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Dr. Ellis Discusses Z359 Harness Requirements


In his letter to the editor in the March 2008 issue of Occupational Health & Safety, Dr. Ellis explains in detail the hazards of using waist and chest belts as opposed to full-body harnesses.
Dr. Ellis also discusses how, contrary to what was asserted in an earlier OHS article, various governing agancies including OSHA and ANSI in the new Z359 Fall Protection Code already have started the move toward requiring the use of harnesses and how he projects this will gain wider acceptance over time. Dr. Ellis also explains how a rope access standard is being developed.
Consult OHS to read the entire article.
You can find out more about 2007 ANSI Z359 Fall Protection Code training for Competent Person on this website at EFSS Z359 Competent Person Training. and about 2007 ANSI Z35p Fall Protection Code training for Qualified Person on this website at EFSS Z359 Qualified Person training.
If you have a specific question, please contact Dr. Ellis at nigel@FallSafety.com.


Safety News Item – 03/07/08 – Ergonomic Regs for Shipyards


OSHA adopteded ergonomic guidelines in March 2008 for the nation’s shipyards. As one of the most dangerous types of workplaces in terms of occupational injuries, these guidelines are aimed at reducing the high injury rate at shipyards.

Shipyard Ergonomic Guidelines.


Tip of the Week No. 175 – 09/03/07 – Free Fall


Fall arrest equipment should be used at all times when a fall hazard of more than 6 feet (or other local trigger height) cannot be eliminated or controlled.
The maximum free-fall distance should be 2 feet for most confined spaces of limited size, but which otherwise meet the criteria of OSHA 1910.66, Appendix C.
Fall equipment with an integral retrieval feature should be considered.

See “Introduction to Fall Protection, 3rd Edition” page 272.
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Navy Spec Reguires ALL Fall Protection Anchorages


The US Navy Safety Requirements UFGS-01525 has recently required that all fixed anchorages and all horizontal lifeline anchorages be designed and certified by a Registered Professional Engineer. The requirement was issued in November 2002 and applies to all contract work conducted in naval shipyards and facilities involving construction, demolition, dismantling, restoration, asbestos abatement, lead hazard control. It applies to all projects in the continental USA and overseas and supplement the Corps of Engineers Safety & Health Requirements Manual EM 385-1-1. FAR clause 52.236-13 Accident Prevention Plan requires an Activity Hazard Analysis detailing plans for fall protection anchorages. Fall protection anchorages conforming to ANSI Z359.1 are required to be left in place for continued customer use. Existing anchors are required to be recertified by a qualified person. Horizontal lifelines shall be designed, installed, certified, and used under the supervision of a qualified person as part of a complete fall arrest system (1926.500). DSC offers this service of Fall Protection Anchorage design, certification and recertification to owners, general contractors, sub-contractors, architects & engineers with nationwide local service and is organized to provide speedy capable service for this new requirement meeting OSHA and ANSI requirements. Call 1 800 372 7775 or email dsc@FallSafety.com.


Tip of the Week No. 17 A – 03/29/04 Qualified Person


The Qualified person may or not also be a Competent person. Qualified means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his/her ability to (re)solve problems relating to the site-specific work to be done. [This is a paraphrase of OSHA 1926.32(m)].

See “Introduction to Fall Protection, 3rd Edition” page 341.
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Tip of the Week No. 31 A – 07/05/04 Rail Systems


When properly installed from a required top rail (cable) and secured directly to deck level, some nets satisfy OSHA requirements for midrail and toeboard protection, as well as overhead protection.

See “Introduction to Fall Protection, 3rd Edition” page 124.

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Tip of the Week No. 40 A – 09/13/04. Fall Protection Plans


Fall Protection Plans – under OSHA regulations, a qualified person is required to prepare the site-specific plan for leading-edge, precast concrete erection and residential construction work. The plan must be maintained at the worksite, implemented by a competent person, and changed only by a qualified person.

See “Introduction to Fall Protection, 3rd Edition” page 321.
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Tip of the Week No. 48 A – 11/15/04 Competent and Qualified Persons


The terms competent person, qualified person and qualified climber or worker need to be defined by each employer and standards of performance need to be developed around safety rules for fall protection.
A company’s Experience Modification Rate (EMR) in future years will be predicated on active fall-incident prevention now. Employers should become leaders for preventive safety engineering in their industry!

See “Introduction to Fall Protection, 3rd Edition” page 62.
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Tip of the Week No. 74 A – 06/13/05 – Competent Person


OSHA’s definition of a competent person (1910.66, Appendix C) is as follows:
“A person who is capable of identifying hazardous or dangerous conditions is the personal fall arrest system or any component thereof as well as in their application and use with related equipment.”
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NOTICE TO ATTORNEYS – OSHA REQUIRES EMPLOYERS TO PROTECT ALL WORKERS ON SITE


All attorneys involved in litigation arising from a workplace should be aware that the Occupational Safety and Health Act (OSHA) of 1970 in section 5(a)(1) & (2) imposes the duty that each employer:
(1)shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious phyical harm to his employees; and
(2)shall comply with occupational safety and health standards promulgated under this Act.

Section 5(a)(2)places this duty on employers even for workers who are not its own if that employer has control over or is supervising the subcontractor or independent contractor/trucker/delivery person/etc.
This lead to the multi-employer worksite policy put into use in 1974.

Need to find out more?! Call Dr. J. Nigel Ellis at 800-772-7775 or email him at dsc@FallSafety.com.
Visit our Ellis Litigation Support section of this website at ELS general information.


Safety News Item – 03/24/06 – Fall Protection Trigger Heights


Remember that general industry and construction use different trigger heights for requiring the use of fall protection. And different tasks within the construction field have different trigger heights.

In general industry the trigger height is 4 feet. For most construction workers the trigger height is 6 feet.
Steel erectors use a 15 foot trigger height, while steel connectors use a 30 foot trigger height!

Be sure you know what regulations and standards apply to you and always be as safe as possible.


Tip of the Week No. 83 – 09/19/05 – ANSI Z359.1


The ANSI Z359.1 standard addresses personal equipment and related methods for arresting falls from heights.
It is the first in a series of U.S. national standards for fall protection for all occupational and nonoccupational activities, except those in Standard Industrial Classification (SIC), Division C. It is not intended to apply to sports activities, such as mountaineering or caving.

Other standards in the Z359 series are addressing the related subjects of positioning, rescue and evacuation. Hazards of moving and supporting people exist both below and above ground, and in confined as well as unconfined spaces.
The Z359 series applies to all of these circumstances.

See “Introduction to Fall Protection,3rd Edition” page 37.
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Safety News Item – 07/29/05 – Multi-Employer Work Site


There currently (spring 2005) is a bill introduced in the House which would permit the labor secretary to cite only employers whose workers were actually exposed on multi-employer work sites to a condition in violation of any standard or rule.

There is no comparible bill in the Senate and no hearings have been scheduled to date.


Safety News Item – 07/22/05 – OSHA Scaffold Interpretation


OHSA’s Directorate of Construction, Bruce Swanson, noted that one way to comply with the requirement that when a scafold is in use that the scaffold wheels be in the locked position is to use a scaffold fitted with a device that permits the worker to lock and unlock the casters/wheels while on the scaffold. This would allow the scaffold to be moved without the workers having to continually having to dismount and remount the scaffold every time it needed to be moved.


Safety News Item – 07/08/05 – Oregon Trigger Heights


In reviewing Oregon’s fall protection standards, OSHA called for comments from the industry.
In his comments, Dr. J. Nigel Ellis expressed concern over Oregon’s 10 foot trigger height for certain fall protection requirements.
Dr. Ellis opined that this is less effective than the federal standard and that an across the board trigger height of 6 feet should be adopted. (see Federal Register Vol.70 No. 86, page 23888, May 5, 2005)
Notwithstanding Dr. Ellis’ comments, OSHA concluded that Oregon’s standards are as strict or stricter than the federal standards and are presumed to be in compliance with section 18(c)(2) of the Act.


Safety News Item – 02/18/05 – US Army Corps of Engineers


The US Army Corps of engineers in November 2003 adopted an extensive health and safety manual for all Corps activities and operations.

The manual is very complete and can serve as a model for commercial endeavors. To review the manual go to EMR 385-1-1.

For those interested particularly in fall protection, Appendix J deals with ladders, ramps, stairs and fixed ladders. The Corps requirements for ladder and hatch safety devices are met by GrabSafe and HatchGrip. For more information visit the ladder and hatch safety page on this website at GrabSafe and HatchSafe.

To review the letter adopting and describing the manual go to Directive by Michael J. Walsh, Colonel, Corps of Engineers, Chief of Staff.


Safety News Item – 11/26/04 – Fall Safety Regulations Around the World


Other cultures and countries place the responsibility for fall safety differently than we do in the USA. Consider the following passage from the novel “Digital Fortress” by Dan Brown:
“Hulohot moved quickly but carefully. The stairs were steep; tourists had died here. This was not America – no safety signs, no handrails, no insurance disclaimers. This was Spain. If you were stupid enough to fall, it was your own damn fault, regardless of who built the stairs.”
Opening page Chapter 100, page 346 paperback version.


Tip of the Week No. 43 – 10/18/04. OSHA 1926.500


The OSHA 1926.500 regulations offer a variety of choices for controlling fall hazards at construction sites. Because the general industry standard equivalent is similar, the 1926.500 standard may be fruitfully applied to general industry too.

See “Introduction to Fall Protection, 3rd Edition” page 312.
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07/16/04 – Safety News Item. China drafts tougher safety regulations.


China has one of the world’s worst safety records and government safety officials have now admitted that China’s work safety regulations are inadequate.
Corruption and a focus on profits at all costs have made China’s mines and industrial workplaces very dangerous, with little liability to those in charge.

The legisalation being drafted would target the individuals (including officials) that are found responsible for serious workplace accidents.

Occupational Safety and Health Reporter, vo. 34 No. 27 (BNA, Inc. publications).


Tip of the Week No. 27 – 06/14/04. Multiple workers at elevation.


Elevated work tasks that require more than one person to complete must be planned carefully. Most horizontal lifeline systems accommodate two or more workers. Independent lifelines may be suitable depending on available anchorage points and on the ability to keep the lines from entangling. For large numbers of workers, measures such as personnel nets, perimeter cable protection, or catch platforms might be more efficient means of guarding.

See “Introduction to Fall Protection, 3rd Edition” page 242.
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OSHA General Industry Fall Protection.


OSHA calls for comment of 1910 General Industry Fall Protection citing increase in fall deaths over the past decade since a proposal was introduced.

A limited re-opening of the 10 April 1990 proposal for general industry is scheduled for June and July ending 31 July 2003. See pages 23528 – 23568
Docket S-029 Walking Working Surfaces; Personal Protective Equipment (Fall Protection Systems), Proposed Rule which is downloadable from the OSHA web site.

Comments on the 62 questions raised may be sent by email on the www.osha.gov site by posting your information as directed. The brief list of questions can be emailed to you by request to dsc@FallSafety.com.


New Scaffold Regulation!


The new scaffold standard was published in the Federal Register August 30 1996.This is the first update of the 1926.451 standard for 25 years.

Look for the standard on the Links to OSHA on the DSC home page to take you directly to the preamble, general standard requirements and training for scaffolds.

Key features for the fall protection requirements for supported scaffolds in 1926.451(g)include the following:

  1. Crossbracing may substitute for the midrail or toprail (dimensions provided), but not both
  2. Guardrail systems must meet (g)(4)
  3. A competent person must determine feasibility for fall protection during erection and dismantling.
  4. Fall arrest systems must meet 1926.502(d)
  5. Portable ladders must meet Subpart X
  6. Trigger height for fall protection is 10 ft

For more information see the complete standard in this site’s Link to OSHA on the home page.


The Prohibition of Body Belts for Fall Arrest:


Body belts are known to be dangerous for fall arrest for over twenty years based on European publicity and standards changes. On 1 January 1998, the USA finally follows the industrialized countries with a ban on the use of waist belts or body belts for fall arresting purposes. The use of belts in aerial lifts is still recognized provided you can fall less than two feet out of the lift platform – now that is difficult!

The question of whether this ban applies to general industry is up in the air since the standards process was halted with the influx of Republican congressmen determined to go to bat for their constituents in late 1994. The smart move is to assume it does since who hires general contractors? Why general industry of course! Then how can an organization apply two standards? Answer – insist on harnesses. The next question is whether belts are allowed in harness designs? The answer is debatable but when belts assist in any way to arrest a fall, ………… well what do you think?? A partial belt in a fall arrest harness, in the form of back support, makes more sense for those who do work positioning.

More to come on this! Also banned January 1st are non-locking snap hooks for fall arrest or work positioning.


Introduction to Fall Protection, 4th Edition #20


Tip of the Week No. 248:
If an employer meets the criteria of a creating, controlling, exposing, or correcting employer, or any combination of them, it has safety and health obligations under OSHA’s regulations. The nature of its obligations varies, to some degree, with its role.
Excerpt from Chapter 3 – Who Needs Fall Protection? Introduction to Fall Protection, 4th Edition. Watch this website for more information about the publication date and how you can order your copy.


Introduction to Fall Protection, 4th Edition #26


Tip of the Week No. 254;
The test for determining controlling employer status is whether the employer “has general supervisory authority over the worksite, including the power to correct safety and health violations itself or require other to correct them.”
These factors must be viewed in the context of the actual construction situation. In almost all cases, some entity has general supervisory authority over the worksite. This authority often is given to a general contractor, although it is sometimes given to a construction manager or other type of entity.
Excerpt from Chapter 6 – Active Fall Protection Systems. Introduction to Fall Protection, 4th Edition. Watch this website for more information about the publication date and how you can order your copy.


Introduction to Fall Protection, 4th Edition #31


Tip of the Week No. 259:
The test for determining controlling employer status is whether the employer “has general supervisory authority over the worksite, including the power to correct safety and health violations itself or require others to correct them.”
These factors must be viewed in the context of the actual constructions situation. In almost all cases, some entity has general authority over the worksite. This authority often is given to a general contractor, although it is sometimes given to a construction manager or other type of entity.
Excerpt from Chapter 3 – Who Needs Fall Protection? Introduction to Fall Protection, 4th Edition. Watch this website for more information about the publication date and how you can order your copy.


Nigel’s Blog – Elimination of Construction Standard for Scaffolds


Currently, there are no construction standards for scaffold in place. We anticipate it will take 6-12 months to re-propose a new standard.
In the interim, the OSHA 1926.450-453 standards are fine as a substitute.
See the complet ANSI/ASSE Announcement of Administrative Withdrawal (2/25/2011) below:

SUBJECT: Administrative Withdrawal of 10 year overage standard:
ANSI/ASSE A10.8-2001, Safety Requirements for Scaffolding in Standards Action: 2/25/2011

According to ANSI’s records this standard expires on: 1/28/2011

The referenced standard will be announced in Standards Action as administratively withdrawn due to overage in accordance with clause 4.2.1.3.1 Administrative withdrawal, and clause 4.7.1 Periodic maintenance of American National Standards of the ANSI Essential Requirements: Due process requirements for American National Standards.

4.2.1.3.1 Administrative withdrawal reads:
An American National Standard shall be withdrawn five years following approval, if the standard has not been revised or reaffirmed, unless an extension has been granted by the ExSC or its designee. An American National Standard that has not been reaffirmed or revised within the five-year period, and that has been recommended for withdrawal by the ExSC or its designee, shall be withdrawn at the close of a 30-day public review notice in Standards Action. American National Standards that have not been revised or reaffirmed within ten years from the date of their approval as American National Standards shall be withdrawn and such action shall be announced in Standards Action.

4.7.1 Periodic maintenance of American National Standards in part reads:
No extension of time beyond ten years from the date of approval shall be granted for action on a standard. In no case shall a standard maintain its status as a current American National Standard beyond ten years from the date of approval. Such approval automatically expires on the tenth anniversary date of approval as an American National Standard.
In the event that an American National Standard approved by a standards developer who has been granted authority to designate its standards as American National Standards is not reaffirmed, revised, or withdrawn within five years after its approval, the standards developer shall follow its own procedures to ensure that work is proceeding and shall notify the Institute and provide the estimated time of completion. In no case shall a standard maintain its status as a current American National Standard beyond ten years from the date of approval. Such approval automatically expires on the tenth anniversary date of approval as an American National Standard.

This administrative withdrawal does not invalidate the ongoing revision or reaffirmation activity that may be currently underway. If the pending action on this standard cannot conclude by the standard’s tenth anniversary date of its approval as an American National Standard (ANS), then the effect is that the standard shall be administratively withdrawn. Should the standard be submitted for approval as an ANS after it has been administratively withdrawn, it shall be submitted and approved as a “new” American National Standard, and not a revision to or reaffirmation of an existing American National Standard.

If you believe that our records are in error and the standard listed have not passed their 10th anniversary of approval as an ANS, please contact the PSA Department immediately at psa@ansi.org or at 212-642-4908.

Thank you.


Nigel’s Blog – OSHA reverses on Fall Protection Snaphook Gate Strengths


On October 13th 2009 OSHA responded to a letter saying that OSHA supported snaphook gate strength of 3600 lbs for construction fall protection use citing the standard ANSI Z359.1-2007 and stating that the general duty clause would be used for future compliance. This was a mighty change over 220 lbs compressive strength which had been the bane of the industry regarding damage during increasing use of large gate snaphooks (2-1/2 inch opening) but still being purchased despite the 2007 change in the general industry standard.

However, on September 30th 2010, OSHA reversed its decision saying that the correct standard to cite was ANSI A10.32-2004 for construction which only requires 220 lbs in compression strength but which still represents approximately 80% of fall protection snaphook connector sales in the USA. Even though a revision to A10.32 is pending and which includes adoption of the Z359 snaphook gate strengths, the slow nature of standards development means that it will be some time to get finished and approved by the ANSI A10 committee.

Large snaphook incidents with 220 lbs gates continue involving gates that jam open or fly-past the nose of the hook. User attachment into small boltholes or onto small angle irons on towers, cheater cable eyes or scaffold rosettes and other shapes found in industry and construction is common. The 220 lbs large snaphook gate is not reliable for use in industry or construction unless each anchor is designed to mate with no forcible snaphook gate contact. The 3600 lbs snaphook gates meeting Z359.12 appear to be strong enough to withstand non-engineered anchors to date.

Users are urged to move to the 3600 lbs gate strength as soon as possible regardless of the OSHA recission of the October 13th 2009 letter. Further standards development is needed to address snaphook nose strengths and minor-axis testing for multiple attachments to shore up the higher gate strength from certain applications that are common in various industries.

J. Nigel Ellis, Ph.D., CSP, P.E., CPE

Note: Copies of the OSHA interpretations are available upon request


Tip of the Week No. 344 – 12/24/2012 – Competent Person!!


According to OSHA regulations, “competent and qualified persons” are a necessary requirement for a fall protection progam. OSHA 1926.32 defines a Competent Person as: “a person who is capable of identifying existing and predictable hazards in the surroundings or identifying working conditions which are hazardous or dangerous to employees and who has authorization to take prompt corrective measures to eliminate them.”
See “Introduction to Fall Protection, 4th Edition” page 386.
Introduction to Fall Protection, 4th Edition now available for purchase. To order your copy call 1-800-372-7775 or order online at Introductionto Fall Protection, 4th Edition Orders.


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