Fall Protection Question

CC1

I have recently taken over as the Safety Rep at my jobsite. I attended a class the other day and the instructor said that fall protection systems need to be replaced every 5 years. He said that goes for the harness as well. I'm reading it to mean only the shock absorbing systems.

Every regulation I read only says that Fall Arrest systems need to be replaced. If I inspect my harnesses and they have never been subject to a fall, can't I continue using them until they begin to show signs of wearing?

Thanks for any replies.

Grumpy

When it comes to saftey, better safe than sorry. Tag 'em and Bag 'em.

CC1

Thanks Grumpy, I understand that totally. I have no problem throwing out equipment as it ages. The problem here is that I have 10 sets of gear. This guy is telling me that I have to replace all 10 even though only 6 have been used. The other four are pristine! They are all still servicable, I inspected each one.

He is telling me that you can only keep them for 5 years after the manufacture date. Hell, I bought them in 2003 and they were manufactured in 2001. Using his logic I was screwed when I unpacked them.

I just don't see anything in writing supporting what he says. Thanks for your input though.

River Rat Dad

Meanwhile, !/2 the commercial planes in the sky would qualify for Historical plates if they were cars....

Double-A

Best to have him quote you the regulation that requires it.

If he's correct, then I'd write a purchase order to my safety supplier stating that you need replacements for the ones you're having to retire, manufactured no earlier than 3 months ago.

Be sure to include this recurring expense in your labor burden so that you're not eating the costs, but rather, passing them along to your clients.

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ProWallGuy

I agree that its better safe than sorry, but the 5 year limit on harnesses, even if not used seems bunk to me. I'd get a second or third opinion before I chucked a couple hundred dollars worth of good equipment.

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Double-A

Ninety percent of the good waiters and waitresses fall into that category too, RRD.

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CC1

I emailed him today asking to quote the source. He emailed me back saying that he would get back to me in a few days....makes me think it's bunk too!

I think the harnesses are good, and the regulation is for the fall arrest systems only.

Thanks for the serious input!

snapper21

I thought that I remembered hearing in fall safety class that the only permittable harnesses these days were the "shock absorbing" type. Just a reply to part of your initial post.
As far as the replacement of what you feel is adequate, and I don't disagree with you. If something were to happen, and it was in no way your harnesses fault (the harness that's outdated according to OSHA), it may open you up to legal actions from the employee, or emp's family. Not because it was at total fault, but it may have helped the situation in some manner. All I know is serious accidents and deaths are investigated pretty thoroughly by OSHA. CYA!!!
EDIT
I did mean to say fall arrest rather than harness above, just too da&* hot to replace em.

Double-A

The five year rule, if it is one, may have to deal with normal wear and tear on the harness if used on a regular basis by crews required to use it more often than not.

Dirt and abrasion will wear anything out, and the damage with fabrics is not always where you can see it. So, instead of saying, "replace when worn", they err on the side of caution and $$ and say, "Replace every 5 years."

Just a guess.

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New York Times, July 20, 2006

asbestos

I was involved in Fall protection. This question was always coming up. If stored properly harnesses and shock absorbing lanyards do not spoil, like milk. in my experience any FP equipment being used wears out before 5 years. construction is tough work. Follow manf's recommended inspection procedure. Some items like SRLs (yo-yo's) may have a service requirement. these can be sent back and OKd by the manf. Condition not age is what matters. An ironworker may trash a harness in a month. Painters can ruin stuff in days. And of course a fall of leingth means every part of the system from the harness up needs to be retired.

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snapper21

I guess I can see the fact that the threads that stitch the equipment together can deteriorate to a point in the wrong environments even without use.

Mike Finley

A super easy resolution is usually going to the horses mouth.

I would simply contact the manufacturer, starting with their website and see what they say, if you can't find anything, find their phone number on the site and give them a call.

I wouldn't make determinations on stuff that is going to protect a life by a kangaroo court on an Internet forum. Ya know what I mean?

sheeter

CC1,

You can find information pertaining to your question in the OSHA standards for the construction industry. Review the following sections: Subpart C - 1926.28
Subpart E - 1926-104
Subpart M - in its entirety

OSHA will give you an interpretation.

Sheeter

BBS

Hey CC1,
Just like most manufacturers of safety items they are going to try and cover their own butt.Chances are who ever made yours will reccomend replacing after five years.But the answer is five years or what ever the manufacturer says.You will find this in many senarios,OSHA will say what ever the manufacturer reccomends.Below is a handy guide also.

http://www.weather.gov/directives/05...011015c_01.pdf

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samthedog

More often than not fall arrest systems that are in regular use will need to be replaced every 5 years. This is due to a combination of damage from uv light, chemicals (paint, solvents, xylene vapor and even overspray from other chemicals at use on the jobsite), ingrained sand and abrasives, shock loading and even cold. Much of this damage will not be picked up from a visual inspection as it can occur from the inside out or on a microscopic level. Having the manufacturer check the system is usually more expensive than just replacing it. To add, the 5 year life is from the beginning of service. Most resellers consider the beginning of service from the time you buy it, not the time you first actually use it. This is the standard in many countries.

Be aware that fall arrest systems have to be regularly cleaned and inspected. Cleaning is usually done by mixing pure soap flakes (like sunlight, dove or palmolive pure soap flakes) in warm water and agitating the harness and ropes in the water. Rinse in pure water until the water dripping out is clean. Dry the ropes and harness in the shade by hanging on a line. Don't store wet and do not use anything other than pure soap and clean water.

I had to regularly test and maintain the safety equipment for our fire department and we strictly adhered to the 5 year service life. Most private contractors don't but it's not something I would take a gamble on. Also, some other things to consider with your fall arrest system is ensure that if you work alone you have a system for self rescue or stirrups . It's really dangerous to be left alone hanging.

mrsafetyman

[quote=CC1;116098]I have recently taken over as the Safety Rep at my jobsite. I attended a class the other day and the instructor said that fall protection systems need to be replaced every 5 years. He said that goes for the harness as well. I'm reading it to mean only the shock absorbing systems.

Every regulation I read only says that Fall Arrest systems need to be replaced. If I inspect my harnesses and they have never been subject to a fall, can't I continue using them until they begin to show signs of wearing?

i must confess but do not know of this requirement. There are specific requirements for evaluating and testing fall protection equipment in 1926.502. No where do I read five years. The standard I would us and the most important is the manufactures recommendations.

Usually the standard for fall protection components requires pre-use inspections for cuts, abrasions, elongation, cracks wear etc. I would not want to wait five years prior to having a damaged fall protection component removed from service. If you take the time to read and follow 29CFR 1926.502 you will get a grasp on whats needed. remember the nOn mandatory appendix does not apply, its guidance. There are also inspection labels on many of the lanyards make sure you mark them documenting the inspections. Another thing you can do is give every piece of fall protection equipment a number and then inspect them documenting them on an excel spreadsheet the number, item type, date inspected how inspected. Hope this helps

Ed the Roofer

Who ever is in "Control" of the jobsite, and that could be multiple parties, are responsible for OSHA Safety.

Contact the OSHA Safety Facility nearest you for a precise interpretation and express your concerns.

They REALLY want to help, rather than fine.

Always get the citations that pertain to your questions and document your calls, with whom and when you spoke with them

Attend a FREE OSHA Fall Arrest 10 Hour Seminar the next time one is scheduled near you, or in a neighboring state.

Ed

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safety-qc

The manufacturers have a date on the fall protection that it was made, plus it has years on a tag, you mark the year on the tag the first time used, then go 5 years from that point or when it needs to be changed.

Aiken Colon

As of 5/13/08 this year OSHA now requires that all employeers pay for new and/or replacement PPE.

Here is the list of the actual statutes. Take any of those statue numbers and plug them in to OSHA's website and you will get a more defined statement.

I am not sure how big your company is, but our larger customers usually just give this stuff to their lawyers and have them clarify it. The language is not always clear.

I will be working on a lot of this over the next few weeks to get it perfectly clear for myself also. Eventually I will be posting up some type of web resource on this, so that us average Joe's can understand it and not get a fine because of crazy verbage.

Good Luck



1910.132(a)

Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

1910.132(b)

Employee-owned equipment. Where employees provide their own protective equipment, the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment.

1910.132(c)

Design. All personal protective equipment shall be of safe design and construction for the work to be performed.

1910.132(d)

Hazard assessment and equipment selection.

1910.132(d)(1)

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

1910.132(d)(1)(i)

Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;

1910.132(d)(1)(ii)

Communicate selection decisions to each affected employee; and,

1910.132(d)(1)(iii)

Select PPE that properly fits each affected employee. Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.

1910.132(d)(2)

The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

1910.132(e)

Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.

1910.132(f)

Training.

1910.132(f)(1)

The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:

1910.132(f)(1)(i)

When PPE is necessary;

1910.132(f)(1)(ii)

What PPE is necessary;

1910.132(f)(1)(iii)

How to properly don, doff, adjust, and wear PPE;

1910.132(f)(1)(iv)

The limitations of the PPE; and,

1910.132(f)(1)(v)

The proper care, maintenance, useful life and disposal of the PPE.

1910.132(f)(2)

Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

1910.132(f)(3)

When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:

1910.132(f)(3)(i)

Changes in the workplace render previous training obsolete; or

1910.132(f)(3)(ii)

Changes in the types of PPE to be used render previous training obsolete; or

1910.132(f)(3)(iii)

Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

1910.132(f)(4)

The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.

1910.132(g)

Paragraphs (d) and (f) of this section apply only to 1910.133, 1910.135, 1910.136, and 1910.138. Paragraphs (d) and (f) of this section do not apply to 1910.134 and 1910.137.

1910.132(h)

Payment for protective equipment.

1910.132(h)(1)

Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees.

1910.132(h)(2)

The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.

1910.132(h)(3)

When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots.

1910.132(h)(4)

The employer is not required to pay for:

1910.132(h)(4)(i)

The logging boots required by 29 CFR 1910.266(d)(1)(v);

1910.132(h)(4)(ii)

Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or

1910.132(h)(4)(iii)

Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.

1910.132(h)(5)

The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.

1910.132(h)(6)

Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.

1910.132(h)(7)

This paragraph (h) shall become effective on February 13, 2008. Employers must implement the PPE payment requirements no later than May 15, 2008.

Note to § 1910.132(h): When the provisions of another OSHA standard specify whether or not the employer must pay for specific equipment, the payment provisions of that standard shall prevail.

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