Significant developments within OSHA and ANSI safety standards will have a considerable effect on fall protection requirements throughout general industry.
OSHA overview
A major re-write of the 29 CFR Part 1910 for walking/working surfaces and fall protection systems is in the works.
OSHA has proposed many regulatory changes. Most important to general industry is the proposed wording change of the “competent person” definition. Per OSHA law, all organizations that use fall protection must have a “competent person” who is responsible for the day-to-day use, training, inspection, monitoring and enforcement of fall protection.
The proposed OSHA law reduces some of the enforcement requirements of the competent person. The objective is to both shield the competent person, who generally tends to be a blue-collar worker or supervisor, from negligence lawsuits, and focus responsibility of enforcement more directly onto executive management and business owners.
Leaders in Washington and OSHA have made it perfectly clear that safety violations will become more punitive in the future with higher fines.
ANSI action
ANSI has been hard at work developing new equipment and user standards that increase the safety of both fall protection equipment and the workers using it.
Although ANSI is a voluntary standard and not federal law, OSHA can cite ANSI as a “nationally recognized safety standard” and hence a requirement for providing working safety under OSHA’s “General Duty Clause” Section 5(a)(1).
ANSI Z359.1, which has been the original fall protection code from 1992 until present, will slowly be “phased out,” as the new ANSI standards Z359.0 and Z359.2 through Z359.18 take its place.
As of the writing of this article, the following new standards have been released
- ANSI/ASSE Z359.0-2007: Definitions and Nomenclature Used for Fall Protection and Fall Arrest
- ANSI/ASSE Z359.1-2007: Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components
- ANSI/ASSE Z359.2-2007: Minimum Requirements for a Comprehensive Managed Fall Protection Program
- ANSI/ASSE Z359.3-2007: Safety Requirements for Positioning and Travel Restraint Systems
- ANSI/ASSE Z359.4-2007: Safety Requirements for Assisted-Rescue and Self-Rescue Systems, Subsystems and Components
- ANSI/ASSE Z359.6-2009: Safety Requirements & Specifications for Personal Fall Arrest Systems
- ANSI/ASSE Z359.12-2009: Safety Requirements for connecting components for Personal Fall Arrest Systems
- ANSI/ASSE Z359.13-2009: Safety Requirements for lanyards and energy absorbers for Personal Fall Arrest Systems
Although the changes are numerous, I will highlight changes that may be of most significance to general industry.
New labeling: ANSI Z359.13 requires new labeling on energy-absorbing lanyards (commonly called “rip-stitch” or “shock pack” lanyards). This is most important when workers need to tie off at foot level. It is very important to note that the attachment at foot level of a 72-inch long energy-absorbing lanyard will result in a free fall of about 12 feet! This causes a serious injury hazard if the worker unknowingly uses a lanyard capable of absorbing only a 6-foot free fall (the most common lanyard). With the new labeling, the user will now be able to easily identify the 12-foot free fall lanyard from the 6-foot free fall lanyard. (Please note that the 6-foot free fall capable lanyard, that is 72 inches long, is only allowed when the tie-off point is at the D-ring elevation or higher. Consult with your lanyard supplier for more information. Hazard analysis/rescue plan: Also important to general industry is Z359.2, a new ANSI “user” standard that requires a hazard analysis and rescue plan for every instance of fall protection. This is crucial for keeping employees safe while wearing fall protection. Common issues that result in hospital visits after a fall event, even when using fall protection, are improper calculation of fall distance, failure to recognize injury hazards impacted during a fall, and swing fall injuries. Improperly calculated fall distance can result in the user hitting a lower level. This can occur when:
a) 18 feet 6 inches of clearance from the attachment point is not provided when using the common 72-inch-long energy-absorbing lanyard; or
b) Wire rope flex is not taken into account on horizontal wire rope systems. Flexible wire ropes will deflect downward significantly during a fall event. For example, a commonly available 100-foot-long wire rope system may deflect 12 feet or more during a fall event. This 12-foot deflection, added to the 18 feet 6 inches of clearance from the attachment point, requires about 30 feet of clearance when using a 72-inch-long energy-absorbing lanyard.
Swing fall injuries can occur when the attachment point is not directly over the worker’s head. The worker can swing or be “pulled” back into the work platform quite violently.
New developments in equipment and fall protection systems “engineer out” the dangers of fall distance and swing falls. A rigid track “traveling bridge” can be used in conjunction with a self-retracting lanyard (SRL) that continually retracts, like a seat belt, to minimize fall distance. The traveling bridge is designed out of lightweight high strength steel or aluminum so it rolls freely along the runways. When the worker walks along the bridge, the trolley follows the worker overhead without effort. Because the trolley always remains directly over the worker’s head, this eliminates the swing fall effect. Any fall event will be “straight down,” resulting in no impact injury to the worker.
To protect workers, follow the new regulations and seek to minimize fall distance by using SRL’s and rigid attachment points. Where mobility is required, combine SRLs with new rigid track monorails or traveling bridges to minimize fall distance and swing fall injuries to workers.
