Does an employer have to keep records of inspections on fall arrest systems?
Falls are among the leading causes of workplace injury and death each year. With more than 7,700 cases in 2018 alone, the Occupational Safety and Health Administration (OSHA) consistently cites more companies for fall protection violations than any other issue.
Keeping Records of Inspections
When it comes to the need of keeping records of inspections of fall arrest systems, the quick answer is yes. The employer is required to have them written on paper or electronically. Along with having them written down, you are also required to have the records filed to prove that they were inspected.
What is a Personal Fall Arrest System?
OSHA defines a personal fall arrest system in standard 1910.140 as, “personal fall arrest system means a system used to arrest an employee in a fall from a walking-working surface. It consists of a body harness, anchorage, and connector. The means of connection may include a lanyard, deceleration device, lifeline, or a suitable combination of these.”
Most would classify a fall arrest system as several components working together to provide fall protection that are permanently or in long term use in a fixed position. Some examples include a rigid track overhead system inside of an aircraft hanger, a permanent horizontal lifeline system on a flat membrane roof or a vertical lifeline system attached to a fixed ladder. These systems are often exposed to elements for long periods of time making inspections very important.
What Qualifies Someone as a Competent Person?
A Competent Person needs to inspect, at minimum, your fall arrest systems annually. There are some questions as to whether it has to be a Competent Person that has to do the inspections or if a person trained by a Competent Person can do the inspections. It is always a good idea to err on the side of caution and have your Competent Person conduct the personal fall arrest system inspections.
OSHA defines a Competent Person as, “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them” [29 CFR 1926.32(f)]
Is Checking Equipment Annually Enough?
Employers should always consider environmental factors such as extreme weather, exposure to caustic or corrosive materials, and the frequency of use when determining whether an annual inspection of the fall protection system is sufficient for the safety of workers while using it.
It’s a good idea to keep a record of your daily inspections which are required as well. An annual inspection is the longest amount of time you can go between inspections on fall arrest systems. All complete inspections should be recorded, it is also a good idea, however not required, to keep a record of daily pre-use checks. Inspections can happen as often as the company would like.
Malta Dynamics has several inspection forms on our website that are free and printable. Some examples of inspection forms include; harness inspection form, SRL inspection form and lanyard inspection form. Those forms along with others can be found here.
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