Over the last ten years we have seen an increase in two critical metrics in fall protection:
- The number of standards comprising the Z359 Code.
- The number of fatal workplace falls.
Have we created the most effective standards possible, or do we have an opportunity to improve?
With the proliferation of all manner of new Self-Retracting Devices, we are seeing new products encouraging old behaviors, and the injuries and fatalities continue to mount. In this webinar, we will examine together a combination of product classes, behaviors, and look for opportunities to qualify both product selections and practices in order to appreciate the safest outcomes.
Join Dan Henn, Vice Chairman of the ANSI/ASSP Z359 Accredited Standards Committee and VP Operations, Reliance Fall Protection as he covers:
- A Decade of Fall Fatalities: The Facts
- Understanding Testing vs. Using
- The Anatomy of a Z359 Product Standard
- Opportunities for Improvement
- A brief overview of Self Retracting Devices (SRL, SRL-R, SRL-LE)
- Practical Steps you can take
- Learning from history
- Final Thoughts
Jamie: Hello, and a warm welcome to everybody! We would like to wish everyone a good morning, a good afternoon, or a good evening, depending on where you are in the world today. My name is Jamie, and I'm one of the co-founders of Safeopedia.
Safeopedia’s mission is to support the EHS professionals, operational folks, any safety-minded individuals, with free safety information, tools and education. I'd like to extend a huge thank you to those professionals for the great work they do on a daily basis.
Just a quick reminder, the webinar is being recorded and we'll be sending out a link to the recording to everybody in just a few days. This webinar is for you, the audience, and we want to keep it interactive, so please get your questions into the GoToWebinar control panel as we go, and Dan will get to them at the end of the presentation.
Today, we're very proud to present, “Fatal Workplace Falls Are on the Rise: Understanding Equipment Testing vs. Field Use”. This Safeopedia webinar has been made possible by Reliance Fall Protection, a preferred manufacturer member of Safety Network. Safety Network demands excellence, so demand Safety Network.
It is now my pleasure to introduce to you today's presenter, Dan Henn. Dan is presently the Vice President of Operations for Reliance Fall Protection in Deer Park, Texas. He first realized his fear of heights at the age of 17 when an army drill instructor forced him to rappel off an 80-foot tower which looked like it was in imminent danger of collapse. His involvement in the fall protection industry was inevitable. Since 2003, Dan has been manufacturing fall protection products with a heavy emphasis on product development and laboratory operations. He has been a member of the ANSI/ASSP Z359 Accredited Standards Committee since 2011, and in the past has served as the chairman of the ISEA Fall Protection Product Group. Dan is currently serving as the vice chairman of the Z359 Accredited Standards Committee, chairman of the Z359.14 subgroup — that's a safety requirements for self-retracting devices — and is a member of both the Z359.18 subgroup and the Technical Review Committee. Dan has studied history at the California State University at Fullerton and has since alienated himself from countless friends and colleagues as a result of unsolicited lectures on the Crusades and World Wars I and II. In his free time, Dan will most likely be found exploring South Texas with other Harley Davidson enthusiasts, raising money for local charities with other miscreants in the biker community, or transferring funds to his 23-year-old son, Spencer, of whom he is enormously proud.
Now, we invite you to sit back, relax and enjoy the presentation. With that, Dan, please take it away.
Dan: Thank you, Jamie. Appreciate it. And folks, I hate to break it to you, but fatal workplace falls are on the rise. So, let's take a few moments trying to understand the difference between equipment testing and field use and how we can better equip our users to make good decisions with their products in the field.
Over the last 10 years, we've seen an increase in two critical metrics in fall protection: 1) the number of standards comprising the Z359 code, and 2) the number of fatal workplace falls. And the question I posed today is: Have we created the most effective standards possible, or do we have an opportunity to improve?
Over the last decade, we have seen increases every year in fall fatalities, excepting 2009 and 2015. And since 2008, fall fatalities have increased by over 27%. At the same time, Fall Protection PPE market has seen growth of 7-10% in each of the last 10 years. So, if we're flooding the market with more PPE, and as equipment is spread throughout the marketplace at a prolific rate, and if we've introduced new technologies and innovations, why are we continuing to see an increase and rise in fall fatalities and significant injuries?
First, we need to take a look at the manner in which these products are tested versus the manner in which they're used and determine whether or not there are steps we can take to improve the safety of the worker in the field. The testing requirements in a Z359 code are intended to do several things. First of all, they're going to establish basic factors of safety in terms of strength requirements and performance requirements. Then they're going to demonstrate the capability of a product and performance intended purpose through testing, and then ensure that key data and guidance is provided to the user so that good decisions can be made about the application of this equipment in the field.
So, it's important understand that testing is performed in a controlled environment, according to a detailed procedure, utilizing fixtures with calibrated equipment, and on structures with specific properties. However, when a product is used, it’s often used in uncontrolled environments, according to the user’s own understanding, utilizing whatever has been made available with whatever available anchorage they may choose on structures and the circumstances with innumerable variables and interferences. And if we look at the photograph in this slide, we can see a lot of different things going on here. We have multiple elevations with different means of ingress and egress. In some areas, we have protective rail, passive systems in place; in other areas, we do not. And if we look at just the complexity of the walking working surface itself, we have just a magnificent tripping hazard here all over the place. So, you know this is an environment in which a fall is virtually inevitable. And what steps can we take to control the environment in which we're working?
So, if we look at the way testing is conducted, we have a diagram here out of the Z359.14 standard illustrating the direct approach leading edge test. And we can see that it's a very unemotional atmosphere. Everything is spelled out, the dimensions are specified, and everything is exceptionally detailed and controlled. But if we look at one of these products in actual use, perhaps in a roofing environment, or here, in a structural steel environment, we’d see that there are different variables involved that aren't anticipated necessarily in the testing procedure. And particularly if we look at the photograph in the lower left hand corner and the worker on the right hand side, we see that the structure beneath him is considerably more complicated than the steel structure we're using to evaluate the efficacy of the leading edge device in the diagram. And contact with a structure of this complexity, with the fasteners and bolts in place, is going to introduce additional hazards to the lifeline cable when it makes contact with the structure that aren't necessarily ferreted out or vetted out in the testing procedure we use in the ANSI standard to evaluate the performance of these products.
So, before we continue this discussion, let's first understand the anatomy of a Z359 product standard. Section 1 will consist of the Scope, Purpose, Application, Exceptions and Interpretations, and this is essentially setting the tone for the standard and establishing objectives. Section 2 will deal with Definitions and nomenclature that are specific or peculiar to the individual standard. Then Section 3 will be composed of all the Requirements, and these requirements may be composition of the product, design of the product, materials that are used. And then obviously, our performance expectations will be established here as well. Then at Section 4, we will have the detailed Qualification Testing procedures. And keep in mind that these are basic procedures, and they are not necessarily all inclusive, as I just illustrated here a moment ago with the leading edge standard. It's very, very difficult to incorporate all of the imaginable hazards that could possibly exist for a product. But nevertheless, Section 4 is the part of the document that deals with that subject matter. Then at Section 5, we’ll deal with Markings and Instructions. Then in Section 6, User Inspection, Maintenance and Storage of Equipment. And then 7 is References or basically our bibliography. And what's important to note here — I've highlighted in red Section 6 — this is the only part of it, the Z359 product standard, that's actually going to be directed at the end-user as an audience. The remaining sessions are all directed at the manufacturing community and the laboratory community as our audience, and there's not a lot of really useful information in those parts of the standard that can be utilized to make decisions about the procurement or the application or the use of product in the field. So, more needs to be done here in order to communicate this type of information to the end user community through the standards as a vehicle.
We have a lot of opportunities for improvement here, and it's important to note that many steps have been taken. And if we look at the history of the Z359 standard, going back to 1992 when it was first published and then revised in 1999, it contains the sum total of the Z359 work product and covered the full spectrum of fall protection products and systems. So, everything was jammed into one document, and it was not terribly broad, nor was it terribly deep. So, the decision of the committee was to expand the body of work and to break it up into individual documents dealing with specific subject matter, whether it was administrative in nature, or whether it was directed at a specific product classification.
So, in 2007, four standards were published, the first being a revision of point one, which included the game changing gate strength requirements that we’re all probably very familiar with. And then three new standards were introduced. Z359.2 introduced requirements for Managed Fall Protection Programs. And to this day, it's the only standard written by the Z359 committee that actually has directed itself at the audience of the end user community. Then .3 and .4 were also published, establishing greater requirements for positioning and restraint systems and for rescue systems, respectively.
Then over the next several years, additional standards have been introduced, and these standards either address specific product classifications such as lanyards, harnesses, SRLsand things of that sort. And then we have a couple of other standards that have been developed, the first being .6, which is the Design Requirements for Active Fall Protection Systems. And this is a standard that's actually written at the engineering community. And then .7 was the Qualification and Verification Testing Standard, and that's basically the laboratory standard that's been introduced.
Additionally, since that time — I think it was published last year — Z359.1 is now no longer a product standard. All of that information has been removed, and it's basically a very, very detailed table of contents and guidance document that — has basically tied all of the individual Z359 standards together into a specific code. And that document helps to direct the user to, or the reader I should say, to the information they're looking for relative to what their concerns are with regard to fall protection, and it's covered in the Z359 code.
It’s important to note that the original Z359.1 document was exceptionally convoluted and did not delve deeply enough into the specifics of each product classification. And the effort that's been expended to create the individual product standards has been extraordinary and has resulted in more comprehensive requirements. And there's no question about that whatsoever. However, new products have been introduced, and they’re new behaviors and therefore new problems as well.
So, our next challenge is to examine the changes in technology as well as a result in changes in end user behavior and create standards that not only include refined product requirements, but also tools for the end user to ensure a better understanding relative to use and limitations of these products and systems in the field.
So, there are a variety of conditions that are not anticipated in the Z359 code or the product standards presently. And examples of these would be age conditioning of textiles. So, for example, when a harness or a lanyard or a webbing anchor strap is tested in a laboratory according to the Z359 code, it's in brand new condition. But what happens to these products over time in use when they're exposed to the elements, when they're exposed to abrasive contact and damage, and just simple wear and tear? And you know, what is the ultimate lifespan of these products? While individual manufacturers and laboratories may have conducted testing on their own to determine some of the answers to some of these questions, we don't have a broad array of data to support any direct answer to these questions.
If we look at tie-back and gate strength testing, almost all manufacturers offer some type of tie-back product, whether it's a lanyard or a self-retracting lanyard, and the hooks used for this purpose are typically of a higher gate strength, but there is no testing being done on connectors to establish the efficacy of these products, yet these products have been on the market for well over a decade. We need to incorporate requirements for those as well. If we look at mating or parachute style buckles which are very, very simple form of fastener for the full body harnesses and among the oldest type being used, they're always used in pairs to create a relationship of both fastening and tentioning. But that relationship isn't evaluated, and the standards are tested as individual components, that doesn't necessarily give us a good view of how effective these products are or are not. So, these are additional steps again we could take to provide better protections.
Suggest arc-flash considerations need to be taken into account. There's testing done under the ASTM standard, but there's no reference to that testing or any requirement for that testing for products that would be applicable. And then if we look at horizontal lifelines, there's been an effort over the last decade to create a horizontal lifeline standard, but it's been fraught with difficulty because of the many means and methods that exist for the creation and the design of horizontal lifeline systems. As a result, establishing consensus has been difficult. And quite frankly, it's been a rather political, politically charged environment in that particular subgroup. And you know, those barriers need to be broken in an effort to provide greater guidance to the end user community, and to the manufacturers as well.
Now, I want to really focus in on self-retracting devices today as a case study because I really do believe they pose the greatest danger to the end user community and represent the greatest opportunity for change and for the application of that change to change in additional product standards as well. And if we look at what's required in Z359.14 standard today, we have three established types of self-retracting device. We have the self-retracting lanyard, we have the self-tracking lanyards with integral rescue capability. We also have the self-retracting liners with leading edge capability. And among those, we have two established classes: the Class A and the Class B. The class A is one in which the maximum arresting force is limited to 1,800 lbs.; the average arresting force is limited to 1,350; and the arrest distance is limited to 24 inches. In the class B device, the maximum arresting force is limited to 1,800 lbs. The average arresting force is limited to 900 lbs., and the arrest distance is limited to 54 inches.
Now, it's been exceptionally confusing to the community, the Fall Protection community, over the last six years or so since the original standard was published. These Class A and B designations are not necessarily applicable to all types of self-retracting lanyards. They’re really only applicable to devices when they're used on an overhead anchorage. If we move it to an anchorage that is below the level of the dorsal D-ring during the fall arrest rigging, then these classes go completely out the window and are no longer applicable.
So, let's get a better understanding of what these established types look like. Here we have a photograph of a self-retracting lanyard in use as intended, mounted overhead and proximate to the working location. There is no free fall in this arrangement. So, we're going to have immediate activation as soon as a user begins to fall. And when the fall occurs, the cable is drawn out of the reel, the reel begins to spin, and we have the opportunity to create the locking engagement, at which point we go into the deceleration phase. So, we have very little acceleration in this event. And as a result, we should have very low forces in a short arrest distance. That's been the traditional advantage of the self-retracting lanyard.
If we look at the SRL, the SRL-R in use as intended. Most often they're used in confined space systems. And here we see again, an overhead anchorage with similar fall arrest performances and SRL, and the added value of the integral hoist for rescue should the worker become incapacitated.
The next type is the SRL-LE in use perhaps not as intended. Here it’s deck mounted, and we have an increased free fall naturally because of the lowered elevation of the anchorage. We have structural contact with the constituent line. We have increased clearance requirements as a result of both of these conditions, and we have the increased potential for swing fall. And what's interesting in this particular photograph, which is simply a non-commercial photograph I pulled off of Google, this is not actually an SRL-LE pictured in this scenario. This is a standard SRL, and were the user of this device to actually take a fall in these circumstances, there's a high probability that that cable would be severed, and he would go all the way to the next lower level at the ground below.
In this next picture, we have what I'm going to describe as a present time as an SRL-P, or a personal SRL. These are commonly used as a substitute these days for energy absorbing lanyards, sometimes referred to as a PFL or a “Personal Fall Limiter”. And these things products enjoy a better reputation than perhaps they deserve. And what I want to say about these devices right now and in an effort to create a better understanding is that, when we're using these devices on overhead anchorages, they're absolutely magical. They really are. They're spectacular alternatives to energy absorbing lanyards in those circumstances.
When we begin to select anchorages of lower elevation, particularly below the back of D-ring or at the foot level, these products are going to struggle to keep up with the capabilities of the energy absorbing lanyard. And one of the things that's not terribly well known is that in the ANSI Z359 standards, lanyards are expected to have a minimum strength of 5,000 lbs as an assembly, whereas self-retracting lanyards are only required to have a 3,000-lb strength as an assembly. So, as a result, SRLs by specification are 40%, weaker than lanyards. And generally speaking, because of the fact that they're tested in a very specific way, they don't have necessarily the same energy capacity that an energy absorbing lanyard may. So, many of these devices are not capable of dealing with any significant amount of free fall whatsoever.
So, if you look at the photograph I have shown here, we have devices rig for about a three- or four-foot free fall. And that's not necessarily going to be a good thing for the device. It's going to put additional pressure on it that it may not have been designed for. And in this particular case here as well, we see the workers tied off with both legs of the of the SRL being a dual headed unit. And it's important to note that devices of this type commonly have independent energy absorbers on each leg. And when we tie off with both as has been done in this scenario, what ends up happening is we put both energy absorbers in play, and it's going to take twice as much for us to deploy those energy absorbers as it would to deploy just a single energy absorber.
So. if this fall were to occur, there's a very good chance that the forces involved with the fall could exceed the strength of the device and produce a failure. And this is all too common a practice in the field, I'm sorry to say.
Now, we're going to take just a short break here., and I want to illustrate the dangers of that pendulum fall or the swing fall type of scenario. This video is going to show a very common misuse of self-retracting devices and the risks associated with swing falls of that type. So, I play this, we watch what happens to the test dummy. We can see that it's a pretty extreme horizontal movement here and there's a great deal of acceleration going on there. The vertical drop isn't exceptional, but the horizontal movement is. I don't know if anybody watching was able to notice that there was a projectile that moved from the middle of the screen where the dummy made contact with the beam off to the right. But that projectile was in fact the amputation of the leg below the knee. So it's important to note that falls of this type are exceptionally violent and need to be avoided at all costs.
So, let's move forward and try to understand why we're focusing on SRLs today and what the danger is to the end user community, and what the opportunity is for us to make some real substantial improvements. If we look at the testing that was done on self-tracking devices, I'm showing two diagrams out of the Z359.14 standard. And these are two of the most informative tests that are being conducted. The test rigging on the left is the dynamic performance test of a self-retracting lanyard. And this is where the Class A and B designations come from. And in this test, the SRL is affixed to the drop tower and the transducer, three feet of line is pulled out and attached to the test weight, and the test weight is released. And once the test weight is released, the drum starts to turn, we have the opportunity to create the locking engagement, and then we have the deceleration phase.
So, it's important to note that there is no free fall in this event because the test weight is always under the tension of a line. And the moment that that test weight is released, that line is in movement coming out of the device creating the activation. So, it's important to compare this test to how we look at how energy absorbing lanyards are being tested. Because when we test energy absorbing lanyard, we're going to initiate a free fall of the test weight of either 6 or 12 feet according to the classification of the lanyard. Whereas when we're testing a self-retracting device, we're imparting a free fall of zero feet. So the introduction of energy is considerably less in this particular event than it would be when we're testing energy absorbing lanyard dynamically.
So, when we look at those Class A and B requirements, this is where they come from. So now imagine if I take a self-retracting device of the personal type, and I test it according to this diagram, and I get the performance data from that, and I give that to you as the end user, that's what you know about the capability of this device. Now, if you tie off to an anchorage that is 3 feet below your back D-ring, you're now introducing a free fall of somewhere between 4 and 5 feet, and the introduction of energy is much higher than this testing is going to subject that SRL to. So, I'm here to tell you is that the manufacturers haven't done additional testing beyond the scope of the Z359 standard, then we really don't have a full understanding of the capabilities of these devices and what their appropriate uses and limitations are.
If we focus now on the diagram on the left, which you've seen before already, this is the leading-edge test for the SRL-LE, and there are actually two tests that are conducted. There's one with a direct approach to leading edge, and then there is one with a five foot diagonal offsets to a guy with sliding effects. But what's important to note is that the steel edge used in this test has very specific properties. This could be an ASTM A108 steel bar, 3/8 inch thick, three inches wide, and the edge radius must not be greater than .005 inches, which is not quite as sharp as a number two paper clip. So, it's not really an exceptionally sharp edge to be perfectly honest. And we're using this substrate to suggest that the SRL-LE is protective in all circumstances. And I would like to suggest that's not necessarily the case.
So, let's examine some of the clear and present dangers we have relative to these devices. First and foremost, the Personal SRL, sometimes referred to as a fall limiter or personal fall limiter. It’s presently qualified in the manner of a traditional SRL. So, the only test for the ANSI standard says that any manufacturer has subjected to is that dynamic performance test I showed you a few moments ago with zero feet of free fall. Now, these SRLs have dissimilar strength characteristics when compared to lanyards which I described to you a few moments ago. And they do not have unique requirements or testing to the extent that lanyards do. These devices are susceptible to old behavior, which I'll describe here in a few moments.
If you look at the table, on this slide, you'll see two columns, one for energy absorbing lanyards and one for the SRL-P. And then we'll see a variety of different tests that are conducted in the ANSI Z359 standards such as Static Strength Testing, Dynamic Performance Testing, Dynamic Strength Testing, then we have Static Strength Wrap-Around, Static Strength Y, Dynamic Performance Testing For Y-Lanyards in a dual leg drop, Dynamic Performance Test For Hip Connection to a full body harness. And we see that the energy absorbing lanyards are subjected to nearly all of these, whereas the SRL-P is only required to go through less than half of these test procedures.
So, there are a whole lot of different things that we expect from an energy absorbing lanyard, and there are tests that we subject those lanyards to in order to evaluate their suitability. But those tests don't exist today for the personal SRL. So, my suggestion is that there's a little bit of you know, let the buyer beware going on here with respect to that because we haven't thoroughly vetted out the capabilities of these products by way of standards and detailed testing.
So, if you look at that old behavior I was discussing a moment ago, if we substitute the personal SRL for the energy absorbing lanyard, naturally it’s going to be subjected to the same behaviors. So, if we look at the gentleman in this photograph here, in the steel erection application, what kind of free fall do we expect to see here? Is this lanyard cable capable of withstanding the arrest forces? How about the anchorage sling? What kind of clearance are we going to need?
And I really want you to take a moment and just visualize the outcome of this potential fall and ask yourself how comfortable you are with this gentleman's safety in the present moment. And I want to suggest that if you look at the freefall distance here, we see he’s obviously tied off with a 6 ft. energy absorbing lanyard, and he's tied off to a cable anchorage sling, and it looks to be about 4 feet in overall length, or diameter, I should say. So, the free fall distance here is going to be approximately 10 feet, perhaps a little bit more. I'm sorry, I take it back — 12 and 4. It would be about 16 feet total. And then the deceleration distance at the end of that fall arrest event is going to be a little bit harder to determine, particularly since this particular lanyard isn't rated for a foot level tie off. If you look very closely, you can see it's of the PLY type, and these are really intended only for 6-foot freefall. So, this this particular fall event, were it to occur, it would not end well at all.
Now, the next question I'm going to ask is, what would it look like if you were using a personal SRL?
Here, we have an orange test dummy that used to weigh about 282 lbs. And it it’s shown suspended here next to the steel structure. And I'll tell you that is tied off with a personal SRL to a cable, cheater cable, much like we saw in the last photograph. And we're going to see what happens in these circumstances.
Not a successful fall arrest to be sure. And I'd hate to say it, but I've seen this behavior, this condition, in the field more times than I can count. And we can see very clearly, this is obviously a very, very dangerous condition.
Clear and Present Danger #2: The SRLs with Leading Edge Capability, or SRL-LEs, became a real phenomenon back in 2012 with the first publication of Z359.14. There are circumstances where devices of this type are absolutely necessary. There's no question about that. However, they really have become the opioids of fall protection. They’re overprescribed and too frequently misutilized. These devices require increased clearance, and they're not impervious to damage over a structural edge.
In this particular slide, we have a photograph of a marketing piece out of one of the safety magazines, and it depicts a self-retracting lanyard with leading edge capability anchored to a column, and the worker is walking away from it. And there are so many things wrong with this photograph that they're almost hard to sum up. But quite frankly, the anchorage sling around the column is not an appropriate anchor. It’s got the ability to slide down and migrate. It's not secure. And then of course, we're moving away, so we're creating that pendulum effect. And were the worker to follow this particular point, he’s going to have a free fall distance of approximately seven, eight, maybe even ten feet. And then at the end of that engagement, we're going to have some deceleration. So, there's a very, very strong probability that we’re going to have contact with the next lower level. And even if we don't, he's going to swing back into that column just like we saw the video a little bit earlier in this presentation. And this is a really, really terrible use of this particular product. And what's really puzzling is that we have a column on one end of this beam. There's obviously going to be a column at the opposite end of that beam. It would have been so very easy to run a temporary horizontal lifeline system to establish an overhead reversible anchorage. It would have been highly protective of the worker, and would have greatly reduced the fall distance and the opportunity for injury or fatality. So again, these devices have become kind of a quick fix or magic wand that we're waving at all of our problems. And while they're certainly useful in many circumstances, again, in way too many circumstances, they’re being used because they're inexpensive, and they're easy.
So, I ask the question: What does a leading edge fall looks like? And this particular video is a pretty good illustration of what we can expect to see happen to somebody during a leading edge fall. And while that's a successful fall arrest in that the end user didn't hit the ground, we had contact with the structural edge that we were tied off to on the way down, as well as this beam, which was an interference in the fall path. And as a result, we've imparted on this dummy several pretty serious injuries. And were this alive human being, this person obviously would not be going to work anytime soon. So, tying off at the foot level and making a leading edge approach or approaching an unprotected edge is not necessarily safe behavior. And this type of work should be done only as a last resort.
Now the third Clear and Present Danger that keeps me up at night is, we take the SRL-LE, and we marry it to the SRL-P, and we make it into a personal device. It’s important to note these personal devices are typically more susceptible to damage than their bigger cousins because typically on the larger devices, we're going to increase the diameter of the cable to get more strength to protect its net cutting and abrasion. But the smaller devices are required to use a smaller cable, but we simply can't run the larger diameter cable around a smaller hub in order to make these things small enough and light enough to be wearable. So, they also require considerable clearance because in order to protect that thinner cable, we have to have an energy absorber or a mechanism that is going to run that deceleration out a greater distance to make it a gentler event, lowering the forces because we have to protect the integrity of the wire rope or the webbing that are sometimes used in products of this type. So, as a result, I would say that the users of these devices may have a false sense of security. It's important to note that they typically require somewhere between 16 and 20 feet of clearance below the walking working surface to safely arrest the fall. I'd also submit that minor changes in the variables associated with a structural edge contact can make a tremendous difference in the performance of the device.
In the video I'm about to show you, we’re testing a personal leading edge product that has legitimate ANSI Z359 credentials through an accredited laboratory. But in this particular test, the steel bar has been replaced with a steel bar that had an edge that had as a radius of only .010 inches, which is only half as severe as the edge that we use in the Z359 standard. So, we're dropping it on a duller edge, and we would expect a pretty good outcome. But the simple fact of the matter is, that variable had an effect on the system. And if we're not establishing standards and procedures to evaluate all of the known variables, we're not going to be able to predict all the possible outcomes.
So, how do we align testing with use? It's important to understand that we have multiple stakeholders in the field of safety, and each has a part to play, whether it be the Z359 Accredited Standards Committee, employers and safety professionals, all protection manufacturers, or individual end users. We, of the Z359 ASC, have to refine the standards. So, for example, with respects to Z359.14, on the left-hand side of the screen, you'll see the basic requirements today of the Class A and B devices and then of the three types. Going forward, what we're working on is establishing three new classes that are specifically aimed at energy capacity, or the capability of the device to deal with extremes of free fall and arrest load. And then we're looking at revising our three types to self-retracting lanyard, self-retracting lanyard for rescue, and self-retracting lanyard personal so that we have clarity among all three types of devices and all three classes. So, in this particular scenario, any of the three types can very easily be classified according to any of the three classes, and then it can be more appropriately prescribed for use to the end user.
Additionally, we're looking at testing and twin devices, evaluating the relationship and the interface between the full body harness and the SRL, increasing the test weight from 282 all the way up to 310, and simplifying retraction tension testing. And then most importantly, what we're doing is we're adding an end user appendix to the standard, which addresses specific issues of importance to the end user, including how to choose and use the product that's necessary for your application, and what kind of training needs to take place to properly arm the and user with information about what the use and limitations of these products are. And that appendix will be made available as a separate technical document at a much reduced cost so that we can get the end user community to have a greater access to this information, which will be prescriptive and useful to them in the future.
We, as manufacturers, must lead by example. By all means, we must innovate and come up with new solutions to problems that exist in the field. There's no question about that. But we must examine and vet them thoroughly. We must anticipate and test for misuse and unanticipated behaviors. We may not have thought that people are going to do the things that they're doing with our products, but once we see that that behavior exists and that those uses are being integrated, we have to go and determine whether or not we've done a good job of protecting the people who are using those products in that manner. We must incorporate known variables into our test protocols. If we know that variables exist in the workplace, we have to incorporate those into our testing. We must develop responsible marketing narratives. If we're going to show our products and use, we need to be able show them — we need to show them being used correctly. We must remember that selling is not training. If we educate our customers, in all likelihood they will buy. We must also qualify our customers — make sure that the customer is capable of utilizing this product appropriately. And if they’re not, then we need to help them develop that proficiency. And sometimes, “No” is the best thing we can tell our customers. If we know that a product is going to be misused or utilized in a manner that's unsafe for the worker, we need to attempt to influence the purchaser of that device to make a better choice.
How do we as employers and safety professionals align testing with use? Well, mainly by way of exercising our hierarchy of controls. We have this methodology and this philosophy, and we certainly know how to use it. And we know that prevention or elimination of the hazard is the best thing we can possibly do for the worker at risk. So, when we have the opportunity to do that, then that should be our first choice. Passive Fall Protection means are going to be the most effective fall protection means. Guardrails and barriers and things to prevent access to the hazard are obviously going to be far more effective than PPE. And when we have those opportunities, we should avail ourselves of those opportunities.
And finally, we get down into Active Fall Protection Systems. Travel restraint is the most effective means because it prevents, again, access to the hazard. And then we have our fall arrest products and systems. And at the very bottom of that, we have leading edge products which should be used only as a last resort because it introduces the highest level of risk possible for the individual worker at risk.
Additionally, we must choose the correct equipment for the application. We must elevate and identify our anchorages. And believe me, I'm going to tell you this, and this is an absolute fact: The higher the anchorage is, the better off the end user is going to be. It improves every measurable metric and fall arrest when we elevate that anchorage above the walking working surface. It reduces the free fall distance, the overall fall distance. And the higher the elevation will also reduce the potential for the pendulum or swing fall.
We must train our people, and we must train them effectively. And using Z359.2 is a great place to start. We must also utilize, adhere to, and disseminate product instructions. And I know every time I ask a group of users what happens to the product instructions, there's a chuckle and a shuffling of the feet and then a little murmuring that they go into the trash. And all too often that's the case. But there is life saving information in those documents. And quite frankly, that needs to be disseminated. We must observe work processes and behaviors. We must coach and remediate, and we must always feel comfortable enough to ask for help if we need it. We don't know what we don't know. And this is an important point, folks. And I'll tell you, even with my time in this business, there are people in the business that I reach out to, and I have questions because I don't always have all the answers. And we've got to get comfortable with being uncomfortable. And when we feel we don't have the right answers, we need to seek those out.
We, as users, have a part to play as well. We have a personal responsibility to know and understand our product and to seek knowledge and training, and then to use that product correctly and safely and consistently. We must produce — we have to do our work, and we have to do it safely. And if we're working at height, we need to move deliberately and carefully, and we need to be paying attention to our surroundings and be situationally aware. We must seek knowledge and clarification. We must inspect our equipment and critique our processes. We must select an elevated anchorage. We must visualize our outcomes. And I say that it's really important every time I tie off, I take a look at my surroundings, the proximity of my anchorage to my working location. And I look down, and I imagine is this system actually going to safely arrest my fall, or am I going to hit something on the way down? And if we don't take the time to do that, we're probably not going to have successful outcomes. So, visualization is a very, very important part of the process. And then finally, we must be willing to peer coach and to take constructive criticism.
This next slide I call “True Confessions of a Fall Protection Professional”, and it speaks directly to personal responsibility. I enjoy riding motorcycles. If you look at this photograph, what's wrong here? I'm wearing short sleeves, no leather, half helmet. If I choose comfort or convenience over safety, I can't complain about the results. I'm not going to be able to sue Harley Davidson just because I got road rash, and I was too lazy or it was too hot at South Texas to put on the proper gear. So, if I'm equipped with the knowledge, it’s my responsibility to apply that knowledge and to do it safely and sanely and I’m responsible for my own results.
The High Cost of the Status Quo. Joe Arrants was a young construction superintendent out in Medina, Washington, working on a bridge job. They were disassembling a concrete form. He was up on top of a wing wall, which was jammed. They had to cut one of the supporting rods loose. When they did, he slid down the wing wall and fell through a gap between the wing wall and the base of the form, and he’d been tied off with a cable SRL to the deck of the form and had a sliding free fall of approximately 12 feet. And that SRL cable severed over the edge, and he fell 60 feet to his death. And it was not a leading edge SRL, but I can tell you there is no leading edge SRL on the planet that would have saved his life that day because of the way he was tied off and the elevation of his working location versus the elevation of his anchorage. And it was a completely avoidable circumstance. There were overhead anchorages available. And this man could have gone home that day.
Next, Walter Burrows, also working in Washington. Passed away last year. Been working on top of a bridge gap, and he was tied off with a personal SRL to an anchorage about two feet above the walking working surface. And when he fell, the webbing of that SRL made contact with the concrete edge of the bridge gap and severed entirely. The energy absorber never even began to deploy, and he fell 35 feet to his death.
Finally, Brian James Daunt, aged 45, a very experienced steel erector. Was killed at a construction site in Bakersfield, California when he was tied off with a leading edge rated webbing personal SRL at the sub level and made contact with steel edge. The webbing was severed, and he went down well over 30 feet to his death as well. The simple fact of the matter is that, these behaviors associated with leading edge devices and personal SRLs particularly, are exceptionally hazardous, and the elevation of anchorage is the one thing that we can always do to make a better outcome possible. And in each of these three cases, if we had chosen an elevated anchorage instead of the anchorage that had been utilized, all three of these individuals would still be with us.
What can we learn from history? I think there's a reference to that in the bio that Jamie read earlier. Now I'm going to bore all of you with it. During World War II, the Navy tried to determine whether they needed to armor their aircraft to ensure they came back home. They ran an analysis where planes have been shot up and came up with this. Obviously, the places that needed to be armored were the wingtips, the central body, and the elevators. That's where the planes were getting all shot up. But Abraham Wald, the statistician disagreed. He thought they should better armor the nose area, the engines, mid body, which was crazy, of course. That's not where the planes were getting shot. Except Mr. Wald realized what the others didn't. What the Navy thought they had done was analyze where the aircraft was suffering the most damage. What they had actually done was analyze where the aircraft could suffer the most damage without catastrophic failure. They weren't looking at the whole sample set, only the survivors. So, meaning that all the aircraft that got shot down obviously had a different set of problems than the aircraft that made it home. So, the question is, quite frankly, do I really understand the problem or I just think I understand it?
Fall arrest is a very, very complicated area in the in the safety business, and it requires a great deal of critical thought. And the use of these products and this PPE isn't an automatic guarantee of safety. Quite frankly, the manner of use dictates the outcome very, very specifically. So, it's very, very important that we choose the product to match the application, and that we consider all of the variables involved with fall hazards in each individual work site and ensure that we’ve married up the correct solution to that problem.
Every worker at height is an accident waiting to happen. Just because you haven't experienced a bad fall doesn't mean that you won't. And we have to match the product or systems to the task and the hazard. Elevate your anchorages, visualize your outcomes, ask for help.
At this point, I'm going to stop and we're going to take questions, comments and remarks from the crowd.
Jamie: Great. Thank you, Dan. Thank you very much. Great presentation extremely educational. We very much appreciate you taking the time to put all this together.
Dan: Thank you! My pleasure.
Jamie: Very eye opening. Alright, yeah, the tons of questions. So, we'll get right at it. We'll start off with some questions that came in during the registration process. So, we'll start out with Leslie. Leslie asks, “I have to provide fall protection for owner operators of trucking trailers. FP (Fall Protection) for flat beds is relatively easy. How would I provide fall protection for soft cover trailers if, you know, I can't use or tie into the ceiling mounted lifeline? Fall protection is required at 4 feet in my state.”
Dan: Yeah, when we're talking about vehicular fall protection, it’s always going to be a very tricky, a tricky situation. And it really depends largely on our circumstances. If we're in a fixed facility and we have the opportunity to run rigid rail or rigid lifelines on the overhead structure, that's absolutely the best-case scenario. Short of that, mobile anchorage davits that are counter weighted are available. And, you know, these solutions do have some expense associated with them, but we've got to get something up above that vehicle in order to initiate that fall arrest as quickly as possible.
Jamie: Thank you, Dan. Alright, Gina has a question. “Is there an ideal choice SRL for across many applications or situations?”
Dan: You know, Gina, that’s a tough question, and, you know, I don't want to be too general on this. My answer to that is no. I really do like taking the toolbox approach to fall protection. You know, quite frankly, there's a reason why there's 20 different hammers, you know, hanging on the wall over Home Depot. You know, framing hammer doesn't make a very efficient finishing hammer, for example. So, we look at SRLs, you know, there are many that have specific intentions and purposes.
I will say that generally speaking, the SRLs of the leading edge variety tend to have more energy capacity than others. So, as a result, they do have the potential to be safer in many circumstances. But the overwhelming axe I have to grind with the products of that classification is that, they tend to encourage a lot of high-risk behavior because people believe that they're impervious to just about anything, and so I can use it anywhere and at any circumstance. So, while I'll also admit that the SRL-LEs tend to be a little bit more robust and have greater survivability, we have to be very, very careful with how they're applied and how the user is trained in the application of those products. So, if you have any question about SRLs, feel free to reach out to me. I'd be glad to kind of coach you up and direct you on that. But let’s try and match the product to the hazard in advance.
Jamie: Perfect. Alright, we'll take a question from the attendee audience here. So, Steve asks, “You started out by saying that fatalities and serious injuries are on the rise. Do you know which industries have the highest numbers, example roofing, structural steel, etc.?” Thanks, Steve.
Dan: Well, the roofers are usually pretty close to the head of the pack. In the steel erection environment, we tend to see safer conditions, or I should say safer behaviors in many cases. The steel erection numbers are much lower than we see throughout other sectors of construction. But in construction in general, comprised just under half of the fall fatalities in the US in 2018.
Jamie: Alright, I'm going to combine a couple of questions here. So, Scott and Rose are asking — so, Scott asked, “How do you measure how long to keep a harness before you have to replace it?” And then Rose, similar line, “Are monthly inspections required by the end users to ensure equipment is in good condition before it's used?” So, how do you know when to replace a harness, and when and how often do you inspect these harnesses?
Dan: Okay, good questions. Well, the user inspection should take place before each use. So that means daily or multiple times per day, and that's a requirement of the ANSI standards, and that’s an OSHA expectation as well. As far as the lifespan of a harness, it’s going to be entirely predicated on the condition of the harness. And the best reference for that is going to be the manufacturer’s instructions themselves, which will give you detailed inspection criteria for each prototype, but specifically gear harnesses, and we’ll tell you what to look for to determine serviceability or unserviceability. So, that would be the best place to go and look. And in my experience, a full body harness has got a lifespan in most environments of somewhere between 60 days and 24 months. And outside of that, unless you're a really clean indoor general industry environment, your full body harness will probably last a lot longer that and remain serviceable.
Jamie: Thanks, Dan. Here's an interesting question from Garth, “Why have building designers not realized that lack of hook points directly attributes to risk for injury?” Thank you, Garth.
Dan: I think it's just a delightful lack of awareness, I'm sorry to say. That would be the first factor. And then the second factor is going to be, you know, what are the owner’s expectations? The person that that that structure is being built for may be very concerned about cost and not want to be spending a lot of money integrating those fall arrest elements into the building. But the simple fact of the matter is that, that forward planning: A) reduces risk, and B) overall in the long term, reduces costs because quite frankly, it costs a lot more to go in and retrofit a building or a structure in hindsight than it does to plan ahead and build that in the beginning. So, you know, a lot of lot of time, trouble, life and limb could be saved by factoring everything in during the design phase. And again, it would give us the opportunity to demonstrate that hierarchy of controls and make sure that we either eliminate those fall hazards or introduce the passive means to prevent them.
Jamie: Awesome! Thanks, Dan. Here's a good question, and I'm hoping I say your name properly. Anyoureg asked, “Do you have any success case studies? If you can provide.”
Dan: Well, let me work on that. I mean, I could get into a lot of specific details with clients we've worked with and problems we've solved. The simple fact the matter is that, you know, the people who are really succeeding in creating good, safe work and height cultures are the ones that are being really, really critical of their own processes, and are, again, like we talked about just a moment ago, planning ahead before the job ever begins, taking a look at what the requirements of the of the job are going to be, and determining what steps they can take to create the safest environment possible before the first, you know, labor hours ever extended. That's what success looks like.
Jamie: Couldn't agree more. Alright here, Dan has a question, and maybe it's a, if you know or give your opinion, Dan. “Now, will OSHA join construction fall protection at six feet with general industry at four feet at some point, making it six feet across the board?”
Dan: That's real hard to say what OSHA is going to do, and OSHA doesn't move real fast as you know. Quite frankly, you know, Subpart M has been out there since the early 90s and, you know, has not undergone a significant change. So, I don't necessarily see OSHA necessarily aligning the construction in general industry standards. What I do see and if we talk about, you know, what does success look like, I see many people in both environments going directly to the forefoot trigger height even in construction in some cases. And quite frankly, if we, you know, kind of move down to the lowest common denominator, you know, it gives us the opportunity to have a greater impact.
Jamie: Great. Thanks, Dan. Let's see here. Paul has a question. “In fire department tower ladders or MEWP platforms, what type of SRL is recommended since connection points are at waist level?”
Dan: Yeah, I would not recommend the use of SRLs in MEWP platforms, unless we are at an established working location at height. But if we are utilizing an SRL as our primary connection the to the platform in the area lift, we're asking for trouble, because in travelling, if we hit a pothole or a bump of some kind and we have, you know, a catapulting effect, we're going to see an ejection. And that ejection is going to result in a serious injury. What we really like to recommend is utilizing a two-point restraint at the hip down to the anchorages below the control panel so that when traveling, the worker is restrained and kept in the basket. Then once they get to an elevation, we could further see them tie off with an energy absorbing lanyard to perform their work and have access.
But when looking at the personal self-retracting devices, many if not most of them are going to have an energy absorber that's adjacent to the anchorage end of the device. So, if a worker falls out of the basket, even while working at height, that energy absorber is isolated inside the basket and is not free to deploy without restriction. So, as a result, we're going to see higher arresting forces and a potential failure, catastrophic failure, of the self-retracting device. So, I strongly discourage in the, you know, most strong terms possible to use those devices in an application in any fixed ladder application. If we can get a full cable real SRL up on top of that ladder or up above that ladder, adjacent to it, then that's going to be an exceptionally good solution. But we certainly wouldn't want to make any kind of waist level connections on a fixed ladder.
Jamie: Awesome! Thanks, Dan. Lee has a really good questions, and Lee's asking for some comments on common practice. “Most users of the personal fall arrest equipment are left to selecting their own anchor points when working inside of a manufacturing facility, oftentimes choosing structural steel. Oftentimes, due to obstructions in the way, example conduit piping, HVAC, duct work, etc., this is what keeps me up at night. Any comment on this common practice?” Thank you.
Dan: That stuff kind of keeps me up at night, too, to be honest with you. You know, the best thing I can say is this, we've got to spend more time training people to make good decisions about how they're tying off. And I know it's much easier said than done, but the simple fact of the matter is that, you know, knowledge is information, and, you know, knowledge is power. And these guys are powerless. They don't know what they don't know. And if we don't take the time to show them, you know, what's advisable and what isn't advisable, and what the risk of those interferences are in terms of creating incompatibility, then, you know, we're not giving them what they need to get their job done properly. And, you know, I got to recognize as a process, it's going to take time to get somebody to understand all of the risks associated with the potential decisions that they're making. But this is where, you know, observation, coaching and peer coaching really become valuable tools. If we're not out there watching what these guys are doing, and, you know, occasionally stopping them and helping them make different decisions and explaining why the different decision is a good one, then, you know, we really don't have the have the opportunity to be effective. So, it really all comes down to training and engagement and repetition. And, you know, I wish there was a magic wand that we can wave at it, but I can't come up with anything better than that.
Jamie: Thanks, Dan. Alright, Robert has a question here. “Is there data or information one can refer to with regard to when self-rescue equipment is not value added? Here's the example: working at a height of 15 feet, tie off is at same level on top of the equipment, a buddy system is in effect, immediate, immediate are —and so a buddy system is in effect and the equipment has components that can be stood… that can be stood on. I am getting asked to allow for self-rescue, but I do not see the value add as they would most likely have hands on them in seconds and can stand on the side of the equipment. Thanks!”
Dan: Well, there's quite a bit to unpack there. What I'll just say is this that, in terms of rescue solutions in the fall protection market, we're not doing a good job there. And what I mean by that is that there are so many different circumstances in which, you know, the rescue of the worker is going to have to be facilitated. And more than likely, the most likely rescuer is going to be, again — he was talking about a buddy system — the guy standing next to the guy or gal who fell, right? And what can we do to put together systems that can be utilized in anger, with a minimum training or with a, you know, with good retention that are going to be effective?
If you look at a lot of the systems that are available that have, you know, complicated block and tackle and extension poles and all manner of components, where we have to select an anchorage, we have to make a connection to the user, now we can make the decision to, you know, cut their lanyard and then lower them down or potentially hold them up if there's a lot of moving parts there. And it creates a lot of complexity. And when we have all these falls occur, it's going to be an exciting event. You know, emotions are going to be running high, and you know, there's going to be some tension there. And how do we make sure that we have something that is foolproof, very simple to employ, and, you know, very, very effective and has redundant factors of safety? And I haven't seen any rescue systems in the marketplace that really impressed me on that level. And, you know, that's, that's what needs to be developed at some point. But I don't necessarily see anything that has been developed that is effective in that manner.
Now, there are some self-retracting devices that have integral rescue descenders that can be operated, and you know, those are good solutions in certain circumstances, provided we've got appropriate clearance and nothing in the way. And they can be automatic or triggered after the fact. And I certainly have some respect for those types of systems, but they're not necessarily going to be universally applicable just because of the high expense. The simple fact of the matter is that rescue is something that, you know, on the manufacturing and standards side of things. We've given a lot of lip service to it, but we haven't really done a lot of work to provide good effective solutions that “again, add value”. You know, simply the most common means of rescue in many of the locations where I'm visiting in my day to day is the area lift itself. You know, fly and airlift, pick the guy up and get them out of there.
And one last thing I want to throw out there. It just adds complexity to the topic of rescue is let's keep in mind that it's very, very likely that the person we're trying to rescue is going to be injured at conclusion of the fall, particularly as we see these, you know, foot level tie off and leading edge behaviors proliferating. So, if the injured — if the worker is injured, you know, self-rescue is probably not going to be an option. And even an assisted rescue is going to be very difficult because they may not be of very much assistance whatsoever.
So, I don't know if I did a very good job of answering his question, but I've got my contact information up on the screen, and if anybody has any follow up questions or wants some additional, you know, talk time, I'm certainly available.
Jamie: Awesome. Thank you, Dan. Yeah, and I do want to invite people. I see we're just past the top of the hour. We'll get a couple more questions in here just because most of everybody has hung on to the line. So, really appreciate that. But yeah, if you have a question after the fact, please, please reach out to Dan, reach out to anybody at Safeopedia. That would be the best to answer your questions.
So, let's see. Let's see. Steve has a question here. “How much do weather conditions affect the fall protection performance?”
Dan: Generally speaking, they shouldn't affect the performance of the fall protection equipment a great deal. There would be a few exceptions to that, you know. Obviously… Well, not obviously. I should say that most of the products that are covered by the Z359 code are put through testing after environmental conditioning. So, we will see wet conditions introduced, high heat, and then very, very cold conditions, usually somewhere in the vicinity of -30 to -40. And then we evaluate the dynamic performance, and there'll be some different limits established, but there are still reasonable limits of performance that are expected.
What I'll say is that synthetic materials, when wet, will tend to stretch a little bit more. So, for example, if we’re looking at synthetic horizontal lifelines, those probably aren't going to perform quite as well in the wet condition as they would in the dry. But in terms of heat and cold, it should not make a tremendous difference in the overall performance of the system. The beautiful part is, when we look at, you know, a properly utilized personal fall arrest system, we have, you know, multiple parts that are all doing something to contribute to the outcome. So, where the conditions may not favor one component, they may in fact favor another. So, on the whole, I don't worry about that a tremendous amount. I would say that, you know, obviously, extremes of temperature are things to consider. And if it's, if it's too hot for you, it's probably too hot for your equipment.
Jamie: Thanks, Dan. Alright, the final question winner goes to Steve. “Does Z359 cover fall protection devices used in conjunction with safety netting?”
Dan: Can you repeat the question?
Jamie: Yeah, sure. “Does Z359 cover fall protection devices used in conjunction with safety netting?”
Dan: I'm not quite sure what they're looking for there, but I'd say nothing associated with the safety netting system itself. That doesn't mean that Z359 products can be used in addition to safety netting, for example. It might be appropriate to be tied off adjacent to. But no, Z359 doesn't delve into that passive element.
Jamie: Perfect. Now, thank you, Dan. Alright, before we close out the webinar, Dan, do you have any final remarks?
Dan: No, I think I'm about remarked out. I will say thank you to everybody who attended, however, and thank you for having me here, Jamie.
Jamie: Yeah, it is absolutely our pleasure. And I second that. Thank you to the audience. Great turnout, really great questions. We know you have a choice of where to spend your time, so we are very grateful that you spend some of it with us today. Thank you so much. Thank you to the International Society for Fall Protection. Thank you, Dan, for putting this together, great presentation. Thank you to Reliance Fall Protection, Safety Network — great partner. Without you guys, you know, we couldn't keep this information free. And that's it.
Quick reminder: We will be sending out a link to the recording and the presentation in just a few days. So, with that, everybody, have a great weekend. Stay safe out there and just like Dan said, there is no magic wand, so understand what you're getting into and visualize what could happen and ask the questions. So, really appreciate it, everybody. Have a great weekend. Take care and stay safe!