Here Is The Scoop On Full Body Harnesses

Personal fall arrest systems - "OSHA regulation 1926.502

Written by John Cleasby and Karen Cleasby
Published March/April 1998 in Western Roofing Magazine

We have all heard it . . .

"OSHA regulation 1926.502 (d) - Personal fall arrest systems and their use shall comply with provisions set forth below. Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system".

. . . and now it is law!

Why the new law? Ernie Williams of Dalloz Fall Protection formerly Miller Equipment, offers this explanation, "while employees who are wearing body belts might not fall to the ground, they can face more severe internal injuries as a result of not having the full protection provided by a harness and shock absorbing lanyard. As of January 1, 1998 this will no longer be a problem as belts will have to be replaced by the full body harness." Other industry executives back up Mr. Williams explanation including Tom Shanahan, Associate Executive Director NRCA (National Roofing Contractors Association), who also agrees that "body belts were outlawed in part, due to the unsafe amount of pressure put on the abdomen."

The new law is in effect, full body harnesses are the only acceptable form of body wear as part of any Personal Fall Arrest System (PFAS). Just what is a PFAS? When and who must wear a full body harness as part of a PFAS? Often asked questions but not always clearly explained. My purpose here is to clearly state the answers to these questions. However, whenever in doubt always ask. Insuring a safe work environment is everyone’s responsibility.

What is a personal fall arrest system? It is a system used to arrest an employee in a fall from a working level. Basically, it prevents the worker from hitting the ground should he fall from an elevated surface. It is imperative that anyone utilizing a personal fall arrest system understand that it is designed to be passive (not to be used for any other purpose; i.e. bungee jumping or swinging from the roof) and will only come into service in the event of a fall. It consists of a body harness, connectors and an anchorage point. It may also include a lanyard, deceleration device, lifeline, or a suitable combination of these per OSHA 1926.500: Scope and definitions for Subpart M. Simply put, a PFAS system is made up of three key components:

1. Body wear: Full body harness.
2. Connecting device: Shock-absorbing lanyard or a nylon lanyard with a rope grab and SOFSTOP.
3. Anchorage point: Anchorage point and anchorage connector must support 5000 pounds.

PFAS equipment choices can be very complicated with so many laws and regulations to consider. A basic system is the best bet when in doubt. Begin with a full body harness that includes a sliding back Dee-ring. In the event of a fall, the body harness will distribute the force of the impact throughout the body instead of on the abdomen, as was the case with traditional body belts (no longer a legal alternative). The sliding back Dee-ring will keep the worker in an upright position if he should fall from a roof or other elevated level. This allows the worker to remain as comfortable as possible while awaiting a rescue. Most all body harnesses are equipped with a back sliding Dee-ring for fall arrest. There are also harnesses available with

side Dee-rings to be used for positioning purposes only. A front Dee-ring is another option for positioning. It can be especially helpful for positioning oneself on a steep roof. The front Dee-ring can also be used for raising and lowering a person. Always remember that the only Dee-ring to be used for fall arrest is the back Dee-ring.

A connecting device is the second component of a basic PFAS. The device can be a rope or web lanyard, rope grab or retractable lifeline. Representatives of Dalloz Fall Protection recommend the use of a lanyard with a built-in shock absorber. The built-in shock absorber reduces the fall arresting forces by 65-80% compared to forces generated by traditional lanyards. However, we recommend primarily the synthetic lanyards with a rope grab and SOFSTOP. These too are shock absorbing connecting devices that afford more versatility. The rope grab and SOFSTOP in effect turn a lanyard into an adjustable life line to accommodate varying job widths. For example, you are working on a roof with a 30 foot width and a ground to eve height of 25 feet. A 50 foot lanyard would be illegal by itself. You would end up falling 20 feet (50 ft. lanyard - 30 ft. roof width). The legal fall limit is 6 feet from the roof’s edge. For a PFAS to meet legal requirements, it cannot permit a worker to fall more than 6 feet from the roof’s edge. A rope grab with SOFSTOP turns the 50 foot lanyard into an adjustable line. The rope grab serves as the anchor by clamping onto the lanyard. The SOFSTOP hooks onto the rope grab and works as a deceleration device that reduces the distance a worker can fall to a mere 24" from where the rope grab is connected to the lanyard. Instead of going through the continued expense of having to buy lanyards to accommodate each roofing job, we recommend the use of the rope grab with SOFSTOP. Otherwise, in the example above you would have to replace the 50 foot line with a 35 foot line to comply with legal standards.

It is important to note too that as of January 1, 1998, the use of a non-locking snap hook as part of a PFAS and/or a positioning device system is prohibited per OSHA 1926.500 Subpart M. Snap hooks are used to connect all of the components of a PFAS. For instance, the lanyard is connected to the body harness with a snap hook. Same as with a SOFSTOP and rope grab. Safety lanyards generally come with the locking snap hooks already installed. Just be aware that when you purchase any personal fall arrest equipment that it is in fact equipped with self-locking snap hooks. OSHA defines a legal snap hook as "the locking type with a self-closing, self-locking keeper which remains closed and locked until pressed open for connection or disconnection". Dee-rings and snap hooks shall have a minimum tensile strength of 5000 lbs. To comply with OSHA.

The final component of the system is the anchor point (more commonly known as the tie-off point). This point must be capable of supporting 5,000 pounds per worker, such as a roof anchor or support beam. We for one, recommend a reusable roof anchor that is OSHA compliant. It is equipped with two forged steel Dee-rings one on either side of the pitch to allow for movement on both sides of the roof. It can be used on both flat and variable pitch roofs. A roof anchor is legally designed to support one person. The two Dee-rings are to allow one worker to move from one side of the roof to the other without having to move the anchor. There is also a single use roof anchor available that meets OSHA standards. It can be used on both steep pitched roofs and flat surface roofs. After the roofing is completed, just hammer the anchor down and roof over it. Should you have any doubts about the anchor or other attachment point - DO NOT USE! Find another OSHA compliant means for attachment.

The second question addresses "when" a full body harness must be worn? Fall protection within the roofing industry is required at any elevated level that has an eve to ground height of 16 feet according to Federal OSHA standards. A PFAS complete with a full body harness is a legally acceptable form of fall protection. An approved PFAS can be used on a low slope roof (a slope of 4-in-12, 33% or less), steep roof (those having a slope greater than 4-in-12), or as protection for keeping workers from falling through skylights and other various openings in a roof’s surface. A personal fall arrest system is one form of fall protection and can be used in conjunction with other OSHA approved fall protection systems including guard rails with toe boards and warning lines.

Last but not least by any means, "who must wear a PFAS with full body harness?" Anyone working at a height that is 16 feet above a lower level and is using a PFAS as a form of fall protection. This also applies to vendors delivering material to the roof. They too must be protected by an approved form of fall protection. The only persons not subject to the new requirements under Subpart M are people making an inspection, investigation, or assessment of a job site prior to the actual construction work beginning or after the work has been completed.

The laws and regulations are very descriptive and should be referred to when setting up a fall protection program whether it be a personal fall arrest system as described in this article or another approved system. A workers safety should be a company’s number one priority. Mr. Williams is astute in his synopsis, "A thorough fall protection program is a cost effective management tool for insuring a safe working environment. It also makes a major contribution to overall efficiency and productivity".

-END-