program or policy changes received from NATON.
9. TRAINING REQUIREMENTS.
a. Per reference (g) ATON Structure Climber – Rescue must receive formal training. This training
can be completed by attending the NATON ATON Structure Climber course or by attending a
NATON approved commercial course that includes training in rescue. Per reference (a), (b) and
(g) these members may serve as the units FPPM and/or FPCP-R.
(1) The FPPM and the unit training officer will work to ensure an adequate number of members
receive formal training to meet unit needs.

8. UnitINST 5100.24
8
b. ATON Structure Climber Advanced (FPCP) and Basic (FPAP) shall be trained, qualified and
certified per reference (g).
(1) FPPM/FPCP-R will identify members who will be good candidates for
qualification/certification as ATON Structure Climber Advanced and basic. They shall
implement the necessary training to meet unit needs.
c. Once certified, members will maintain currency in accordance with reference (g).
d. Recertification will be completed in accordance with reference (g)
10. PREVENTION AND CONTROL MEASURES.
a. All workers near fall hazards will follow standard safety techniques and polices to prevent falls
from occurring
b. Where possible engineering controls will be utilized to reduce the need for PFAS and decrease
the possibility of a fall. If possible relocation of equipment to a lower level to conduct servicing
will be a primary means of instituting engineering controls. Additionally if feasible, improved
day board mounting practices will be developed to reduce exposure time while working at
height.
c. The use of step or extension ladders may provide for a more stable working environment and
also remove the need for members to be trained in fall protection. If ladders are used the
member should have a working knowledge of how to properly and safely use the step or
extension ladder.
d. Unit specific requirements
11. HAZARD ASSESSMENT.
(Remove/edit section if your unit does not work on ATON Structures/tailor to your units needs –
buoy information is includes below but may need to be tailored for unit needs)
a. Do to the large number of ATON Structures assigned to this unit and standardization of most
structures a hazard assessment for each structure type and required fall protection is contained
in enclosure 1 as an information sheet. Aids with special requirements/hazards will have their
own specific information sheet in enclosure 1.
(1) Prior to each climb, the team will complete an ATON Structure Inspection Form (CG-6042).
If hazards are identified and the structure is deemed unsafe to climb suspend operations and
notify the CO/OIC as soon as possible.
b. In the event of a major work project, a special hazard assessment will be conducted.
c. Appendix B of reference (c) provides datasheets for various ATON structures in use by the Coast
Guard. Each data sheet has a paragraph stating the recommend fall protection required for
working on a given type of structure. This recommendation will be the primary guiding

9. UnitINST 5100.24
9
information related to selecting the proper level of fall protection to be used. Both the primary
climber and safety climber shall agree on the level of protection required.
d. Minor ATON Structures: Normally 20’ or less in height.
(1) Climbing and performing work on most minor structures will not require the use of fall
protection, as the work area is located at relatively low height above the water surface (or
ground) and using fall protection may adversely impact climber safety and ability to
accomplish work. When structures satisfy the conditions for guardrails per reference (c), this
will meet the requirement for fall restraint eliminating the need for a personal fall arrest
system (PFAS), provided the guardrails are in serviceable condition. If the climber will be
working from the ladder, a full body harness and work positioning lanyard will be required
for the climber to work hands free.
(a) If no guardrails are installed or they are not serviceable then the climber may utilize a full
body harness and work positioning lanyard in order to work hands free. This will serve
as fall restraint and ideally prevent the climber from stepping off the platform. The risk
relative to falling on ground or water at a low level will need to be taken into
consideration.
NOTE: Minor ATON structures do not provide the proper anchor points or available clearances for the
use of PFAS. In order for the PFAS system to work properly, the anchor point for attaching the arrest
system must be at or above the climber’s dorsal D-ring, capable of supporting 5,000 lbs (non-certified)
or 3,600 lbs (certified), and must provide for a minimum of 18’ clearance from the lower level in the
event of a fall.
e. Major ATON Structures: Over 20’ in height.
(1) Performing work on major ATON structures will require PFAS on the structure platform and
while climbing and working on the skeleton tower. For multiple pile platform structures,
guardrails shall be in place, serviceable, and serve as the fall restraint system on the structure
platforms. In addition, a ladder safety device on a fixed ladder and guardrails on the top
platform shall be in place, serviceable, and serve as the fall protection systems on skeleton
towers.
(a) When using a ladder safety device the climber will be fully dressed out in PFAS.
(2) If a climber is not designated as the primary or safety and will be remaining on the primary
platform, they will not be required to be dressed out in climbing equipment, provided the
guardrail system is in place and serviceable.
(3) Anyone who will be, or has the potential to climb, will be dressed out in a full body harness,
energy absorbing lanyards and have a work positioning lanyard attached to their harness.
(4) Enclosure 1 has more specific requirements and details for major structures within this unit’s
area of responsibility.
f. Additional Hazards to consider.

10. UnitINST 5100.24
10
(1) Stinging insects and snakes.
(2) Poisons plants.
g. Unit specific requirements
h. Buoys: (Remove this section if your unit does not work on buoys)
(1) Climbing and performing work on buoys will not require the use of energy absorbing
lanyards, as the work area is located at relatively low height above the water surface (or
ground) and using energy absorbing lanyards may adversely impact climber safety and
ability to accomplish work. If the climber will be working from the buoys cage or body, a
full body harness and work positioning lanyard will be required for the climber to work
hands free. This will serve as fall restraint and prevent the climber from falling from the
buoy.
(a) The use of step or extension ladders may provide for a more stable working environment
and also remove the need for members to be trained in fall protection. If ladders are used
the member should have a working knowledge of how to properly and safely use the step
or extension ladder.
(b) Unit specific requirements
12. PRE CLIMB/WORK FROM ELEVATED SURFACES AND WORK SITE INSPECTION.
a. The First step is to review the aid folder/FID to determine if there are any specific issues
documented in regards to working/climbing on the structure.
b. Pre planning that includes ensuring the required equipment is available on scene is a critical
element of ATON Structure Climbing. Always ensure the following equipment is included in
the items taken to the scene:
(1) First aid kit – Inspect prior to departing the unit
(2) Working at height rescue kit – Inspect the kit and equipment prior to departing
(3) Climbers’ gear bag
(4) Ladder safety climbing devises as needed
NOTE: Once on scene and it is determined that any of the above equipment is missing,
incomplete, or unserviceable; suspend work and notify the CO/OIC immediately.
c. For none routine or special evolutions a fall protection plan will be specifically developed to
include detailed equipment use requirements and rescue plan. Additional training shall be
conducted to meet the specific requirements of the plan.
d. Climbers will inspect their personal climbing equipment prior to and post use. If issues are
identified they shall not use the equipment and notify the FPPM/FPCP-R immediately.

11. UnitINST 5100.24
11
e. Surveying and assessing fall hazards on ATON structures will be conducted at every visit where
climbing will occur.
(1) Prior to each climb, the team will complete an ATON Structure Pre-Climb checklist and risk
assessment form (Enc 2) and an ATON Structure Inspection Form (CG-6042). If hazards are
identified and the structure is deemed unsafe to climb, notify the CO/OIC as soon as
possible. If the structure is going to be worked from the boat, a Pre-Climb checklist will not
need to be completed. A CG-6042 will still need to be completed.
f. After each climb a review will be completed of the evolution. Any issues identified with the FPP
or specific to working at the given structure will be documented on the FID worksheet.
(1) Changes to the FPP will be passed to the FPPM.
(2) Information specific to working on the structure will be documented on the FID.
g. Unit specific requirements
13. PROPER USE AND INSTALLATION OF FALL PROTECTION SYSTEMS.
a. All climbers will follow standards provided during training and equipment user
guides/instructions while using fall protection equipment.
b. Installation of permanent fall protection systems (ladder safety devices) will be conducted per
the manufactures instructions and guidance from the approving authority and/or qualified person.
c. Unit specific requirements
14. USE OF FALL PROTECTION SYSTEMS.
a. All personnel subject to fall hazards will follow standards provided during training and in
equipment user guides/instructions while using fall protection equipment.
b. In the event of a major work project or extended operation, a fall protection plan will be
specifically developed for the situation and include detailed equipment use requirements.
Additional training shall be conducted to meet the specific requirements of the plan.
c. Installation of permanent fall protection systems (ladder safety devices, horizontal life lines,
guard rails) will be conducted per the manufactures instructions and guidance from the
approving authority and/or qualified person.
d. Unit specific requirements
15. RESCUE PROCEDURES.
a. Prior to the start of any work at height, a rescue plan will be identified and discussed with all
members. This shall include the location of the nearest emergency medical services (EMS) and
their contact information (911 etc.)

12. UnitINST 5100.24
12
b. Once a fall occurs, the designated safety observer will initiate the rescue plan for that specific
work site. Members not directly involved should immediately contact EMS and/or OPCON.
c. Initial actions are critical for anyone suspended in a full body harness as death can occur in 30
minutes or less.
d. When the situation is stabilized, notification shall be made to OPCON, the CO/OIC and
XO/XPO.
e. Minor ATON structures: Depending on the location of the victim and equipment used, the most
common rescue requirement will be to recover the victim from the water. If the climber was
using work positioning lanyard, the employment of an assisted rescue process may be utilized.
The primary steps include attaching a safety line to the victim; clearing the member of the work
positioning or other obstruction and lowering them to safety.
f. Major ATON structures: Specific plans will be developed and discussed prior to departing the
unit.
g. Unit specific requirements
16. RECORDS MANAGEMENT CONSIDERATIONS. This instruction has been thoroughly reviewed
during the directives clearance process, and it has been determined there are no further records
scheduling requirements, in accordance with Federal Records Act, 44 U.S.C 3101 et seq., NARA
requirements, and Information and Life Cycle Management manual, COMDTINST M5212.12
(series). This policy does not have any significant or substantial change to existing records
management requirements.
17. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. Environmental
considerations were examined in the development of this Instruction and have been determined to be
categorically excluded.
18. FORMS/REPORTS. ATON Structure Inspection Form (CG-6042)
//s//
NAME/RANK
Commanding Officer/Officer in Charge
Encl: (1) Aid Specific Information
(2) ATON Structure Pre-Climb Checklist and Risk Assessment

13. Enclosure 1
Aid specific information – Single Pile Wood (SPW)
Can cover multiple structures of the same type – considering land or water based issues
Insert picture here
Structure Type: SPW w/A-frame
Total Height: Platform is 18’ above water at
normal low tide.
Description: Single pile wood with A-frame,
has ladder lagged into pile.
Special Requirements:
Unit specific
Climber Requirement:
1 Basic or 1 Advanced
1 Rescue to serve as safety supervisor
Fall Protection Minimum Equipment:
1. Full body Harness
2. Work Positioning Lanyard for working
hands free
3. Rescue Kit
4. Life jacket
Special Equipment/Fabrication for climbing:
Unit specific requirements.
Example if aid is located on land a 30 foot
extension ladder may be used to eliminate the
need for PFAS.

14. UnitINST 5100.24
Enclosure 1
Aid specific information – Multi Pile Platform/Skelton Tower
Insert picture here
Aid Name: NATON Rear Range LT
LLNR: 12345
Date Built July 20, 1940
Foundation: Multi pile platform/ground
Structure Type: Multiple pile platform with 108
foot skeleton tower
Total Height: 120 feet
Last CEU Inspection: unknown
Description: This aid is 120’ tall with installed
ladder safety device. Main platform is 12 feet
above ground. Aid is on dry land.
Special Requirements:
Unit specific
Climber Requirement:
Due to this aid’s height 3 climbers are required
when climbing. Primary climber and two safety
observers. Or 2 Advanced and 1 Rescue
Climber.
The aid is approximately 30nm from the nearest
point of emergency rescue/medical services.
Prior to departing or starting work the
following units will be notified:
USCG Station Two Rivers COMCEN at xxx-
xxx-xxxx.
Fall Protection Minimum Equipment:
1. Full body Harness/PFAS
2. First Aid Kit
3. Rescue Kit
Special Equipment/Fabrication for climbing:
Need 20 foot extension ladder to access first
platform which is 12 feet above ground. Climbers
shall be fully dressed out and use PFAS with
ladder safety device.

15. ATON Structure Pre-Climb
Checklist and Risk Assessment
Page 1 of 2 Enclosure 2
Date: Structure Name: Type:
Climbing Team Position Name Qualification Level
Safety Observer/Supervisor  Rescue (minimum)
Primary Climber  Basic  Advanced  Rescue
Alternate Climber  Basic  Advanced  Rescue
Alternate Climber  Basic  Advanced  Rescue
NOTE: For structures over 150’ a secondary climber must ascend staying within 150’ of primary climber.
This climber shall be rescue certified.
Purpose of Climb:_____________________________________________________________________________________________
____________________________________________________________________________________________________________
____________________________________________________________________________________________________________
Current Weather Forecasted Weather
Sunny/Temperature Sunny/Temperature
Rain Rain
Snow Snow
Fog Fog
Ice Ice
Winds (knots/MPH) Winds (Knots/MPH)
Emergency Medical Services (EMS) Contact Information
Prior Notification Made of climbing operations?
 No /  Yes – Agency Name/Number:
Nearest Hospital/Number:
Primary EMS Contact Number if no prior notification:  911 /  Other – Number:
NOTE: Ensure route maps to nearest medical services are located where members can access them and all team members are
aware of EMS contact procedures.
RESCUE PLAN
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Pre-Climb Checks Initials
Climbing Gear issued is in good working order and PMS has been performed.
Ensure climbers know location and proper operation of safety equipment and first aid kits.
Perform hand-held radio or cell phone check. Ensure radio checks are conducted every 5 minutes while climbing
in reduced visibility.

16. ATON Structure Pre-Climb
Checklist and Risk Assessment
Page 2 of 2 Enclosure 2
Pre-Climb Checks (Continued) Initials
Ensure Structure is de-energized for mounting, climbing and dismounting.
Check for any special fabrications needed before work begins.
Ensure safety lanyard is attached to all tools and equipment on the structure to prevent missile hazard.
Check for any electrical dangers, noise, live hazards (snakes, birds, insects, rodents, farm animals and other
humans).
Perform individual pre-climb inspections of Personal Protective Equipment (harness, D-rings (centered on back),
deceleration lanyards, working lanyards, and ladder safety device) include route inspections.
ATON Structure Inspection Form (CG-6042) completed -  Yes  No
Command Specific Requirements
Discus Climb Plan and Evolution to include the WHO, WHAT, WHEN and HOW
Comments:__________________________________________________________________________________________________
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GAR Operational Risk Management Assessment (Score between 1 and 10)
SUPERVISION: Supervisory Control should consider how qualified the supervisor is and is the supervision taking
place. (0 low risk to 10 high risk).
PLANNING: Planning and preparation should consider how much information you have, how clear it is, and how
much time you have to plan and evaluate the information. (0 low risk to 10 high risk).
CREW SELECTION: Crew selection should consider the experience level of the individuals used for the specific
evolution. (0 low risk to 10 high risk).
CREW FITNESS: Crew fitness should consider the physical and mental state of the crew. This is generally a
function of how much rest the crew has had. (0 low risk to 10 high risk).
EQUIPMENT: Equipment should consider factors that may affect operational status of equipment such as
monitoring and controls of equipment, rated load, conditional status of equipment. ( 0 low risk – 10 high risk)
ENVIRONMENT: Environment should consider factors affecting personnel, cutter, and attached boat performance.
This includes time of day, temperature, sea conditions, etc. (0 low risk to 10 high risk).
EVOLUTION COMPLEXITY: Event complexity should consider both the required time and the situation. The
longer exposed to a hazard, the greater the risks. (0 low risk to 10 high risk).
SCORE
 GREEN – 0 to 26  AMBER – 27 to 48  RED – 49 to 70
NOTE: For scores in the AMBER and RED discus mitigation options or consider postponing climb. For structures that do
not have a favorable inspection (CG-6042) notify CO/OIC and suspend climb till corrective action can be taken.
Safety Observer/Supervisor Name/Signature: Date:
CO/OIC Name/Signature: Date:
Climb Start Time: Climb End Time:
Observations/good to know for next visit:
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