To begin this article, I want to offer a disclaimer. One of the reasons the “Train the Trainer 101” series was created is to examine the practical aspects of compliance as they relate to the utility industry. We do that by reading the statutes, looking at how OSHA interprets and enforces the rules, reviewing what the consensus standards state and then determining practical ways the employer can manage and comply with the rules. Sometimes I raise an eyebrow, but in working with the group of professionals who review every article published in Incident Prevention’s pages, we endeavor to ensure the advice given is not merely good but also compliant. With that said, in the following pages I am going to address some fall protection issues that iP has received many questions about in recent weeks. Several of them are driven by the latest OSHA final rule on walking and working surfaces, which contains some new language and expanded rules on fall protection.
Who is Responsible?
I get a lot of questions about fall protection that stem from a salesperson telling an employer they need to do a certain something in order to comply with OSHA. First, a nod to our partners in the industry: the vendors and manufacturers. They have done a great job meeting the needs of the employer by innovating, creating and often collaborating with the industry to get the tools we need into the field. Work with your vendors and manufacturer representatives, but be clear about your responsibilities in the relationship. Understand that there are no OSHA-approved devices for sale in any marketplace. OSHA does not approve equipment for manufacturers even though they may comment on a method of compliance if a written request is made by an employer. Even then, OSHA’s language to the employer often is something such as, “OSHA does not approve a particular device or piece of equipment, but the method you describe would meet the requirements of the standard.” And never forget that – no matter what the manufacturer’s rep says – you, as the employer, are ultimately responsible for how you comply with OSHA’s expectation. As I said, work with your vendors, but do your homework and educate yourself about the requirements. We aren’t just complying with standards – we’re protecting our employees and co-workers.
Common Misconceptions About Harnesses
I have often heard that you can’t arrest at the waist or chest. That is correct if you are truly arresting, which usually means the act of interrupting a fall from height by a personal fall arrest system attached to an anchorage limited to a distance of 6 feet. If you fall 6 feet, you must limit the fall arrest’s load, and the fall arrest’s load must be distributed across the body. That is why we use a full-body harness.
Let’s talk about the front chest loop and the waist fall arrest. The OSHA standard requires the arrest point to be in the middle of the wearer’s back. An exception is defined in 29 CFR 1910.140(c)(22): “Personal fall protection systems must be worn with the attachment point of the body harness located in the center of the employee's back near shoulder level. The attachment point may be located in the pre-sternal position if the free fall distance is limited to 2 feet (0.6 m) or less.” Many employers have not taken advantage of this exception that is especially helpful in tower climbing. The pre-sternal loop often is called the rope loop, following rappelling techniques that use the pre-sternal position to rope rig climbing safeties that are attached to vertical lifelines or safeties. But the front loop on a harness can be used in any fall protection application where the fall distance is less than 2 feet. Here is a practical reason why a front loop attachment would be useful, which, by the way, comes from experience; I tried both of the following scenarios to see what would happen. Imagine a worker climbing a spread-leg tower above the waist of the tower. If the climber is attached by 6-foot lanyards and hooks or to a safety rope by a rear-attached 6-foot lanyard and he falls, what happens? Imagine the dynamics. The lanyards will most likely be under his arms as he climbs. If that’s the case, as his lanyards tighten, his face will be pulled into the tower, and his body will spin around as the lanyard slides up his armpit. He will now be suspended with his back facing the tower, hanging out at an angle making self-recovery impossible. On the other hand, if the climber is attached to his anchorage with a short lanyard and falls, he is left hanging, facing the tower and likely within reach of self-recovery. You should try the system you use now to see what the result is after arrest. This is something missing from many rescue and emergency plans. Try the system to see if it does what you think it does. As I said, that is how I learned about back-attached arrest on a tower. It was painful, but it was better than falling.
Speaking of trying things out, you should have every worker who wears a harness hang in theirs for a little while. What they will learn is that a snug-fitting harness is very desirable if you actually have to use it. Over the years I have found that most harnesses being worn in the field are somewhat loose fitting or sagging when in use. In an arrest, the harness straps will tighten up quickly. If the harness is loose, the attachment ring on the wearer’s back will be somewhere at the back of his head. In some cases with some designs, a loose harness can come off if the fall arrest is from a sideways falling position, such as when being pitched from a bucket. In an arrest, loose harnesses do damage to the body that is not necessary. Worse, a worker can fall out of a loose harness in an arrest. Keep harnesses snug.
One more thing on this topic: I have heard from some sources that you cannot suspend from the pre-sternal loop. This is not true. You cannot arrest from that front loop as the forces create a whiplash that could injure the neck more easily than a sudden stop facing frontward. However, a rescue does not deliver those forces. In fact, if you try to remove a person from a bucket, you will find that the front “rescue” loop – as some manufacturers call it – is much faster to access and easier to use than the middle of the back. Again, try to perform a removal from a bucket using both front and back loops. You will find that an injured person can easily be maneuvered out of the bucket when rigged to the front rather than the back. In addition, a man rigged from the back comes down face first; front rigging brings the victim down face up.
Arresting at the Waist
Forty years ago those of us who used a restraint in a bucket used a waist belt. OSHA soon prohibited arrest forces at the waist and everyone went to a full-body harness. Everyone, that is, except some employers who understood the rules and requirements. A bucket worker can still wear a belt if the belt, rigged as a restraint system, prevents a fall. This system is also known as a travel-restraint system. A travel-restraint system typically requires the use of a 2-foot-long lanyard or a lanyard of a length that the employer can demonstrate will not permit the worker to travel or fall out of the bucket. I describe it that way for the purposes of planning the travel-restraint system. It may be possible to use a lanyard longer than 2 feet to allow greater freedom of movement for the worker. However, if that length would allow the worker to leave the bucket, he may have more arrest forces imposed than allowed. In addition, if thrown from the bucket, the worker may find himself in a position from which he cannot recover without assistance, adding the risk of injury. Generally the fall-restraint criteria uses a fall length of no more than 2 feet, such as with portable pole-climbing systems. The bucket system, for the reasons previously described, ideally prevents the worker from leaving the bucket at all. That works pretty well for tree workers, but not so much for lineworkers. Most lineworkers need more than 6 feet of movement to work from the bucket, so they prefer the 6-foot lanyard, mandating they wear a full harness.
The wood-pole climbing systems in use today have their own peculiarities. These systems, now called portable anchorage fall protection systems, are fall restraint and anchorage built into one portable system. Not everyone uses these systems as designed, and on occasion improper use could violate the OSHA criteria for a fall prevention system. If a climber uses a classic free-climb step distance, he may be hoisting his arrest system far past the distance allowed by the design of the equipment. Stepping up with the climber’s waist above the device means that a fall would be longer than 2 feet before the device stopped the fall, if the climber were to fall while the device was at the lowest position. If that fall distance is more than 2 feet, it violates the 2-foot distance allowed by an arrest at the waist. As OSHA states in the note to rule 1910.269(g)(2)(iv)(B), “Fall protection equipment rigged to arrest falls is considered a fall arrest system and must meet the applicable requirements for the design and use of those systems. Fall protection equipment rigged for work positioning is considered work-positioning equipment and must meet the applicable requirements for the design and use of that equipment.” Not the least to consider is that a portable wood-pole fall arrest that allows a climber to fall more than 2 feet not only violates the arrest criteria of the OSHA standard, but the forces imposed on the device may exceed the design criteria built into the device.
Improperly Applied Exceptions
The second part of rule 1910.269(g)(2)(iv)(C)(3) has an exception to fall protection for climbers. The exception states that after April 1, 2015, “each qualified employee climbing or changing location on poles, towers, or similar structures must use fall protection equipment unless the employer can demonstrate that climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.”
If you are using this exception to let your workers climb transmission without fall protection, you should probably stop. You won’t get away with it for a couple reasons. One is that there are now devices available for almost any climb scenario you can come up with. Yes, they take time to employ, but there is nothing in the OSHA rules that uses “time to comply” as an exception for fall protection.
One of the provisions of the fall protection standard is the criteria for anchorages for fall arrest. Shortly after the final rule was published, Edison Electric Institute hosted a webinar with David Wallis, who is the author of the final rule and at the time was OSHA’s director of engineering safety. A webinar participant asked if a lack of rated anchorages permitted the exception to fall protection use on towers. Mr. Wallis answered quite simply: A lack of rated anchorages does not permit climbing without fall protection. That’s to the point, but that doesn’t mean tie off to anything. Several sources have performed structure analysis, but we are most familiar with the analysis – provided by Salt River Project, Western Area Power Administration and Bonneville Power Administration – that shows there are some members on a tower bridge that could cause significant structural damage and perhaps even partial failure of the tower if a full-weight fall arrest was placed against it. Other studies by these groups showed that step-bolts could not be relied on as fall arrest points either when tested at arrest forces. The lesson is that, yes, there are appropriate ways to prevent falls from towers, but not all systems are created equal. The employer is going to have to put time, training and treasure into finding the right system for the workforce.
Power Transformer Tops
Over the years we’ve given lots of advice on this problem, often on how to employ travel-limiting devices. The issue is the anchorage. Many say the anchorage has to be engineered or rated. Well-engineered anchorages or rated anchorages are fine, but OSHA has no language or criteria for the anchorage on a travel-restricting system other than some suggestions by way of interpretations.
In a November 1995 letter to Envirocon Inc. regarding anchorages for travel-limiting systems (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21999), OSHA offered this advice: “OSHA has no specific standards for restraint systems, however, we suggest that as a minimum, fall restraint systems should have the capacity to withstand at least twice the maximum expected force that is needed to restrain the person from exposure to the fall hazard.” Read the guidance carefully. OSHA takes great care to precisely word their guidance, knowing it shapes workplace safety. This guidance has not changed and OSHA still has not produced any criteria for restraint systems. The key is for the employer to understand the intent, which is to prevent a fall. Restraint systems keep the worker from going over the edge. If they don’t go over, there is no fall to arrest. Use a system and tie-off that do the job required. The substation transformer is a good example. Some employers buy engineered stanchions that cost thousands of dollars. Another gets the same result by screwing a $4 eye nut on an exposed three-quarter bolt and tying off his restraint ropes to it. And as we have done successfully for more than 100 years, you can use ropes, beckets and knots to set the length of your restraint ropes. It does require that you plan and train on proper configuration and installation, but the result is simplicity and compliance in an economical package.
As a final example, let’s go back to Mr. Wallis’ comment from the EEI webinar. I had a crew dismantling elevated capacitor banks in a substation. They were over 20 feet off the ground under an energized string bus. While discussing the work and safety plan, I asked what the crew was doing for fall protection. They had none planned because there was nothing to tie off to. I disagreed. We supplied short, lightweight retractables that happened to be Nano-Loks and slings. I agreed with them that those are not the best if we had other choices, but to tie them off to frames or brackets. Use the best choices, and use them when you head to those open sides. The crew members agreed somewhat grudgingly. A few days later I received one of my favorite photos from the crew. Our foreman, while heading to a visible spot to give signals to a crane, was walking to the edge to look around a control house on the platform. He tied off to a steel frame at his feet and stepped to the edge. He didn’t realize the control house overlapped the edge of the platform by a foot and, looking into the morning sun, he walked right off the edge. Even though his retractable was at his feet, it caught him safely and prevented a 20-foot fall to rails and foundations. In fact, it didn’t even deploy the softener on the web strap. His crew couldn’t resist the photo opportunity. He became one of our best fall protection advocates, and I keep that photo as another example of how consistency and out-of-the-box thinking for solutions make a difference. Sure, attaching at the feet is not ideal, nor is untested strength on an anchorage, but the alternative hurts – and sometimes it hurts a lot.