OSHA Letter Addresses Limits of Some Shock-Absorbing Lanyards

In a Letter of Interpretation dated Jan. 14, 2009, posted to the OSHA Web site Feb. 10, OSHA's Directorate of Construction Acting Director Noah Connell noted that some shock-absorbing lanyards are inadequate as fall protection in certain circumstances and therefore prohibited by the agency.

A question sent to OSHA focused on a particular shock-absorbing lanyard with a manufacturer-stipulated minimum anchor point elevation of 18.5 feet. The questioner wrote: "My concern centers around the fact that, when raising an employee from a work surface, or upon returning an employee to a work surface, the employee at times will be at elevations that are less than [18.5] feet. . . . Since at times the distance between a lift's work platform and a lower level will be less than [18.5] feet, does the manufacturer's instruction regarding the minimum anchor point elevation preclude its use as part of a fall protection system in an aerial lift?"

In answer, Connell noted that 29 CFR Section 1926.502(d)(16(iii) requires a personal fall arrest system to prevent employees from contacting a lower level, which the lanyard in question would not do at heights less than 18.5 feet. Furthermore, 29 CFR Section 1926.453(b)(2)(v) requires fall protection for employees in aerial lifts at lesser heights as well, he noted. "Since the fall protection system you describe would not meet the requirements of [Section] 1926.502(d)(16)(iii) under these conditions, it would be prohibited," he wrote.

Connell added that a variety of self-retracting lanyards are available for fall protection, some with an operating range of more than 100 feet and a capability of limiting a free-fall distance to less than two feet. If one of these type lanyards were used in the scenario described, with the lanyard rigged so that the free-fall distance of the employee in the aerial lift was limited to two feet, the system would meet the requirements of Section 1926.502(d)(16)(iii), he said. Connell cautioned, however, that the vertical and lateral loads that may be placed on an aerial lift in the event of an arrested fall must be considered. Load requirements for anchorages come into play when fall arrest systems in aerial lifts are anchored to the lift's boom or basket, and the length of the free fall permitted by a self-retracting lanyard may affect whether a personal fall arrest system complies with Section 1926.502(d)(15).

"The longer the fall, the greater the impact forces imparted to the system," Connell wrote. "Thus, the more free-fall allowed by the self-retracting lanyard, the greater the load imposed upon the aerial lift. Some aerial lifts may lack the capacity to withstand the vertical and lateral loads caused by an arrested fall. Therefore, the length of free fall permitted by the self-retracting lanyard must be such that the aerial lift is capable of maintaining a safety factor of at least two when it arrests a fall." Connell added that a restraint system using a body harness or body belt might be used instead of a personal fall arrest system if a self-retracting lanyard cannot be rigged to satisfy Section 1926.502(d)(15), as long as the system is rigged to prevent the employee from falling.

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