Compliance in a can - or is it really?
OSHA Regulation 29 CFR 1926.501(b)(1) states the each employee 6’ or more above a lower level shall be protected from falling by the use of one of three choices - guardrail systems, safety net systems, or personal fall arrest systems (PFAS). For the most part, safety nets are impractical. This leaves you, the employer, and your workers with only two practical options – guardrail systems and/or personal fall arrest systems. Guardrail systems work great, but have limited applications and therefore the personal fall arrest system is what many employers choose to protect their workers from falling off roofs.
Many companies, particularly residential contractors, have purchased what they believed was an all-inclusive fall protection system for their workers - “Compliance in a Can”, an OSHA compliant system, all in one bucket. Typically, this bucket has a rope grab system for their PFAS which includes a body harness, a lanyard with a built-in shock absorber, a ropeline with a rope grab (to arrest the fall of an employee) and a 5,000 pound rated anchor - all in one neat easy to carry bucket.
Some of the challenges that employers and workers face in order to be in compliance with OSHA standards and regulations include:
1926.502(d)(16)(iii) - no one is permitted to free fall more than 6 feet nor contact any lower level;
1926.502(d)(16)(iv) - before his fall protection equipment begins to slow his descent and limits deceleration distance to no more than 3.5 feet; and
1926.502(d)(16)(ii) - limit maximum arresting force on the employee’s body to 1,800 pounds when used with a body harness.
Let me explain the challenges by drawing you a picture: Assume your employee is working on the roof of a one story ranch style house with a 5/12 slope. In an effort to be compliant, you choose to use the “Compliance in a Can” equipment system. Let’s assume the roof is 20’ from the roof eave straight up directly to the ridge of the roof where he places his anchor point. This is where he attaches the snaphook end of his rope lifeline. Next, he attaches one end of a 2’ long lanyard (which also includes a built-in shock absorber with 3.5’ maximum elongation used to slow and stop a fall) to the dorsal “D-ring” on the back of his well-fitting harness and the other end of this lanyard (which has the metal rope grab) to his rope lifeline. Then he walks 20’ straight down the roof to the eave. Keeping the rope lifeline taught from the lanyard (attached to the back of his harness) straight up to the anchor at the ridge is the text book method for using the rope grab system.
At this point, if your worker were to fall (example # 1), he and his equipment would meet the intent of the OSHA regulations and both the employee as well as the employer would likely be in compliance.
Let’s look at the facts related to this fall and let’s calculate this total fall distance. Assuming his back D-ring is approximately 5’ above his feet before the fall and that because of the force of the fall, his harness stretches and tugs and shifts his back D-ring to just above his head or roughly 6’ above his feet. Let’s assume that the shock pack (shock absorber) on his 2’ lanyard deploys and elongates only about 1’ (because everything was just right on his equipment and his rope lifeline was taught straight up to the anchor and the forces created by the fall were very minimal.)
With his fall arrested, and his feet hanging about 9’ below the roof’s eave, he would most likely have been compliant with 1926.501(b)(1) because he was protected from falling by using a PFAS; also with 1926.502(d)(16)(ii) because his shock absorber likely reduced the force of the fall to a range between 700-900 lbs.; with 1926.502(d)(16)(iii) because his free fall was only 2’ before his equipment started to arrest his fall to prevent him from contacting a lower level and with 1926.502(d)(16)(iv) because his shock absorber only elongated 1’.
While this sounds great in theory, this scenario is not generally how people actually work. Let’s assume (example # 2) for a moment that after walking straight down the roof to the roof eave that the worker needs to walk laterally along the roof eave 10’ to do get some materials. By opening the rope grab and allowing more of his rope lifeline out, he is able to walk laterally. At this point (assuming the Pythagorean Theorem still works) he will have approximately 22’- 4” of rope out from the anchor point straight to his D-ring. Then, if he were to walk straight back to his previous position along the eave line, to do his job, he would have approximately 2’- 4” of slack in his ropeline. This is where the rope grab system issue starts to become problematic. If, after walking back to his starting point on the roof’s eave and directly below his anchor point, he doesn’t pull the slack out of his rope lifeline through his rope grab, this extra amount of rope slack must be added to his free fall distance. This extra free fall distance will also increase the force of the fall on his equipment and on his body.
If he were to fall now (example # 2), his feet would end up stopping 2’- 4” lower than the original 9’ level (in example #1) because of slack in his rope, which will in turn cause his shock absorber to pull out further, and therefore his feet are likely to be 12’ or more below the roof eave and he will likely have hit the ground or other objects below him. The problem just grows larger as workers tend to let out more slack in their ropes in order to get their jobs done. Often, I see workers with 10, 15 or 20’ of slack in their rope so they can move around freely.
The fallacy is not in the rope grab system (the technology really does work, when used as instructed). The fallacy begins with the lack of proper training by the employer’s competent person and is exhibited by the poor work practices of the employee in not being diligent in taking the slack out of the rope. So I ask you, what is an OSHA Compliance Officer (CSHO) supposed to think and do, when he sees someone working on the roof, using a rope grab system, but the worker has enough slack in his rope to certainly hit the ground?
Examples of rope grab systems at work:
One solution is to use Self-Retracting Lifelines (SRLs) which are a much more technologically advanced system that automatically keeps the line (lanyard) taught from the worker straight up to the anchor. SRLs have an advantage because their lanyard is automatically self-retracting (self-tightening like the seat belt in your truck) keeping it taught and up off the roof deck, whereas the worker using a rope grab system must constantly be manually adjusting the slack out of his rope. Also, an SRL only requires a maximum of two feet to arrest the fall, instead of typical three and a half feet of the shock pack, plus the lanyard’s length. In most cases, the braking of an SRL is almost instantaneous, which significantly reduces the risk of the worker hitting the ground, as well as the shock to the worker body.
Examples of Self-Retracting Lifelines at work:
Generally speaking, self-retracting lanyards are the preferred system because they automatically eliminate the requirement for the worker to constantly adjust the slack out of his rope (when using the rope grab system) in order to be able to arrest a fall in the shortest distance possible. SRLs are the choice of people who understand how workers actually work and use their fall protection equipment to keep them from hitting the ground.
Instead of focusing simply on being compliant, let’s raise the bar and start focusing on getting everyone safely home to their families.
For additional resources on Fall Protection:
OSHA’s Fall Protection Page
OSHA’s Educational Training Materials and Resources
OSHA’s Fall Protection Publications
If you would like more information, you may contact us at 1 (866) 273-1105. If you would like to schedule a free consultation, please complete the request form at:
The USF OSHA Training Institute and Education Center also offers the following Fall Protection related courses:
• OSHA 3115 – Fall Protection (formerly OSHA #3110 Fall Arrest Systems)
• OSHA 7405 – Fall Hazard Awareness for the Construction Industry
You can find more information and register for these courses by looking under the construction tab at: http://usfoticenter.org/osha-training/