While some
fall protection issues are black and white, there are others that fall into a
gray area. One of these gray areas involves using aerial lifts to carry
employees to overhead stations. Prior to May of 2001, this was an issue that
was very confusing in the fall protection community because OSHA regulations
require any worker in an aerial lift to be anchored to the lift with a
restraint or fall arrest system. Then in 2001, OSHA released a letter of
interpretation stating this regulation on aerial lifts does not prohibit a
worker from exiting or entering an aerial lift basket that rests on or adjacent
to an elevated surface.
However,
when employees move from the basket to the elevated surface, the requirements
in OSHA 1926, subpart M,may apply. Workers entering or exiting a lift must be
safeguarded from any unprotected sides or edges. This can be accomplished with
the use of guardrails, a fall restraint or a fall arrest system. Subpart M also
elaborates within 1926.502(d)(16) that, “personal fall arrest systems, when
stopping a fall, shall be rigged such that an employee can neither free fall
more than six feet nor contact any lower level.”
In January
of 2009, OSHA attempted to answer a question regarding the use of lanyards that
require 18.5 feet of clearance. As a general rule, a lanyard that requires 18.5
feet of clearance is going to be a six-foot energy-absorbing lanyard. To reduce
the clearance needed, the worker can use a restraint system, a shorter lanyard
or a self-retracting lifeline (SRL) that has been approved for use in such
applications.
Self-retracting lifeline/lanyard means a deceleration device which contains a drum wound line which may be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement, and which, after onset of a fall, automatically locks the drum and arrests the fall.
Of course, companies
should always check the equipment manual for proper clearance instructions for
all personal protective equipment.
The gray
area is this: Competent persons, as deemed by the employer, know that using a
six-foot energy-absorbing lanyard will not meet OSHA requirements because the
lanyard will not protect a worker from striking objects below in the event of a
fall. The object in this case would be the ground when moving the lift from
one location to another when the lift is in the lower position.
Keep in mind
that employees also leave the lift to perform specific tasks when they cannot
reach the work site due to obstructions, though working from the lift is always
much safer. This demonstrates that the worker does not have 18.5 feet of
clearance below and that a six-foot energy-absorbing lanyard is not the right
tool for the task.
From a
training specialist’s perspective, this is an issue that confronts companies
time and time again. The best solution for employees working from aerial lifts,
when feasible, is to use a fall restraint system. However, if the worker
requires more mobility for the task either within the aerial lift or outside
the lift, the next best solution is to use an approved SRL.
The fall
protection industry offers several different SRL options to achieve this goal. a 10-foot Rebel SRL with a swivel snaphook - the Rebel attaches to the anchor in the aerial lift. Also, the
harness being worn by the worker should have a tie-back talon attached to the webbing of the harness. This allows the employee to attach the
tie-back talon to the appropriate anchor at the work location still maintaining
100 percent fall protection.
Finally,
workers should remember to never attach a snaphook to a dorsal D-ring
that already has another connector on it. This violates OSHA 1926.502(d)(6).
There are
many other ways in which competent persons can keep workers safe at heights.
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FALL
PROTECTION / SRL
Harnesses,
retractable lanyards and static lines are effective in minimizing the risk of
working at height – but, to do this properly they must be in good working
order. Therefore this equipment must be used, stored, inspected and cleaned
correctly.
SELF
RETRACTING LIFELINES/DECVICES (SRL/SRD)/CLIMB ASSIST SYSTEMS
ANSI
requires the product to be inspected at least annually by a Competent Person
Extreme
conditions of use may require increasing inspection frequency (In Canada, CSA
requires SRL’s to be serviced within two years of mfg. date, thereafter
annually)
Before each
use OSHA and ANSI require SRL’s to be inspected (by the user)
After an
impact, the SRL must be removed from service (per OSHA and ANSI) and inspected.
Servicing
may be required
WINCHES
Manufacturers
recommend that winches be serviced and recertified every year (extreme working
conditions may require increasing the frequency)
On a
monthly basis the manufacturers recommends that a competent person other than
the user formally inspect the winches
Before each
use, the manufacturers require winches to be inspected (by the user)
After an
impact, the winch must be removed from service and inspected (servicing may be
required)
RESCUE
POSITIONING DEVICES (RPD’s)
The
manufacturer recommends that RPD’s be serviced and recertified every year
(extreme working conditions may require increasing the frequency)
On a
monthly basis, the manufacturers recommend that a competent person other than
the user formally inspect the RPD
Before each
use, the manufacturer requires the RPD to be inspected (by the user)
CONTROLLED
DESCENT DEVICE
Manufacturers
recommend that these devices have maintenance check performed every 6 months by
the user or competent person
On a
monthly basis, manufacturers recommend that these devices be formally inspected
by a competent person other than the user
LADDER
SAFETY SYSTEM
Manufacturers
requires the ladder safety system is by inspected at least annually by a
competent person
Before each
use, manufacturers and OSHA require the system to be inspected (by the user)
After an
impact, the entire system shall be inspected by a competent person
TRIPODS,
DAVIT ARMS, SUPPORT STRUCTURES
Manufacturers
require at least a monthly inspection by a competent person
Before each
use, manufacturers, OSHA and ANSI require an inspection (by the user)
After an
impact, remove the product from service and inspect (servicing may be required)
LOAD
ARRESTORS
Manufacturers
require the load arrestors to be serviced and recertified every two years
(extreme working conditions may require increasing the servicing frequency)
Annually, a
competent person should inspect the units
After an
impact, the load arrestor must be removed from service and returned to a repair
center for service/recertification