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When you are using a fall protection system as described below what is the maximum load imposed on the anchor point for the system? Anchor point SRL with maximum arrest force at 900lb Safety harness supporting person 255lb The maximum arrest distance is 2ft before coming to a stop. As a guide, when using fall protection systems the loading on the anchor point should be equivalent to the maximum arrest force imposed on the person. Is this the case? I hope you can give me some guidance on these points.
Point 2 is 900 lbs (if 900 lbf force is imposed on the anchorage). For a Rule of Thumb calculate in energy units: Wt x free fall distance = Force x deceleration distance. So Weight 255 lbs x two foot free fall = Force x one foot deceleration (typical) so force is 510 lbf. If deceleration distance is longer than the free fall the static load is what the anchorage eventually encounters. This type calculation works best for lanyards rather than the more complex SRL absorbers. EFSS has a software program available on this web site under Publications that has great flexibility for the type of problem you are posing.
Can you please clarify the following regarding personal fall arrest equipment anchorages in CFR1926.502 d (15) that indicates that anchorage will be “capable of supporting at least 5000lbs per employee attached”? Also, can two employees attach their personal fall arrest equipment to a single anchorage if it is capable of supporting 10,000lbs? If not, what then would be required for two persons?
Yes, you theoretically can do that if you are using lanyards. You then have the problem of compatibility of two snaphooks in an “eyebolt” that might lead to trouble (check Z359.1 two hooks in a D-ring are problematic). Two attachments to the same angle iron is a questionable situation. There are some tripods capable of supporting 10,000 simulating a rescuer additionally. Two, three or four attachments to a line are possible in an engineered horizontal line; the 2:1 factor is critical for cables. Everything is specific to an application. For a 100% application including moving, a logic appears upon analysis because the equipment has to be compatible with each anchorage system. This is why a Qualified Person (preferably a structural P.E.) who is skilled in fall protection engineering design is an invaluable addition to a Competent Person non-engineering group. Without engineering, the 10,000 lbs joint anchorage is the guide to follow for two persons. P.S. Perhaps we can help you plan. Send a description of the application with specific questions. Check Chapter 7 of Introduction to Fall Protection, 3rd Edition for further information.
I am looking for some information or direction on quality tie off in cooling towers. It is difficult to maintain the 5,000 lb anchorage policy. Would you be able to suggest or direct me on this matter?
Yes, the key is not 5,000 lbs but the OSHA 2:1 strength factor. The possibility of finding 2xMAF static strength in wood and plastic structures is a lot easier than 5,000 lbs using an engineered system. We can do this kind of work based on erection, dismantling or maintenance procedures that go hand in hand with sound fall protection.
I am a structural engineer in Portland, Oregon. I have been asked to check an embedded unistrut P3200 in concrete for adequacy to support loads from attaching fall arrest systems. I have been told that this needs to be designed for 5,000 lbs of vertical load. I am trying to verify if the 5000 lbs requirement is correct, whether it is allowable stress, level load or strength level (ultimate) load, and where (what spec.) it comes from.
OSHA goes by ultimate load; 5,000 lbs per person attached, or 3,000 lbs for SRL and 2:1 factor for documented engineered systems. You may wish to treat as allowable or in some cases as yield when values are known. The importance is not to pile safety upon safety thereby increasing the cost. The trick is to limit the force going into the structure. Single anchors can be very low based on MAF’s, HLL slightly more. You do that by specifying the fall systems and conditions for fall loading. Drawings should show people and allowed methods of use including multiples of people and distances of fall and MAF consideration from mfrs devices. Much of this is in Introduction to Fall Protection, 3rd Edition Chapter 7. (see Publications on this web site).
I have taken over a Safety Coordinator role in our manufacturing facility. We have been searching for the OSHA regulations regarding tying off when in a man basket or powered platforms. We have scoured 1910.66 and 1926.500-503 and we cannot find anything. If you could give us some ideas as to where we may look to find this standard, we would really appreciate your help!
You have chosen a tough subject. Remember that when we don’t find anything in the Federal Register (or ANSI) that we (the employers) must go to the 5(a)(1) part of the statute and look to see if there is a hazard and if so how to avoid, prevent or control through fall arrest /restraint. So sometimes standards can help and sometimes they cannot. When leading industry people disagree then the standards cannot get resolved around a hazard. The bucket truck is a prime example. Now I assume you have looked at 1926.453 and 1910.67. To answer your question, the anchorage point for a lift should be five feet from the floor (DOT rules for height of a vehicle will dictate whether that should be retractable). The connecting device should be a small retractable lanyard. Finally the harness is full body without a waist belt unless separately worn. Connection is 100% of the time as soon as entering the lift by an acceptable means. The enemies are potholes, collisions while moving and over-reaching while working. Plastic buckets need a slightly different approach with the bracket for the device being on the boom. We have to recognize that while a belt and short lanyard may be sufficient for limiting free falls to two feet that this system does not take care of a fall; thus a harness is required. Scissor lifts required two systems for expected reach-beyond-the-elbow applications. If any questions arise out of this, please come back with more questions. I understand that others may not agree with me but I believe that this view will prevail for the safety of our workers and the first step is to make a decision for safety when the hazard is recognized. Check Introduction to Fall Protection, 3rd Edition for sketches showing the aerial lift anchorages in place at Publications of this web site.
An engineered and approved fall arrest system including an anchorage point is being designed. A self-retracting lifeline will be attached directly to the anchorage point and the snaphook will be attached directly to the D-ring on the harness. What static load must the anchorage point be designed to support?
This is a favorite issue of mine and one the manufacturers may not have gotten around to thinking through. Their standard 5000 lbs answer is too conservative. The answer is 3000 lbs provided the free fall distance is 2 ft or less (by design) and that means installing at least five feet high (D-ring height) or if lower than 5 ft then the device sees a 7 ft free fall in which case 5,000 lbs may not be enough and the line strength of the SRL must exceed 5000 lbs! 1926.502(d)(13). Reason for 3000 lbs? Simple. It is the minimum break strength of the line assembly per OSHA 1926.502(d)(12). Just keep the devices high!!
I am looking for information on whether or not it is permissible to use a mobile crane hook as a tie off point for fall protection. We have an activity that requires personnel to climb on top of flatbed trucks to tarp the load. There is no nearby building or structure that can be used. We have a large capacity Link crane that could be parked near the truck with the boom/hook over the truck. Are there any regulations that cover this? Are there any restrictions on the crane while this is happening?
Thanks for your question regarding mobile crane anchors that should be of interest to many people. This question will have many answers from many people, but my answer is “why not?”!! In a field situation there are not many options until the trucks have their own system many years from now. As Bill Donovan of OSHA Chicago Area Office would say “it won’t be pretty” but it would be acceptable (referencing boson’s chair work from the hook and a lifeline to the boom, NATE, Dallas, TX 2 22 01). The issue is protection of employees, not crane manufacturer’s interests, provided the answer has been carefully documented. Here is what I suggest for an independent lifeline from the crane to work unloading a flatbed in the field greater than six feet (construction), or 4 ft (general industry): Position the crane appropriately and set up for the overhead anchorage. Do not use the hook or ball or main cable because there is too much debate over the years plus regulation, unless meeting 1926.550(g). Use a place on the boom or jib that has the static capacity for anchor for fall arrest (2 x MAF per fall equipment manufacturer’s certification) such as a bracket or temporary web anchorage connector. Use a SRL of appropriate length with a tag line for access. Lock the crane out. How high the attachment is depends on the consequences of swing fall from a remote part of the flatbed so position the anchor centrally over the area of movement as high as reasonably possible. Then you can go to work under competent observation. For an engineered solution, we could help you with this important solution that could apply nationwide with careful application. Please call to discuss what items we need from you if you would like to consider our services.
What is a typical proof test for an anchorage point for a vertical lanyard? Is there an accepted proof test factor that is applied or is it acceptable to load test the point just up to the design load or the 5000 lbs (if you do not engineer the system)?
These are your choices for proof load: 5000 lbs non-engineered is probably easiest to rationalize 3600 lbs OSHA regulations, reference D-ring/snaphook Max arrest force equivalent for engineered systems Assumption Proof load is approx. one half of min. break strength – general rule Note: OSHA went 67% of 5000 lbs min break for proof load.
On page 206 of “Introduction to Fall Protection, 3rd Edition”, there is the following statement: “To prevent specific anchorage points from being used for attaching hoists and powered come-alongs, they should be painted yellow or orange and clearly tagged with their usage rating…” My question is why is it necessary to prevent the anchorage points from being used? I ask because I know that with the capacity clearly marked, I will soon be asked to allow a hoist to be attached to the anchorage to lift out a piece of equipment. Usually these anchorages are located in areas near to the equipment that needs the most frequent maintenance and service. The argument will likely proceed on the basis that the tag says it’s good for 5000 pounds, so why can’t I attach this 1 ton hoist? As long as the pull is in the appropriate direction, do I have any other good reasons to decline their requests?
Thanks for your excellent question! I supose we should have said “reasonably prevent” to start out. Only you and your collegues will know to what extent you should paint or mark a special attachment. If you do not indicate a specific rating directly on the anchorage point you can require the potential user to contact the person best able to deal with the situation. You might also consider attaching to the anchorage point a non-removable shackle for use with fall protection equipment only. I suggest you discuss the issue with your egronomics partners. We would like to hear more about what you think about the whole of page 206 – We would like to know your thoughts on how your business works to distinguish engineered safety items from production items.
California regulation presently prohibits anchoring of PFAS to guardrails (8CCR 1670(b)(17)). The staff of the Cal-OSHA standards board is considering amendments to permit personal fall arrest systems to be anchored to guardrails. What are your thoughts on the use of guardrails for anchorage?
Guardrails (railings) are fall prevention systems for a standing worker(s) on a platform that can be considered for fall arrest anchors when working or accessing beyond the guardrail Fall Arrest Anchors from Guardrails: My opinion is that anchor points for fall arrest systems using guardrails are OK if they are approved by a Qualified Person who is a Registered Structural Engineer skilled in the field of fall protection engineering. The responsibility would be for that person to have active control over the use of the anchor points in its particular application including numbers of persons attached and equipment used. The need for a structural engineer is particularly pertenent in the area of use of cables such as perimeter cables used as guardrails where no data is available from cable manufacturers on dynamic sag, dynamic end-force and pre-tension (less than 3 inches at 200 lbs). Removable guardrails would be a concern if the force is up and over an obstruction unless the engineer could recognize a special foreseeable problem. Scaffolding railings would be another consideration relative to their purpose and design. Requirements: One concern is height of anchors – all anchor points must be overhead as a general rule for fall arrest such that the effective impact force on the railing would be down and outwards. Another is abrasion over corners or edges surrounding the railing and compatible anchoring to the railing itself. Another, assuming the first question is answered, is what height to use assuming the base is strongest and the end of a railing at its top point is weakest at least for bending. Additionally the use as a single anchor point as opposed to a horizontal lifeline is an engineering consideration. There are other specific issues to consider and finally because this would be an exception to several existing rules including OSHA 1926.502(d)(23), what form of labeling is appropriate to the application for an approved section of guardrail. Restraint and work Positioning Systems: As restraint systems get better developed as equipment rigged such that a fall hazard cannot be reached and beyond that into a new category of fall equipment where the total fall distance is limited to 2 feet, this new class of fall equipment can emerge that serves people at low heights and where lower anchor points like guardrails would be ideal. However force levels would have to be set for this equipment (which is not the intention of the forthcoming Z359.2 standard). If leaning was a common feature of the usage then consideration as a work positioning system would call for a secondary back-up fall system.
Background info: We have a rappel tower that we need to put operational in the next coming months. The anchor points in the tower consist of (3) three stainless steel U-bolts that are one inch to one & a half inch thick in diameter that are bolted to the floor of the rappelling tower. Our Navy Construction Battalion did the work and they told us that the anchor points are capable of sustaining 1 – 2 rappellers per anchor point but we don’t have anything in writing. The command intends to start training our Marines by next month before they deploy and go to the Middle East. However, before we put it operational, we have to ensure that all safety requirements are in-place. The safety checklist requires the following be conducted before we put the rappel tower operational: Rope anchor points must be load tested AND certified to 5,000 lbs each. Reference: ANSI Z359.1 (1992) & 29 CFR 1910.66 part(I)(c)(10) of Appendix C. All fast rope anchor points shall be tested to 5,000 pounds each, per person on the rope (e.g. 2 ropers on the rope at the same time requires testing to 10,000 lbs.) Question: Could you please define or explain the difference between load testing, testing, and certifying the anchor points? And can we do one without the other? In other works, if we get a certification on the anchor points, do we still need to conduct the load testing?
These could mean the same. Certifying more likely means a representation from a third party to the user that anchor strength meets a certain standard. Z359.1 standard is 3600 pounds minimum static strength for a single point anchor. There usually is a time period that the certification is stated to be valid, during which load testing should not be required depending on application. That sets the deadline for when load testing will become necessary. You can set the deadline by determining the chances of deterioration of the anchor point over about 2-3 years if the application is outdoors and maybe 5-10 years if it is indoors. Multiple uses of the anchor point should be assessed carefully, for example rigging for hoisting loads, long free falls or abrupt fall arrests that can produce forces over 1800 lbf. All fall arrest anchors should be labeled for proper use and referred to an engineering drawing. Forces from the Z359.1 fall arrest tests may be 900 lbf or 1800 lbf depending on the components.
Background info: We have a rappel tower that we need to put operational in the next coming months. The anchor points in the tower consist of (3) three stainless steel U-bolts that are one inch to one & a half inch thick in diameter that are bolted to the floor of the rappelling tower. Our Navy Construction Battalion did the work and they told us that the anchor points are capable of sustaining 1 – 2 rappellers per anchor point but we don’t have anything in writing. The command intends to start training our Marines by next month before they deploy and go to the Middle East. However, before we put it operational, we have to ensure that all safety requirements are in-place. The safety checklist requires the following be conducted before we put the rappel tower operational: Rope anchor points must be load tested AND certified to 5,000 lbs each. Reference: ANSI Z359.1 (1992) & 29 CFR 1910.66 part (I)(c)(10) of Appendix C. All fast rope anchor points shall be tested to 5,000 pounds each, per person on the rope (e.g. 2 ropers on the rope at the same time requires testing to 10,000 lbs. each). Questions: How do you do the certification and who does the certification? Does the certifier require some kind of training?
Often a structural engineer can do this if his/her firm has skills in personal fall protection and a good understanding of the Z359.1 standard. The structural engineer should preferably have attended a Qualified Person training course and successfully passed the course test.
I have a couple of questions regarding permanent anchorage points for window washing work. 1.How often must these point be inspected? 2.What is included in the inspection, is it just a visual and was type of training does someone require to perform such an inspection?
The answer may depend on in which state the building is located. Generally, it must remain strong enough for its intended purpose. What standards does your company currently have for PFAS? What inspection intervals are used, specifically in a marine environment annual inspections are best and the specs must be changed to an acceptable stainless steel. For roof installation with set back from edge or parapet we propose annually to inspect and then test one anchor against the next and certify strength to a proof load which is a percentage of ultimate rating. For window installation where window opens I may refer you to a colleague for this.
From: John Whitty [mailto:jwhitty@itac-net.com] Sent: Friday, February 05, 2010 9:44 PM To: Semoedi, Alfonds Cc: JeffS47@aol.com; Kromopawiro, Harold T.; Nigel@fallsafety.com; Bruce Simms Subject: RE: Train The Trainer question Alfonds, Good to hear from you& I will attempt to answer your question: First and foremost the anchor should be selected and designed properly the right anchorage for the work method & designed with a minimum of 2 to 1 safety factor against peak dynamic loading peak dynamic loading could vary by anchorage purpose, i.e., restraint, fall arrest, work positioning or rescue. See section 2.6 of the attached D plate user instruction for details the basis of these loads are as stipulated in the latest ANSI Z359 Fall Protection Code. The anchor should pass all the criterion of anchor point planning as shown in the Introduction to Fall Protection you should have a copy of this book weve discussed this before in previous training. The Hilti adhesive anchors would need to be installed in strict conformance with the manufacturers instructions no ifs ands or buts here. See attached portion of this anchorage systems technical specification. I would recommend at least 24 hours of cure time even though the info attached indicates much less. Pay particular attention to hole size, edge distances, spacing of anchors, blowing out of holes, etc. Install the anchorage per the installation instructions outlined in section 3.3 of the user instruction for the D plate anchor this section also gives some pointers of things to look for as well during the installation process. It is not absolutely necessary to pull test the anchors however if its a must we recommend a static proof load test 100% of proof load, i.e., loading from restraint, fall arrest, work positioning or rescue. For example, in the case of fall arrest the load applied would be the maximum anticipated dynamic force in the system 1,800 pounds for a single worker. This load should be applied in the weakest direction of the anchorage. In this case that would be either straight up (because of the spacing of the anchor bolts) or along the minor axis of the anchor D ring. Apply the load in a static fashion utilizing a dynamometer, come along and a fixed end connection combination. Hold the static loading at a constant level for a period of 1-2 minutes. There should be no permanent deformation in any component in the system. Inspect the anchorage after the test in accordance with the user instructions as well as on a recurring period interval (prior to each use and on an annual basis at a minimum) see section 5.0 of the D plate user instructions. Be certain to label, tag and fill out the inspection log. This is a good start I hope it helps. We can go in further detail if needed or we can address further when I come to the site. Just let me know. Should you have any questions, comments or concerns please advise. I have a question about the inspection of permanent D-ring anchor points that are fixed on concrete floors, walls and ceiling. What are the critical points that have to be addressed during the inspection, what to look for, and how to test to verify that the installation is done properly and thus can withstand the maximum arrest force? In this case we have used a DBI/ SALA D-Ring Anchor Plate fixed on concrete with HILTI Corp. ½ X 4¼ HVU Adhesive together HILTI Corp. ½ X 6 ½ 304 SS HAS Rod.
I will attempt to answer your question: First and foremost the anchor should be selected and designed properly the right anchorage for the work method & designed with a minimum of 2 to 1 safety factor against peak dynamic loading peak dynamic loading could vary by anchorage purpose, i.e., restraint, fall arrest, work positioning or rescue. See section 2.6 of the attached D plate user instruction for details the basis of these loads are as stipulated in the latest ANSI Z359 Fall Protection Code. The anchor should pass all the criterion of anchor point planning as shown in “Introduction to Fall Protection, 3rd Edition”. The Hilti adhesive anchors would need to be installed in strict conformance with the manufacturers instructions no ifs ands or buts here. I would recommend at least 24 hours of cure time even though the info attached indicates much less. Pay particular attention to hole size, edge distances, spacing of anchors, blowing out of holes, etc. Install the anchorage per the installation instructions outlined in section 3.3 of the user instruction for the D plate anchor this section also gives some pointers of things to look for as well during the installation process. It is not absolutely necessary to pull test the anchors however if its a must we recommend a static proof load test 100% of proof load, i.e., loading from restraint, fall arrest, work positioning or rescue. For example, in the case of fall arrest the load applied would be the maximum anticipated dynamic force in the system 1,800 pounds for a single worker. This load should be applied in the weakest direction of the anchorage. In this case that would be either straight up (because of the spacing of the anchor bolts) or along the minor axis of the anchor D ring. Apply the load in a static fashion utilizing a dynamometer, come along and a fixed end connection combination. Hold the static loading at a constant level for a period of 1-2 minutes. There should be no permanent deformation in any component in the system. Inspect the anchorage after the test in accordance with the user instructions as well as on a recurring period interval (prior to each use and on an annual basis at a minimum) see section 5.0 of the D plate user instructions. Be certain to label, tag and fill out the inspection log.
Can the anchor point for a fall restraint system be at the same level as where the employee would be working (ex. standing on the roof of an indoor Envir chamber) or does it need to be at least equal to or above the back dorsal ring of his harness while the employee is standing up?
The response depends on the hazard you are recognizing. Introduction to Fall Protection, 3rd edition mandates that we need a shoulder height or higher anchor point for fall arrest to avoid a 7 ft free fall over an edge and subsequent rescue. Foot level is the worst condition for fall arrest standing close to the edge. If you apply that system to fall restraint at the same location, the user must not be able to get within a couple of feet of the edge at any time. The a foot level anchor might be fine. That depends on the geometry of the workplace as to whether it is reasonable for the Competent Person to assume that and apply a written plan. Anchorage point requirements are contained in Z359.2 for both fall arrest and fall restraint. At this time use Z359-2007 and 2009 over OSHA construction due to the latter being 16 years old and the newer Z359 since 2007. System standard Z359.1 is due for retirement in two years at which time the component standards Z359.2-18, plus definitions Z359.0 remain.
I am looking for information on training users of fall protection on using active systems appropriately on construction sites where we may not have installed dedicated anchor points, or specific procedures. Instead, it seems to me there should be a way to train users on how to recognize appropriate constructions conditions that could be used as anchor points, short of sending everyone through competent person training. What are your thoughts on this?
Although all workers on a construction site do not have to be competent persons, there must be a competent person on-site whenever active fall protection systems (such as personal fall arrest systems) are being used. In addition, OSHA and the ANSI Z350 standard require that selection of anchor points be conducted by a competent person. Over 50% of those who die in falls from elevation die with harnesses on – this is frequently because use of equipment and selection of anchorage points is left up to those who are not competent to make those determinations. The detailed information provided in competent person training regarding non-certified vs. certified anchorage strength requirements, fall clearance distances, the effect of fall distance on force, rescue, use and limitations of anchorage connectors, etc. is important for the person who selects anchorage points in any situation to have. There does need to be someone on a construction site who is designated to be a competent person – that person must oversee workers using active fall protection systems, must be the one to select non-certified anchorages, and must be available and able to answer any questions that authorized persons have regarding the use of equipment. This does not mean everyone who uses a PFAS has to be a competent person – most need only be trained as authorized persons. However, authorized persons can not select anchorage points.
When you are using a fall protection system as described below what is the maximum load imposed on the anchor point for the system? Anchor point SRL with maximum arrest force at 900lb Safety harness supporting person 255lb The maximum arrest distance is 2ft before coming to a stop. As a guide, when using fall protection systems the loading on the anchor point should be equivalent to the maximum arrest force imposed on the person. Is this the case? I hope you can give me some guidance on these points.
Point 2 is 900 lbs (if 900 lbf force is imposed on the anchorage). For a Rule of Thumb calculate in energy units: Wt x free fall distance = Force x deceleration distance. So Weight 255 lbs x two foot free fall = Force x one foot deceleration (typical) so force is 510 lbf. If deceleration distance is longer than the free fall the static load is what the anchorage eventually encounters. This type calculation works best for lanyards rather than the more complex SRL absorbers. EFSS has a software program available on this web site under Publications that has great flexibility for the type of problem you are posing.
Can you please clarify the following regarding personal fall arrest equipment anchorages in CFR1926.502 d (15) that indicates that anchorage will be “capable of supporting at least 5000lbs per employee attached”? Also, can two employees attach their personal fall arrest equipment to a single anchorage if it is capable of supporting 10,000lbs? If not, what then would be required for two persons?
Yes, you theoretically can do that if you are using lanyards. You then have the problem of compatibility of two snaphooks in an “eyebolt” that might lead to trouble (check Z359.1 two hooks in a D-ring are problematic). Two attachments to the same angle iron is a questionable situation. There are some tripods capable of supporting 10,000 simulating a rescuer additionally. Two, three or four attachments to a line are possible in an engineered horizontal line; the 2:1 factor is critical for cables. Everything is specific to an application. For a 100% application including moving, a logic appears upon analysis because the equipment has to be compatible with each anchorage system. This is why a Qualified Person (preferably a structural P.E.) who is skilled in fall protection engineering design is an invaluable addition to a Competent Person non-engineering group. Without engineering, the 10,000 lbs joint anchorage is the guide to follow for two persons. P.S. Perhaps we can help you plan. Send a description of the application with specific questions. Check Chapter 7 of Introduction to Fall Protection, 3rd Edition for further information.
I am looking for some information or direction on quality tie off in cooling towers. It is difficult to maintain the 5,000 lb anchorage policy. Would you be able to suggest or direct me on this matter?
Yes, the key is not 5,000 lbs but the OSHA 2:1 strength factor. The possibility of finding 2xMAF static strength in wood and plastic structures is a lot easier than 5,000 lbs using an engineered system. We can do this kind of work based on erection, dismantling or maintenance procedures that go hand in hand with sound fall protection.
I am a structural engineer in Portland, Oregon. I have been asked to check an embedded unistrut P3200 in concrete for adequacy to support loads from attaching fall arrest systems. I have been told that this needs to be designed for 5,000 lbs of vertical load. I am trying to verify if the 5000 lbs requirement is correct, whether it is allowable stress, level load or strength level (ultimate) load, and where (what spec.) it comes from.
OSHA goes by ultimate load; 5,000 lbs per person attached, or 3,000 lbs for SRL and 2:1 factor for documented engineered systems. You may wish to treat as allowable or in some cases as yield when values are known. The importance is not to pile safety upon safety thereby increasing the cost. The trick is to limit the force going into the structure. Single anchors can be very low based on MAF’s, HLL slightly more. You do that by specifying the fall systems and conditions for fall loading. Drawings should show people and allowed methods of use including multiples of people and distances of fall and MAF consideration from mfrs devices. Much of this is in Introduction to Fall Protection, 3rd Edition Chapter 7. (see Publications on this web site).
I have taken over a Safety Coordinator role in our manufacturing facility. We have been searching for the OSHA regulations regarding tying off when in a man basket or powered platforms. We have scoured 1910.66 and 1926.500-503 and we cannot find anything. If you could give us some ideas as to where we may look to find this standard, we would really appreciate your help!
You have chosen a tough subject. Remember that when we don’t find anything in the Federal Register (or ANSI) that we (the employers) must go to the 5(a)(1) part of the statute and look to see if there is a hazard and if so how to avoid, prevent or control through fall arrest /restraint. So sometimes standards can help and sometimes they cannot. When leading industry people disagree then the standards cannot get resolved around a hazard. The bucket truck is a prime example. Now I assume you have looked at 1926.453 and 1910.67. To answer your question, the anchorage point for a lift should be five feet from the floor (DOT rules for height of a vehicle will dictate whether that should be retractable). The connecting device should be a small retractable lanyard. Finally the harness is full body without a waist belt unless separately worn. Connection is 100% of the time as soon as entering the lift by an acceptable means. The enemies are potholes, collisions while moving and over-reaching while working. Plastic buckets need a slightly different approach with the bracket for the device being on the boom. We have to recognize that while a belt and short lanyard may be sufficient for limiting free falls to two feet that this system does not take care of a fall; thus a harness is required. Scissor lifts required two systems for expected reach-beyond-the-elbow applications. If any questions arise out of this, please come back with more questions. I understand that others may not agree with me but I believe that this view will prevail for the safety of our workers and the first step is to make a decision for safety when the hazard is recognized. Check Introduction to Fall Protection, 3rd Edition for sketches showing the aerial lift anchorages in place at Publications of this web site.
An engineered and approved fall arrest system including an anchorage point is being designed. A self-retracting lifeline will be attached directly to the anchorage point and the snaphook will be attached directly to the D-ring on the harness. What static load must the anchorage point be designed to support?
This is a favorite issue of mine and one the manufacturers may not have gotten around to thinking through. Their standard 5000 lbs answer is too conservative. The answer is 3000 lbs provided the free fall distance is 2 ft or less (by design) and that means installing at least five feet high (D-ring height) or if lower than 5 ft then the device sees a 7 ft free fall in which case 5,000 lbs may not be enough and the line strength of the SRL must exceed 5000 lbs! 1926.502(d)(13). Reason for 3000 lbs? Simple. It is the minimum break strength of the line assembly per OSHA 1926.502(d)(12). Just keep the devices high!!
I am looking for information on whether or not it is permissible to use a mobile crane hook as a tie off point for fall protection. We have an activity that requires personnel to climb on top of flatbed trucks to tarp the load. There is no nearby building or structure that can be used. We have a large capacity Link crane that could be parked near the truck with the boom/hook over the truck. Are there any regulations that cover this? Are there any restrictions on the crane while this is happening?
Thanks for your question regarding mobile crane anchors that should be of interest to many people. This question will have many answers from many people, but my answer is “why not?”!! In a field situation there are not many options until the trucks have their own system many years from now. As Bill Donovan of OSHA Chicago Area Office would say “it won’t be pretty” but it would be acceptable (referencing boson’s chair work from the hook and a lifeline to the boom, NATE, Dallas, TX 2 22 01). The issue is protection of employees, not crane manufacturer’s interests, provided the answer has been carefully documented. Here is what I suggest for an independent lifeline from the crane to work unloading a flatbed in the field greater than six feet (construction), or 4 ft (general industry): Position the crane appropriately and set up for the overhead anchorage. Do not use the hook or ball or main cable because there is too much debate over the years plus regulation, unless meeting 1926.550(g). Use a place on the boom or jib that has the static capacity for anchor for fall arrest (2 x MAF per fall equipment manufacturer’s certification) such as a bracket or temporary web anchorage connector. Use a SRL of appropriate length with a tag line for access. Lock the crane out. How high the attachment is depends on the consequences of swing fall from a remote part of the flatbed so position the anchor centrally over the area of movement as high as reasonably possible. Then you can go to work under competent observation. For an engineered solution, we could help you with this important solution that could apply nationwide with careful application. Please call to discuss what items we need from you if you would like to consider our services.
What is a typical proof test for an anchorage point for a vertical lanyard? Is there an accepted proof test factor that is applied or is it acceptable to load test the point just up to the design load or the 5000 lbs (if you do not engineer the system)?
These are your choices for proof load: 5000 lbs non-engineered is probably easiest to rationalize 3600 lbs OSHA regulations, reference D-ring/snaphook Max arrest force equivalent for engineered systems Assumption Proof load is approx. one half of min. break strength – general rule Note: OSHA went 67% of 5000 lbs min break for proof load.
On page 206 of “Introduction to Fall Protection, 3rd Edition”, there is the following statement: “To prevent specific anchorage points from being used for attaching hoists and powered come-alongs, they should be painted yellow or orange and clearly tagged with their usage rating…” My question is why is it necessary to prevent the anchorage points from being used? I ask because I know that with the capacity clearly marked, I will soon be asked to allow a hoist to be attached to the anchorage to lift out a piece of equipment. Usually these anchorages are located in areas near to the equipment that needs the most frequent maintenance and service. The argument will likely proceed on the basis that the tag says it’s good for 5000 pounds, so why can’t I attach this 1 ton hoist? As long as the pull is in the appropriate direction, do I have any other good reasons to decline their requests?
Thanks for your excellent question! I supose we should have said “reasonably prevent” to start out. Only you and your collegues will know to what extent you should paint or mark a special attachment. If you do not indicate a specific rating directly on the anchorage point you can require the potential user to contact the person best able to deal with the situation. You might also consider attaching to the anchorage point a non-removable shackle for use with fall protection equipment only. I suggest you discuss the issue with your egronomics partners. We would like to hear more about what you think about the whole of page 206 – We would like to know your thoughts on how your business works to distinguish engineered safety items from production items.
California regulation presently prohibits anchoring of PFAS to guardrails (8CCR 1670(b)(17)). The staff of the Cal-OSHA standards board is considering amendments to permit personal fall arrest systems to be anchored to guardrails. What are your thoughts on the use of guardrails for anchorage?
Guardrails (railings) are fall prevention systems for a standing worker(s) on a platform that can be considered for fall arrest anchors when working or accessing beyond the guardrail Fall Arrest Anchors from Guardrails: My opinion is that anchor points for fall arrest systems using guardrails are OK if they are approved by a Qualified Person who is a Registered Structural Engineer skilled in the field of fall protection engineering. The responsibility would be for that person to have active control over the use of the anchor points in its particular application including numbers of persons attached and equipment used. The need for a structural engineer is particularly pertenent in the area of use of cables such as perimeter cables used as guardrails where no data is available from cable manufacturers on dynamic sag, dynamic end-force and pre-tension (less than 3 inches at 200 lbs). Removable guardrails would be a concern if the force is up and over an obstruction unless the engineer could recognize a special foreseeable problem. Scaffolding railings would be another consideration relative to their purpose and design. Requirements: One concern is height of anchors – all anchor points must be overhead as a general rule for fall arrest such that the effective impact force on the railing would be down and outwards. Another is abrasion over corners or edges surrounding the railing and compatible anchoring to the railing itself. Another, assuming the first question is answered, is what height to use assuming the base is strongest and the end of a railing at its top point is weakest at least for bending. Additionally the use as a single anchor point as opposed to a horizontal lifeline is an engineering consideration. There are other specific issues to consider and finally because this would be an exception to several existing rules including OSHA 1926.502(d)(23), what form of labeling is appropriate to the application for an approved section of guardrail. Restraint and work Positioning Systems: As restraint systems get better developed as equipment rigged such that a fall hazard cannot be reached and beyond that into a new category of fall equipment where the total fall distance is limited to 2 feet, this new class of fall equipment can emerge that serves people at low heights and where lower anchor points like guardrails would be ideal. However force levels would have to be set for this equipment (which is not the intention of the forthcoming Z359.2 standard). If leaning was a common feature of the usage then consideration as a work positioning system would call for a secondary back-up fall system.
Background info: We have a rappel tower that we need to put operational in the next coming months. The anchor points in the tower consist of (3) three stainless steel U-bolts that are one inch to one & a half inch thick in diameter that are bolted to the floor of the rappelling tower. Our Navy Construction Battalion did the work and they told us that the anchor points are capable of sustaining 1 – 2 rappellers per anchor point but we don’t have anything in writing. The command intends to start training our Marines by next month before they deploy and go to the Middle East. However, before we put it operational, we have to ensure that all safety requirements are in-place. The safety checklist requires the following be conducted before we put the rappel tower operational: Rope anchor points must be load tested AND certified to 5,000 lbs each. Reference: ANSI Z359.1 (1992) & 29 CFR 1910.66 part(I)(c)(10) of Appendix C. All fast rope anchor points shall be tested to 5,000 pounds each, per person on the rope (e.g. 2 ropers on the rope at the same time requires testing to 10,000 lbs.) Question: Could you please define or explain the difference between load testing, testing, and certifying the anchor points? And can we do one without the other? In other works, if we get a certification on the anchor points, do we still need to conduct the load testing?
These could mean the same. Certifying more likely means a representation from a third party to the user that anchor strength meets a certain standard. Z359.1 standard is 3600 pounds minimum static strength for a single point anchor. There usually is a time period that the certification is stated to be valid, during which load testing should not be required depending on application. That sets the deadline for when load testing will become necessary. You can set the deadline by determining the chances of deterioration of the anchor point over about 2-3 years if the application is outdoors and maybe 5-10 years if it is indoors. Multiple uses of the anchor point should be assessed carefully, for example rigging for hoisting loads, long free falls or abrupt fall arrests that can produce forces over 1800 lbf. All fall arrest anchors should be labeled for proper use and referred to an engineering drawing. Forces from the Z359.1 fall arrest tests may be 900 lbf or 1800 lbf depending on the components.
Background info: We have a rappel tower that we need to put operational in the next coming months. The anchor points in the tower consist of (3) three stainless steel U-bolts that are one inch to one & a half inch thick in diameter that are bolted to the floor of the rappelling tower. Our Navy Construction Battalion did the work and they told us that the anchor points are capable of sustaining 1 – 2 rappellers per anchor point but we don’t have anything in writing. The command intends to start training our Marines by next month before they deploy and go to the Middle East. However, before we put it operational, we have to ensure that all safety requirements are in-place. The safety checklist requires the following be conducted before we put the rappel tower operational: Rope anchor points must be load tested AND certified to 5,000 lbs each. Reference: ANSI Z359.1 (1992) & 29 CFR 1910.66 part (I)(c)(10) of Appendix C. All fast rope anchor points shall be tested to 5,000 pounds each, per person on the rope (e.g. 2 ropers on the rope at the same time requires testing to 10,000 lbs. each). Questions: How do you do the certification and who does the certification? Does the certifier require some kind of training?
Often a structural engineer can do this if his/her firm has skills in personal fall protection and a good understanding of the Z359.1 standard. The structural engineer should preferably have attended a Qualified Person training course and successfully passed the course test.
I have a couple of questions regarding permanent anchorage points for window washing work. 1.How often must these point be inspected? 2.What is included in the inspection, is it just a visual and was type of training does someone require to perform such an inspection?
The answer may depend on in which state the building is located. Generally, it must remain strong enough for its intended purpose. What standards does your company currently have for PFAS? What inspection intervals are used, specifically in a marine environment annual inspections are best and the specs must be changed to an acceptable stainless steel. For roof installation with set back from edge or parapet we propose annually to inspect and then test one anchor against the next and certify strength to a proof load which is a percentage of ultimate rating. For window installation where window opens I may refer you to a colleague for this.
From: John Whitty [mailto:jwhitty@itac-net.com] Sent: Friday, February 05, 2010 9:44 PM To: Semoedi, Alfonds Cc: JeffS47@aol.com; Kromopawiro, Harold T.; Nigel@fallsafety.com; Bruce Simms Subject: RE: Train The Trainer question Alfonds, Good to hear from you& I will attempt to answer your question: First and foremost the anchor should be selected and designed properly the right anchorage for the work method & designed with a minimum of 2 to 1 safety factor against peak dynamic loading peak dynamic loading could vary by anchorage purpose, i.e., restraint, fall arrest, work positioning or rescue. See section 2.6 of the attached D plate user instruction for details the basis of these loads are as stipulated in the latest ANSI Z359 Fall Protection Code. The anchor should pass all the criterion of anchor point planning as shown in the Introduction to Fall Protection you should have a copy of this book weve discussed this before in previous training. The Hilti adhesive anchors would need to be installed in strict conformance with the manufacturers instructions no ifs ands or buts here. See attached portion of this anchorage systems technical specification. I would recommend at least 24 hours of cure time even though the info attached indicates much less. Pay particular attention to hole size, edge distances, spacing of anchors, blowing out of holes, etc. Install the anchorage per the installation instructions outlined in section 3.3 of the user instruction for the D plate anchor this section also gives some pointers of things to look for as well during the installation process. It is not absolutely necessary to pull test the anchors however if its a must we recommend a static proof load test 100% of proof load, i.e., loading from restraint, fall arrest, work positioning or rescue. For example, in the case of fall arrest the load applied would be the maximum anticipated dynamic force in the system 1,800 pounds for a single worker. This load should be applied in the weakest direction of the anchorage. In this case that would be either straight up (because of the spacing of the anchor bolts) or along the minor axis of the anchor D ring. Apply the load in a static fashion utilizing a dynamometer, come along and a fixed end connection combination. Hold the static loading at a constant level for a period of 1-2 minutes. There should be no permanent deformation in any component in the system. Inspect the anchorage after the test in accordance with the user instructions as well as on a recurring period interval (prior to each use and on an annual basis at a minimum) see section 5.0 of the D plate user instructions. Be certain to label, tag and fill out the inspection log. This is a good start I hope it helps. We can go in further detail if needed or we can address further when I come to the site. Just let me know. Should you have any questions, comments or concerns please advise. I have a question about the inspection of permanent D-ring anchor points that are fixed on concrete floors, walls and ceiling. What are the critical points that have to be addressed during the inspection, what to look for, and how to test to verify that the installation is done properly and thus can withstand the maximum arrest force? In this case we have used a DBI/ SALA D-Ring Anchor Plate fixed on concrete with HILTI Corp. ½ X 4¼ HVU Adhesive together HILTI Corp. ½ X 6 ½ 304 SS HAS Rod.
I will attempt to answer your question: First and foremost the anchor should be selected and designed properly the right anchorage for the work method & designed with a minimum of 2 to 1 safety factor against peak dynamic loading peak dynamic loading could vary by anchorage purpose, i.e., restraint, fall arrest, work positioning or rescue. See section 2.6 of the attached D plate user instruction for details the basis of these loads are as stipulated in the latest ANSI Z359 Fall Protection Code. The anchor should pass all the criterion of anchor point planning as shown in “Introduction to Fall Protection, 3rd Edition”. The Hilti adhesive anchors would need to be installed in strict conformance with the manufacturers instructions no ifs ands or buts here. I would recommend at least 24 hours of cure time even though the info attached indicates much less. Pay particular attention to hole size, edge distances, spacing of anchors, blowing out of holes, etc. Install the anchorage per the installation instructions outlined in section 3.3 of the user instruction for the D plate anchor this section also gives some pointers of things to look for as well during the installation process. It is not absolutely necessary to pull test the anchors however if its a must we recommend a static proof load test 100% of proof load, i.e., loading from restraint, fall arrest, work positioning or rescue. For example, in the case of fall arrest the load applied would be the maximum anticipated dynamic force in the system 1,800 pounds for a single worker. This load should be applied in the weakest direction of the anchorage. In this case that would be either straight up (because of the spacing of the anchor bolts) or along the minor axis of the anchor D ring. Apply the load in a static fashion utilizing a dynamometer, come along and a fixed end connection combination. Hold the static loading at a constant level for a period of 1-2 minutes. There should be no permanent deformation in any component in the system. Inspect the anchorage after the test in accordance with the user instructions as well as on a recurring period interval (prior to each use and on an annual basis at a minimum) see section 5.0 of the D plate user instructions. Be certain to label, tag and fill out the inspection log.
Can the anchor point for a fall restraint system be at the same level as where the employee would be working (ex. standing on the roof of an indoor Envir chamber) or does it need to be at least equal to or above the back dorsal ring of his harness while the employee is standing up?
The response depends on the hazard you are recognizing. Introduction to Fall Protection, 3rd edition mandates that we need a shoulder height or higher anchor point for fall arrest to avoid a 7 ft free fall over an edge and subsequent rescue. Foot level is the worst condition for fall arrest standing close to the edge. If you apply that system to fall restraint at the same location, the user must not be able to get within a couple of feet of the edge at any time. The a foot level anchor might be fine. That depends on the geometry of the workplace as to whether it is reasonable for the Competent Person to assume that and apply a written plan. Anchorage point requirements are contained in Z359.2 for both fall arrest and fall restraint. At this time use Z359-2007 and 2009 over OSHA construction due to the latter being 16 years old and the newer Z359 since 2007. System standard Z359.1 is due for retirement in two years at which time the component standards Z359.2-18, plus definitions Z359.0 remain.
I am looking for information on training users of fall protection on using active systems appropriately on construction sites where we may not have installed dedicated anchor points, or specific procedures. Instead, it seems to me there should be a way to train users on how to recognize appropriate constructions conditions that could be used as anchor points, short of sending everyone through competent person training. What are your thoughts on this?
Although all workers on a construction site do not have to be competent persons, there must be a competent person on-site whenever active fall protection systems (such as personal fall arrest systems) are being used. In addition, OSHA and the ANSI Z350 standard require that selection of anchor points be conducted by a competent person. Over 50% of those who die in falls from elevation die with harnesses on – this is frequently because use of equipment and selection of anchorage points is left up to those who are not competent to make those determinations. The detailed information provided in competent person training regarding non-certified vs. certified anchorage strength requirements, fall clearance distances, the effect of fall distance on force, rescue, use and limitations of anchorage connectors, etc. is important for the person who selects anchorage points in any situation to have. There does need to be someone on a construction site who is designated to be a competent person – that person must oversee workers using active fall protection systems, must be the one to select non-certified anchorages, and must be available and able to answer any questions that authorized persons have regarding the use of equipment. This does not mean everyone who uses a PFAS has to be a competent person – most need only be trained as authorized persons. However, authorized persons can not select anchorage points.
