In one of our previous articles, we discussed necessary steps to using fall protection equipment properly. The article was primarily based on remembering the fundamentals of fall protection, applying your jobsite analysis to both equipment and activities and taking a deeper dive into inspection. This month we are going to focus on equipment usage. Below are fundamental steps to be taken prior to each use.
We know that there are two levels of inspection required by law – the pre-use inspection and the competent person inspection. Employers are responsible for making sure their workers are trained and assessed for competency in the use and inspection of the equipment they will be using on the jobsite. This includes safety equipment. They must make sure their workers have read and understand the product information and have checked that the components in the system are compatible.
The competent person inspection is required to occur at least once per year but there may be additional inspections due to other contributing factors. If equipment is exposed to extreme working conditions, more frequent formal inspections may be required. The frequency of inspection is established by the company based on workplace conditions and the exposure time of the equipment. The competent person should perform the inspection following the procedures outlined above.
It is not enough to conduct the regularly scheduled competent person inspections. These inspections must be recorded as well. An inspection log should be created for all products so that the next person conducting the competent person inspection can check before each use to see that the previous inspection was performed . This is also a document that OSHA inspectors will want to see. In fact, it could become a critical piece of evidence should a worker face injuries on the job.
Equipment, including safety products, can deteriorate. When it has deteriorated to such an extent that it may put people at risk (or stop production in the case of operational equipment) it needs to be repaired. Be careful with safety equipment as it should only be maintained to the specific manufacturer’s instructions. The frequency of both repairs and maintenance should be determined through risk assessment.
If not properly maintained and inspected, the equipment could fail, posing a risk to the health and safety of the workers. Because safety equipment is relied upon to save the lives of those using it, a higher level of attention is crucial.
Unlike operational equipment, you cannot wait until safety equipment breaks down or fail to maintain it.
Manufacturer's instructions are required to describe what maintenance is needed to keep the equipment safe. These instructions should be followed always. When the instructions are not clear, contact the manufacturer and be cautious about getting your information from a third party. It is not always accurate. Maintenance on a less frequent basis than the manufacturer's recommendation should be subject to careful risk assessment and I recommend contacting the manufacturer and requesting written clarification. Most manufacturers will work directly with end users and provide clarification on a case-by-case basis.
You are not required to keep a maintenance log for most safety equipment because the majority of harnesses, lanyards, rope grabs, etc. are not designed and marketed for repair. Larger, more heavy duty high-risk equipment like mobile fall arrest systems and customized horizontal lifelines, even self-retracting lifelines can be repaired. Products like these should have maintenance logs in order to provide useful information for the future planning of maintenance, as well as informing maintenance personnel of the previous actions taken. If you have a maintenance log, you must keep it up-to-date.
When it comes to horizontal and mobile fall arrest systems, inspection should continue to be part of your regular routine. That means you should be inspecting prior to each use. The visual inspection of the equipment for wear, deterioration, and damage needs to be executed before each use. Unlike PPE, systems often include components like tensioners, eye bolts, shackles, a cable that connects to shock absorption devices and additional hardware. All these need to be routinely checked to the manufacturer’s specifications. Inspect for signs of wear, corrosion, pitting and proper connection. Whenever you determine structural damage or loose parts, the system immediately needs to be locked out of service and the service provider should be contacted. Some manufacturers require annual recertification for their products that must be followed if the system is to be considered compliant.
When it comes to self-retracting lifelines maintenance, in all circumstances, the maintenance has to be performed by the manufacturer or an authorized third party. To my knowledge, there are no products on the market where the manufacturer allows for repairs and/or recertification by the user unless they have taken the proper training and classes to become an independent authorized repair center. This is because cracking open the shell of the self-retracting lifeline and making changes to the braking system comes with massive liability for all parties involved. The process is critical to the functionality of the product, and the user’s life is at stake.
OSHA requirements and ANSI recommendations are limited to inspection and both bodies recommend that users follow the manufacturer’s instructions. As for our company, we instruct that any product that fails either the competent person or pre-use inspection be removed from service immediately. If the product has failed any aspect of the inspection and been properly removed from service then re-certification is advised.
I hope this follow up on service and maintenance has been helpful. If anyone has comments or questions, please do not hesitate to reach out to me directly.
Ken Hebert Bio
Ken Hebert is the Co-Founder and National Sales Manager of Malta Dynamics and a customer-focused professional who has spent over 20 years in the safety and training industry. To view the safety products his company has created to help keep people safe, visit Malta Dynamics’ website at maltadynamics.com. To receive his free e-newsletter or to speak with Ken about technical safety issues or about Malta Dynamics products, Ken can be reached at firstname.lastname@example.org or call 832-683-6218.