Considerations for Selecting Fall Protection PPE

Understanding types and classes of SRDs, leading edge vs. non-leading edge, solutions for aerial lifts and more.

• By Dennis Capizzi
• Oct 15, 2024

Fall Protection continues to top OSHA’s list of the top 10 most frequently cited workplace standards, coming in at number one in 2023 for the 13th year in a row. OSHA 1926.501 addresses Fall Protection for the construction industry, requiring the use of guardrail systems, safety net systems or personal fall arrest systems for employees working at a height of 6 feet or more.

Separate from OSHA, the American National Standards Institute (ANSI) is a private, non-profit organization that administers and coordinates the U.S. voluntary standards and conformity assessment system. ANSI works in close collaboration with stakeholders from industry and government to identify and develop standards- and conformance-based solutions to national and global priorities.

ANSI Z359 fall protection and fall restraint standards address “fall protection equipment and systems for climbing, work positioning, fall arrest, rescue, evacuation and other fall hazards. These standards also address training, and how to identify and abate hazards to prevent injuries when working at height.”

OSHA often references these ANSI standards as providing guidance related to worker protection.

Understanding OSHA requirements and ANSI standards, along with identifying the risks of your jobsite and application through a comprehensive hazard assessment – and what OSHA and ANSI require for those specific applications – are factors in helping keep workers safe at height. The below considerations about fall protection ABCs, industry standards, leading edge vs. non-leading edge and other unique applications, are additional factors that may be beneficial to keep in mind when choosing proper PPE and safety equipment.

The ABCs of Fall Protection

Selecting proper fall protection begins with an understanding of the components of a personal fall arrest system, often referred to as the “ABCs of Fall Protection” including Anchor Points, Body Harnesses, and Connecting Devices. Whether you have worked in the construction industry for years or are new to the job, a refresher on the ABCs can help prepare you and your team for working at height.

• Anchor points. These are the foundation of any fall arrest system. Positioned securely on the structure being worked on, anchor points must be capable of supporting the considerable forces exerted during a fall. According to OSHA, there are two options when considering the strength of an anchor point: A non-certified anchor point should be able to withstand 5,000 pounds and does not need to be determined by a Qualified Person; a Certified Anchor Point does require analysis from a Qualified Person to determine if the structure can withstand two times the force at impact that will result from a fall, known as a safety factor of two.

• Body harnesses. Acting as the primary connection between the worker and the fall protection system, body harnesses help distribute the force of a fall across the more resilient parts of the body, such as the thighs, chest and shoulders. This distribution helps reduce the risk of injury. 

• Connecting devices: These include energy absorbing lanyards, self-retracting lifelines (SRLs) and personal fall limiters (PFLs), and serve as the link between the harness and the anchor point. Their flexibility and functionality help provide freedom of movement while working at height. 

Updates to ANSI Z359.14: Types, Classes, and Performance Requirements

Originally published in 2012 and updated in 2014, ANSI Z359.14 defines both types and classes of self- retracting devices (SRDs). The latest edition of Z359.14, published in July 2021, features several updates to Types, Classes, and Performance Requirements of SRDs, including:

• Types. SRD “Types” are simply a way of helping the manufacturer determine what type of tests they should perform based on the SRD design. The 2021 updates have added a new type of SRD and removed another from the previous list.

• New. Type SRL-P. A device compact enough and approved by the manufacturer to be worn on a full-body harness.
• Removed. Type SRL-LE. Now a type of SRL—defining Leading Edge – is covered in the new Classes of SRDs.

• Classes. Classes are now used to describe products for overhead only products (Class 1) and leading edge rated products (Class 2). These classes explain how much free fall the unit can handle and if the unit has been tested for a fall event over an edge.

• New. Classes are separated as Class 1 and Class 2.
• Removed. Classes A and B have been removed.

• Performance requirements. There are no longer multiple performance requirements depending on Class. SRDs must now comply with specific limits for Maximum Arrest Force, Average Arrest Force, and Maximum Arrest Distance.

The deadline for manufacturers to comply with the latest Z359.14 edition went into effect on August 1, 2023.

Leading Edge vs. Non-Leading Edge Applications

OSHA defines a leading edge as “the edge of a floor, roof, or formwork for a floor or other walking or working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed.”

Due to the nature of the work, installing a guardrail around the edge of a surface under construction may not be feasible. However, workers are required by OSHA to wear fall protection when approaching the unprotected “leading edge.”

Leading edge work adds additional considerations that users should be aware of when selecting fall protection:

• If a worker falls over the leading edge, the sharp edge can sever a lifeline on impact or from the worker swinging back and forth.
• The anchorage for leading edge applications is usually (though not always) below D-ring level, often at foot level, because there is not always an overhead, approved attachment point, such as a wall or ceiling joist, and the lower anchor point does not interfere with a worker’s arm movement.

Aerial and Scissor Lift Applications

Due to their mobility and flexibility, aerial lifts are sometimes preferred over ladders and scaffolding on many jobsites. Aerial lifts may be powered or manually operated, and they are still considered to be aerial lifts whether or not they can rotate around a primary vertical axis.

Both the OSHA General Industry regulation and the OSHA Construction regulation specifically require fall protection when working in aerial lifts.

• General Industry 1910.67(c)(2)(v): “A personal fall arrest or travel restraint system that meets the requirements in subpart I of this part shall be worn and attached to the boom or basket when working from an aerial lift.”

• Construction 1926.502(d): “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.”

Solutions for aerial lifts may include restraint lanyards, energy absorbing lanyards, and leading edge personal fall limiters.

A scissor lift operates much like an aerial lift—it is motorized and contains a basket from which workers can perform their jobs. However, the platform only goes up and down and cannot be articulated from side to side on a turntable. Per OSHA, this difference is significant enough that a scissor lift is not considered an aerial lift but, instead, a form of scaffolding. Since a scissor lift platform is designed with guard rails around the perimeter of the platform, OSHA generally allows work inside the basket without the added protection of a Personal Fall Arrest System (PFAS).

Despite this, many employers treat scissor lifts like aerial lifts, and choose to have their employees wear a PFAS when operating a scissor lift.

Choosing and Using Fall Protection PPE

Conducting a comprehensive hazard assessment can be an important step in choosing fall protection. Determining the unique risks and concerns associated with your specific jobsite and application, and understanding the relevant OSHA requirements and ANSI standards, can help identify which fall harnesses, SRDs, and additional safety equipment and training may be right for your organization. 

• Harnesses. An employer may consider factors including wearer comfort and mobility, as well as how easily the harness can be adjusted for a proper fit. A wider variety of size options may also be an important consideration, especially in light of OSHA’s recent rule proposal that would explicitly require that PPE fit workers properly.

• SRDs. An employer may consider devices with features such as color-coded housing or iconography, in addition to the Class shown on the product label, to help a user to determine whether the device is intended for leading edge or non-leading edge use (for example, green housing may signify leading edge, while gray signifies non-leading edge). An employer may also desire PFLs made with lightweight materials in a compact design, which may enable enhanced user mobility.

As a final note, training and proper use of the selected PPE help to maintain safety while working at height. National standards and state, provincial, and federal laws may require the user to be trained before using fall protection products. Reference to product user manuals may also be incorporated as part of a user safety training program that is appropriate for the user’s occupation. Employers often provide these instructions to users before use of the product and allow user to retain the instructions for ready reference. Employers may require the user to read, understand (or have explained), and follow all instructions, labels, markings and warnings supplied with the product and with those products intended for use in association with it.

This article originally appeared in the October 2024 issue of Occupational Health & Safety.