February 2015 Q&A
Q: The issue of multiple snaphooks in a single D-ring and Incident Prevention’s stance on it have received a lot of attention, and we are pleased to address this topic once more in the Q&A section.
A: iP received two notable responses to our guidance regarding manufacturer approvals and OSHA’s requirement that prohibits the use of two snaphooks in a single D-ring unless (1) the snaphook is a locking type and (2) the snaphook is specifically designed for certain connections.
As readers may recall from the December 2014 Q&A (see https://incident-prevention.com/blog/december-2014-q-a), we noted that both Buckingham Manufacturing Co. and Jelco approved the use of two snaphooks in one D-ring. We also pointed out that Buckingham was the first to offer four-D-ring body belts, and that Jelco and other manufacturers also offer these types of belts. Additionally, we addressed the history of the prohibitions and our understanding of the reasons for them, as well as the new locking snap designs that solve the original risks of disengagement.
A reader then forwarded us a letter from Capital Safety, manufacturers of the Cynch-Lok wood pole fall-restricting device. The letter, written by Vice President of Engineering J. Thomas Wolner, ME, PE, does not recommend using a second positioning strap connector to a D-ring that is already occupied by the Cynch-Lok connector. Mr. Wolner’s letter goes on to state that “use of additional D-rings helps to ensure that connectors do not interfere with each other during transitioning.”
We also received email from David Wallis, author of the 1910.269 final rule, who recently retired from OSHA. Mr. Wallis responded to our guidance, citing the original intent of the standard that prohibited non-locking snaps in a single D-ring because of the tendency for non-locking snaps to disengage each other under use. Mr. Wallis wrote to add to and clarify our response in accordance with his intent in his wording of the standard. Per his letter, “’The response states: ‘Snaps are now specifically designed not to be able to be accidentally disengaged or to inadvertently open another snap in the same D-ring.’ Accidental disengagement is not the sole hazard address by the cited standard. The snaphooks and D ring must also be capable of safely stopping a fall with a second snaphook in the D ring. That said, to the extent the affected manufacturers approve the connection of two snaphooks in a single D ring, the standard permits such connections.”
The iP staff and editorial advisory board members thank readers and Mr. Wallis for taking the time to write and add to the quality and accuracy of our guidance, and we encourage readers to continue to do so.
Q: I have been reading with interest iP’s information regarding snaps and D-rings and the differing opinions involved. How do I find the information needed to keep our people safe and my company compliant?
A: There is no simple answer to your question. Some compliance issues are very simple while many others are more complex, especially with regard to emerging standards. We address some of the resources you can use in this issue’s “Train the Trainer 101” article and encourage you to read that.
Recent rule-making and interpretation have slightly changed OSHA’s historical position regarding the issue of compatible parts for snaphooks. For instance, in an October 23, 2012 letter of interpretation to Chris Medina (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28739), OSHA cites non-mandatory requirements of employers, stating that they must determine whether combinations of equipment from different manufacturers would meet the standard. OSHA further states that a competent person must make the decision.
In contrast, a similar rule in 29 CFR 1926.502(d)(15)(ii) requires a combination system be designed and applied under the supervision of a qualified person. A qualified person is normally defined by OSHA as someone with a recognized degree, certificate, or professional standing, or someone who possesses extensive knowledge, training and experience. Yet according to the mandatory appendix to the vehicle-mounted platform rule – not bucket trucks – the fall protection system must be designed by a qualified person, which is defined as someone with a recognized degree or professional certificate, and who has extensive knowledge and experience in the subject field and is capable of design, analysis, evaluation, and specifications in the subject work, project or product. What this means is that you must carefully read and seek guidance through reliable resources that can provide references for stated opinions. The good news is that the more time you spend conducting research, the easier it gets.
Q: We are looking into ladder training, and a question has come up about belting off to a ladder. As a best practice, we teach workers to belt off to the ladder when they cannot maintain three points of contact. For example, when a serviceman is connecting a weatherhead on a home using a 16-foot extension ladder, another employee must hold the ladder to secure it. In a June 2014 Q&A, an answer addressing transformer tops stated to either find a way to prevent falls from transformer tops or to work from a ladder. Does that mean you don’t need fall protection when you’re on a ladder?
A: The simple answer is no, you are not required to use fall protection when working from a portable ladder. That should not be a justification for using ladders so that you don’t have to use fall protection, or for not using fall protection when working from a ladder, but there is a very specific circumstance in which you should not use fall protection on a ladder and a very important reason why you should not use it.
If you read all of the OSHA Subpart M fall protection rules and the ladder safety rules in 1926 Subpart X, you will not find a requirement to safety-off to a ladder. You will find various references to securing a ladder before tying off to it, but you won’t find a requirement to secure fall protection to a ladder without securing the ladder first. If you can’t secure the ladder from falling because there is no way of doing so, you should not tie off to it. If you fall while tied off to an unsecured ladder, the ladder will fall with you and badly hurt you. The potential results of falling while tied to a ladder are usually much worse than falling from the ladder when you aren’t wearing fall protection. We are aware of a horrendous result in which a ladder fell while a worker was tied off to it using his body belt and safety strap. As he fell, his legs were thrust through between the rungs. When the ladder came to rest, the femur in both legs received compound open fractures. OSHA addressed portable ladders and fall protection in a November 28, 2007 letter of interpretation to Robert S. Beisel (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25906). In the letter, OSHA does not address why fall protection is not required by the standard, only when it is required.
Q: Are you aware of any OSHA letter of interpretation or other information regarding outer garments being worn over an employee’s fall protection harness?
A: We think this is a question that is answered by the general duty to provide a safe workplace. We are not aware of any rules that specify a method or considerations, such as how outerwear may affect fall protection. The rules require protection of employees from conditions that may injure them. If outerwear would compromise the protection or create some other hazard or performance issue with the fall protection, it would not meet the employer’s obligation to provide a safe workplace free of hazards.
We are also not aware of any questions to or interpretations from OSHA on this particular subject. OSHA would have a hard time with the question unless it was very specific as to type and scenario, so I think the answer would be along the lines of our response above.
We can tell you that having seen men hanging in full-body harnesses, if they were in a coat – even one with an opening in the back for a lanyard – the harness stretches high over the wearer’s back in a fall, and a coat on the outside will pull up the wearer’s arms and probably hurt them. Our guidance for full-body harnesses with winter outerwear is to wear the harnesses outside the clothing.
Do you have a question regarding best practices, work procedures or other utility safety-related topics? If so, please send your inquiries directly to kate@incident-prevention.com. Questions submitted are reviewed and answered by the iP editorial advisory board and other subject matter experts.