By: Robert Apel, Contributing Author
Out with the old, in with the new,” is a cliché that gets plenty of mileage this time of year, but often with good reason. Businesses, like people, tend to reassess priorities and revise game plans as a new year begins.
With workplace safety such an absolute priority in the construction industry, safety professionals must keep up with ever-changing safety standards and practices and the equipment best suited to meet them.
Fall protection personal protective equipment (PPE) is often at the top of the list, because falls are the leading cause of construction-related deaths, according to the U.S. Department of Labor’s Occupational Safety and Health Administration. OSHA reports an annual average of 362 fatalities from 1995 to 1999 due to falls, a trend that appears to be continuing.
As you know, OSHA enforces the bottom line of standards for workplace/wor-ker safety, including personal protective equipment for fall protection. Part 1926—Safety and Health Regulations for Construction, .28(a) Personal Protective Equipment, states, “The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees.”
According to OSHA, standards {1926.10(a) & .13(c)} apply not only to contractors, but also to subcontractors and suppliers of materials involved in construction activity.
OSHA’s mandatory regulations are usually in line with those established by the American National Standards Institute. (ANSI is a private, non-profit organization that develops U.S. voluntary standardization and conformity assessments and systems for a multitude of products and processes. ANSI also is affiliated with the American Society of Safety Engineers.)
The difference is . . .
Recent changes to ANSI regulations regarding fall protection are significant for the construction industry. The new regulation, A10.32-2004, “Fall Protection Systems for Construction and Demolition Operations,” replaces the A10.14-1991 “Requirements for Safety Belts, Harnesses, Lanyards and Lifelines for Construction and Demolition Use.”
ANSI A10.32 sets new guidelines that pertain to equipment testing, performance and training. Professional safety experts recently compared 24 definitions and conditions of the new standard, A10.32, with the previous, A10.14, as well as OSHA guidelines.
The following highlights will help you quickly identify what changes need to be made to comply with the current regulations for fall protection.
Three notable areas of change in which both the new ANSI A10.32 and current OSHA regulations differ from the past are:
- Body belts are no longer considered adequate for fall arrest. They are permitted for restraint and work positioning only. A full-body harness is required for fall arrest;
- Positioning device systems are no longer considered a fall restraint. ANSI defines a positioning device system as a combination of equipment that permits the user to use both hands freely while being supported on an elevated surface. OSHA’s definition is similar, but calls it a body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning. It must be rigged to prevent a free fall no more than 2 ft and have an anchor strength of 3,000 lb; and
- ANSI standards used in testing arresting force have changed, and the new ANSI A10.32 now differs from OSHA. ANSI allows 1,400 lb maximum and OSHA allows 1,800 lb. Standards assume that the load measured in testing is greater than the force experienced by the person by a factor of 1.4. Therefore, a measured load of 1,400 lb is considered equivalent to a force of 1,000 lb on the human body.
Other changes of note are:
- A qualified person must now supervise the design, installation and use of two types of equipment/processes, as per A10.32 and OSHA, where engineering consultation was once adequate, specifically:
1. Horizontal lifeline: Must be designed, installed and used under the supervision of a qualified person as part of a complete system with a safety factor of two; and
2. Anchorage: The sole specification of A10.14 was 5,000 lb per attached worker. But A10.32 has added an option of a system judged by a “qualified person” to have a safety factor of two is a more feasible process on many construction sites.
- Two new specifications are now indicated for the following conditions (where none had previously existed in A10.14):
1. A capacity of 310 lb or greater is now needed when designed, tested and labeled accordingly as per A10.32. OSHA requires design and test for the higher weight, with 310-lb minimum; and
2. Carabiner: ANSI now requires that carabiners be self-closing, self-locking and capable of being opened only by two consecutive, deliberate actions. OSHA requires the locking type. Both require minimum tensile strength of 5,000-lb gate nose side load to 350 lb, with proof load to 3,600 lb.
Other changes are reflected in the categorization of equipment types and testing of materials. Some requirements, such as formal inspection, remain the same.
For your support
Body harnesses and lifelines are better designed than ever so that workers can be comfortably yet securely protected from falls while they concentrate on maintenance tasks at various heights.
To be sure that fall protection PPE complies with the new standard, the equipment purchaser needs to look for labeling on fall protection products that certify the equipment meets OSHA, ANSI Z359.1 and/or ANSI A10.32-14 requirements. In addition, the users of fall protection must follow guidelines for proper installation, training, inspection and usage.
If your company is considering a change in your fall protection program to specify equipment that meets the new A10.32 standard, you may need to re-evaluate fall protection equipment currently in inventory.
Legacy equipment with markings that indicate compliance with A10.14 may not meet the new requirements of A10.32. This is particularly a concern with older fall-arrest lanyards. When in doubt, contact the manufacturer for advice.
Equipment owners must remember, when buying new body support components, that nothing less than a full-body harness is now required by both ANSI and OSHA.
Some important considerations for selection and use of full-body harnesses are proper sizing, comfort, well-designed hardware and appropriateness for the workers’ needs. Customized body harnesses are now available for better fit, comfort, protection and acceptability by workers. Be sure these questions are answered to your satisfaction.
- Are you able to order exactly the components you want and need?;
- Do webbing straps adequately curve and conform to body contours?;
- Does adequate padding cover areas of pressure?;
- Are the materials durable, yet lightweight and breathable?;
- Are varying widths of straps available?; and
- Are the components of the harness adjustable and appropriate for your needs?
Safety pays
Once an updated equipment shopping list is made, who pays for it? OSHA standards concerning responsibility for payment of PPE are not well defined and were opened for debate in July 2004.
Although the docket is now closed, parties may contact OSHA with their concerns regarding the status of this debate until an official ruling is decided.
At this time, OSHA’s 29 CFR 1926 “Construction Standards that Require the Employer to Provide PPE at No Cost to the Employee” specify PPE for four instances in construction. They are 1926.60 Methylenedianiline; 1926.62 Lead; 1926.103 Respiratory Protection; and 1926.1127 Cadmium. All others are classified simply as “Standards that Require the Employer to Provide PPE.”
So what about “Out with the old, In with the new?” Making safety a priority for all may not be new, but it’s a resolution worth keeping in 2005.
To obtain copies of these standards, type “29 CFR 1910.502” or “ANSI A10.32-2004” into the search area of an Internet browser like www.google.com. OSHA documents are free government documents, but you must pay for hard or downloaded copies of ANSI documents.
About The Author: Apel is product group manager, fall protection for Mine Safety Appliances Co., Pittsburgh.
