This article addresses changes that are affecting fall protection equipment and training used in the construction industry. New and revised consensus standards provide guidance for the construction industry.
ANSI A10.32-2004 and ANSI Z359-2007
The current U.S. national consensus standard for fall protection in the construction industry is the American National Standards Institute (ANSI) A10.32-2004, "Fall Protection Systems for Construction and Demolition Operations." This standard replaced ANSI A10.14, which had been virtually unchanged since 1975.
ANSI A10.32-2004 moved fall protection product design and test requirements closer to those of the ANSI Z359.1 general industry standard. But, previously, only ANSI A10.32 addressed requirements for work positioning and travel restraint components. However, on November 24, 2007, the newly revised ANSI Z359 standard took effect as a new family of fall protection requirements, adding work positioning and travel restraint products, as well as rescue systems, to ANSI Z359.
The accredited standards development organization, the American Society of Safety Engineers (ASSE), administers both A10.32 and Z359 committees, who now work together more closely than ever. The A10.32 committee met in January 2008 and resolved to incorporate by reference the complete suite of ANSI Z359 product standards into ANSI A10.32, thereby eliminating duplicate fall protection equipment standards for general industry and construction.
The next revision of ANSI A10.32, likely to take effect in late 2008 or early 2009, will include new construction industry guidelines on the selection and use of fall protection components for specific jobs, fall hazard assessment and training construction workers to work safely at heights.
New Product Standards
So, how will these changes affect the products and work practices in construction? Let's examine and compare changes in fall protection PPE in the new ANSI Z359 standards.
Fall Arrest Systems, Subsystems and Components
The most significant change in product requirements is related to increases in the strength of the gate mechanisms for snaphooks and carabiners.
The change affects all snaphooks and carabiners used as connectors in fall arrest, work positioning, travel restraint and rescue systems. The increase in gate strength is intended to provide higher levels of protection from forced roll-out, especially in connectors used for attachment directly to an anchor structure. Probably the most important improvement is in the strength of large throat-opening snaphooks used in work positioning, climbing and rebar work.
The new ANSI Z359.1 standard addresses the traditional trapezoid-shaped carabiner without a captive eye to restrain the connecting rope or strap. When used to connect elements of a fall protection system, it's possible to exert load directly against the gate mechanism from the direction inside the gate, forcing the gate outward. Carabiners of this type are required to resist a static load of 3,600 pounds of force in the worst-case loading condition, from the inside of the gate pressing outward. Products meeting this criterion have significantly greater resistance to failure when loads are applied against the inside of the gate.
Another expected benefit of the increased gate strength is greater freedom in making compatible connections. The new high-tensile gates will better resist loads generated against the gate mechanism when connecting the snaphook or carabiner to a ring, loop, eye-bolt or other connecting element. Concerns over compatible connections between components from different manufacturers will also be addressed by the stronger gates. For example, the lanyard of manufacturer A is more likely to be compatible with the connecting d-ring in the harness or anchorage connector from manufacturer B.
Many people believe that accidental disengagement (a.k.a. "roll-out" or "burst-out") of the fall arrest connector poses a significant hazard to workers at height. Improved compatibility should make it easier for workers to make proper connections and reduce chances of accidental disengagement. The rationale for the 3,600-pound tensile strength is based on the maximum fall arrest loads permitted in any fall protection system of 1,800 pounds, as mandated by OSHA regulations. The new standard provides a 2:1 factor of safety for connectors in what has been the weakest point in the personal fall arrest, work positioning and travel restraint system.
New Requirements for Twin-Leg Lanyards
A second area affected by new standards is the testing and instructions for twin-leg fall arrest lanyards. Also called "y-lanyards," they can be potentially misused so as to generate very high loads at the point of connection between the two legs of the lanyard. To address concerns over possible failure at this point, ANSI Z359.1 requires that all lanyards of this type be tested to resist a static load of 5,000 pounds across the connection of the two lanyard legs.
To further reduce misuse of the twin-leg lanyard, ANSI Z359.1 calls for additional cautions in the user instructions provided with each product:
- Connect only the center snaphook to the fall arrest attachment element.
- Do not attach the leg of the lanyard which is not in use to the harness except to attachment points specifically designated by the manufacturer for this purpose.
- Do not rig the lanyard to create more than a six-foot free fall.
- Do not allow the legs of the lanyard to pass under the arms, between the legs or around the neck.
Frontal Attachment Element on Full Body Harnesses
The third significant change in the new ANSI Z359.1 standard concerns the use of frontal attachment elements on full-body harnesses. The proposed new standard includes design and test requirements for a single attachment element, d-ring or loop, located on the front of the harness about sternum level. The frontal attachment level is intended to be used only for limited fall arrest, in which the maximum free-fall distance is two feet and the maximum fall arrest force is controlled by the fall arrest system to 900 pounds or less. Harness frontal attachments must meet a static and dynamic strength test that ensures that the strength of the harness possesses a substantial margin of safety over the anticipated forces in a fall.
The frontal attachment element will find application in two-line rope access systems, in ladder- climbing safety systems, and possibly in roofing work where a rope-grab fall arrester is connected to the front of the harness during work on steeply pitched roofs.
Positioning and Travel Restraint
Work positioning and travel restraint activities in construction use a range of harnesses and lanyards that are described in the current ANSI A10.32. The new ANSI Z359.3 standard, "Safety Requirements for Positioning and Travel Restraint Systems," was published as part of the Z359 Fall Protection Code. The requirements in the two standards are very similar, although the Z359.3 standard has increased the strength requirements. It includes fall-factor-two dynamic drop tests for positioning lanyards, and attachment elements on full-body harnesses for the hip d-rings. The design and test criteria in ANSI Z359.3 are consistent with the requirements of the other Z359 sections, and workers benefit from the harmony of following an integrated set of product standards. The A10.32 committee believes adoption of the Z359.3 product standard for work positioning and travel restraint systems provides the highest level of protection for construction workers in these work activities.
Rescue Systems
Rescuing a worker after a fall involves specialized equipment for accessing and moving the fallen person to a safe working level. OSHA construction safety regulations and the current ANSI A10.32 standard require that employers have a rescue plan and the means at hand to implement it in the event of a fall. Previously, standards did not address the specifications for rescue equipment.
However, the new ANSI Z359.4 industry standard covers "Safety Requirements for Assisted Rescue and Self-Rescue Systems, Subsystems and Components." It comprises product design and test requirements for the following components of rescue systems:
- Connectors
- Harnesses
- Lanyards
- Anchorage Connectors
- Hoists
- Descent Control Devices
- Rope Block and Tackle Systems
- Self-Retracting Lanyards with Emergency Rescue Capability
These equipment components are as adaptable for construction rescue applications as they are for general industry. As stated earlier, the ANSI A10.32 committee intends to incorporate this product standard into the A10.32 standard at the next scheduled revision in 2008. Construction industry personnel should get a copy of the Z359.4-2007 standard (after its scheduled publishing in June 2008). This standard is an excellent source of information on rescue equipment and can be used as a purchasing specification for future procurement of it.
Arc-Resistant Harnesses and Lanyards
In 2005, the American Society for Testing and Materials (ASTM) issued ASTM F887-05, concerning "Personal Climbing Equipment." Although originally created for the utility industry, this standard is definitely of interest to construction safety professionals. It contains important requirements for fall protection harnesses and shock-absorbing lanyards used near high-voltage electrical sources.
The hazard of electric arc flash, with the potential to damage fall protection equipment by high heat, is a hazard also encountered in construction. Examples include construction of power supplies, electrical switching gear, electrical vaults and other cases where workers are exposed to the hazard of high-voltage electrical discharge as well as the hazard of a fall. The ASTM F887-05 standard includes testing of harnesses and lanyards by exposure to electric arc flash, followed by dynamic drop-testing to the requirements of ANSI Z359.1-1992(R1999). Equipment certified to this standard will continue to function when subjected to electric arc flash exposure of 40 cal/cm2 and will not ignite or melt.
New guidelines for a managed fall protection program
Another part of the new ANSI Z359 standard serves as a guideline to employers for creating a managed fall protection program. (The construction industry currently follows guidance in this area in the non-mandatory section of 29 CFR Part 1926 Subpart M.) The new ANSI Z359.2 standard, "Minimum Requirements for a Managed Fall Protection Program," goes into greater detail than the OSHA rule, including:
- Definitions
- Policies, Duties and Training
- Fall Protection Procedures
- Eliminating and Controlling Fall Hazards
- Rescue Procedures
- Incident Investigations
- Evaluating Program Effectiveness
The Z359.2 program standard, developed for use by general industry, also provides much useful information to safety professionals in construction. Still, it does not refer to some topics that are paramount to the construction industry, for example, the need to manage and control the fall protection programs of subcontractors.
The new program also points the way for the ANSI A10.32 Fall Protection Committee to develop a similar document specifically tailored to construction industry needs, and it is committed to doing so in 2009. Expect similar emphasis on job planning, formal hazard assessment techniques, employee training, and rescue.
Training upgrades for the construction industry
The current ANSI A10.32-2004 standard addresses the need for employee training in section 6.1, including, "...lectures, demonstrations and hands-on experience performing tasks [described in this section]." The days of informal toolbox safety training meetings and fifteen-minute training videos have passed, and employers increasingly recognize the need to train and assess their work force for competence to work at heights. Over the last decade, construction workers have also come to accept the need for personal protective equipment when working at heights above 6 feet. As the use of fall protection equipment has increased, and as the variety and complexity of fall protection products has grown, the need for sophisticated training has also increased.
The ANSI A10.32 committee will address the need for higher levels of competence in fall protection training through new training standards for construction over the next year. The construction industry poses special challenges to contractors and other employers who must contend with a highly mobile and transient workforce, constantly changing hazardous environments, time constraints, a multi-tiered management system and participants with varying levels of responsibility.
The ANSI A10.32 committee intends revisions to existing training requirements to strengthen and expand training requirements to include:
- Minimum qualifications for fall protection trainers
- Tie-in between training and hazard evaluation and abatement procedures
- Measures of competence and assessment of learning
- Documentation demonstrating actual proficiency
The trend toward increased worker competency for work at heights will mean greater resources allocated to training workers and measuring their proficiency in use of fall protection for working safely around fall hazards. The conundrum faced by standards writers and employers alike is how to do more than simply provide "training classes," and instead hold workers accountable for mastering certain life-critical safety skills. New training guidelines should create greater understanding and awareness of fall hazards among workers whose primary job functions are building trades. Improved training regimes will:
- Guide workers through acquiring skills and judgment
- Require demonstrated proficiency in meeting the training goals
- Promote individual responsibility for safe work practices
- Continually adjust and update training to account for changes in work, hazards, equipment, and other safety-related factors
Applications issues in construction
The construction industry encompasses infinite numbers of activities and potential fall hazards, so it is impossible to match all the equipment and techniques needed for each construction hazard. Nevertheless, the ANSI A10.32 committee will soon begin to assemble application guidelines for certain critical areas in construction associated with high risk for injury or death from falls. These guidelines will give employers a set of best-industry practices for the selection and use of fall protection equipment in each application, starting with these applications:
- Scaffold work, including erecting and dismantling
- Protection from falls out of aerial lift devices
- Leading edge work
- Confined spaces in construction
- Working on concrete forms
- Fall protection for heavy workers
- Horizontal lifelines in construction
This list will be refined after input from the larger construction community. If you have suggestions for additional topics, or would like to serve on the A10.32 working groups, please contact the ANSI A10.32 committee at ASSE (www.asse.org).
NIOSH research update
The Division of Safety Research at the National Institute of Occupational Health (NIOSH) is undertaking new research in fall protection for scaffold workers. The research team will be headed by Dr. Christopher Pan in Morgantown, WV. Dr. Pan is working with the ANSI A10.32 committee and fall protection equipment manufacturers to develop realistic fall hazard scenarios. These fall hazards will be represented in virtual space using advanced 3D holographic imaging to test the behavior and reflexes of workers in a scaffold environment (without placing the subjects at risk of falling). Also included in the research project will be dynamic load testing. Drop tests will be conducted to evaluate scaffold stability and to identify locations for possible attachment of fall arrest anchors on scaffold structures.
Dr. Pan hopes to proceed with his scaffold safety project this year, with preliminary findings completed in 2009.
Significant advances in national consensus standards are leading to increased strength and performance abilities of fall protection equipment and adding rescue equipment specifications for the construction industry.
Safety professionals can expect increasing requirements for work planning that emphasizes fall hazard evaluation and abatement measures for new construction projects. Trends also indicate greater attention to training personnel in all aspects of fall protection. New tools for fall protection program management and training are being developed by the A10.32 committee and should be available within a year or so.
BIBLIOGRAPHY
US Federal OSHA:
- 29 CFR Part 1926.502 Subpart M
- 29 CFR Part 1910.66 Appendix C
US National Consensus Standards:
- ANSI A10.32-2004, "Fall Protection Systems for Construction and Demolition Operations."
- ANSI Z490.1-2001, "Criteria for Accepted Practices in Safety, Health and Environmental Training"
- ANSI Z359.1-2007, "Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components"
- ANSI Z359.2-2007, "Minimum Requirements for a Managed Fall Protection Program"
- ANSI Z359.3-2007, "Safety Requirements for Positioning and Travel Restraint Systems"
- ANSI Z359.4-2007, "Safety Requirements for Assisted-Rescue and Self-Rescue Systems, Subsystems and Components"
- ASTM F887-05, "Personal Climbing Equipment."
Construction Business Owner, June 2008