A tool is most effective when the user knows how to operate it properly, so it can achieve its intended purpose. This point is especially true when that tool is an element of a fall protection system, since misuse of that equipment can lead to a serious injury or fatality, and costly damage to the equipment itself.
Fall protection has historically been a top 10 OSHA citation and falls are a leading cause of fatalities in the construction industry. Employers can, however, take steps to reduce fall injuries and fatalities by understanding how to properly design, implement and use fall protection systems.
A peer-reviewed article by Craig Galecka, P.E., CSP, and Shawn Smith, CSP, titled “Fall Protection: Top 10 Misuses & What to Do About Them,” highlights common mistakes that are made when using fall protection equipment, and ways to avoid them.
1. Misuse of rebar snap hooks.
Also referred to as pelican hooks, large gates or form hooks, these types of equipment are frequently used because they are large and can connect to many objects. However, this equipment is only approved for specific configurations. Use outside of those configurations can present a hazard.
Rebar snap hooks are preferred by some since they eliminate the need for an additional anchorage connector. However, this can present a danger to users because the strength of the worker’s anchorage choice may be questionable or cause the snap hook to be loaded improperly. Furthermore, these types of hooks are designed larger in order to capture larger structures, and those structures may not be directly over the worker using the equipment.
The best way to mitigate potential misuse of rebar snap hooks and the like is to ensure that the anchorage connector D-ring is larger than the snap hook to avoid side loading of the snap hook. Since this is difficult to achieve, users are encouraged to use a small anchor snap to achieve the appropriate geometry.
If an employer opts to use rebar snap hooks, it should know the gate strength of those hooks and understand that some hooks will have two stress points that should align with the strongest points on the hook.
2. Inappropriate anchorage connections.
When selecting a lanyard, remember that most lanyards are not designed to accommodate being wrapped back upon themselves. Misusing a lanyard in this way risks both equipment failure due to improper gate loading or damage to the lanyard material from point loading.
Whether a lanyard is designed to be wrapped on itself, users must be aware of what the lanyard is wrapped around, be it piping, beams, a guardrail or ductwork, and whether its composition could create a sawing action.
To avoid misuse, there should be an unobstructed load path between the anchor and the potential fall path of the worker. In addition, use a simple beam strap or beam clamp designed as an anchorage connector to address concerns of sawing actions.
3. Insufficient anchorage strength.
For a fall protection system to be effective, the anchorage used must be strong enough to support the person wearing it. In many cases, workers think that connecting to anything on the building is better than not connecting at all. Without testing the anchorage strength, such a connection may not provide the proper support.
Furthermore, the weight of an anchor point can be deceiving since the protective coating can conceal the core material. You can use several methods to ensure that an anchorage is of appropriate strength:
- Train competent persons who supervise authorized persons to identify proper anchorages and be capable of judging that a noncertified anchorage has adequate strength.
- Use certified anchorages designed by a qualified person.
- Specify the equipment that will be used for each system and ensure that the anchorage is designed for different loading possibilities with 900 lb. and 1,350 lb. average arresting force lanyards.
Since the weight of individual users varies, the anchorage and overall system must be designed for the maximum weight of any potential users.
4. Anchoring below dorsal D-ring.
Another common misuse with regard to anchorage is workers anchoring below their feet. When this occurs, it increases free fall, potentially above the allowable limits of the equipment. Pushing equipment to its limits can cause the lanyard or anchorage to fail, or exceed the allowable force on the body, increasing the likelihood of a serious injury.
It’s important to keep in mind that even if the system arrests a fall, longer fall distance increases forces on the body, which can lead to serious injuries. To mitigate this issue, it is best to not anchor below the dorsal D-ring. Absent an alternative, a worker should use equipment such as a 12-ft free fall energy-absorbing lanyard or self-retracting lanyard that is rated for additional free fall. It’s important to note that the average arresting force for each of these lanyards is more than that of a standard version, and, as such the anchorage must be designed accordingly.
To mitigate this issue:
- Do not stand if it is not necessary to do so.
- Keep the center of gravity low to reduce free fall distance and fall potential energy.
- Use the correct equipment for the appropriate application (e.g., using 12-ft. free fall lanyard if the only anchorage option is below the dorsal D-ring).
5. Confusing twin-leg energy-absorbing and self-retracting devices.
Although these two devices are similar in both appearance and function, a common mistake is thinking that they are interchangeable. These devices are tested in different applications and conditions and should only be used in the manner for which they have been tested.
Furthermore, workers commonly misuse both types of lanyards by anchoring below the dorsal D-ring. This mistake has the potential to increase the arresting force of a fall up to 2,700 lb.
These tips can help workers avoid this problem:
- Ensure that the twin-leg energy-absorbing and self-retracting devices are tested in the manner to be used (e.g., testing for additional free fall if attached below dorsal D-ring).
- Don’t attach both legs to an anchorage. Always connect the unused leg to the non-load-bearing part of the harness via breakaway tab or specific lanyard parking element. Do not attach to a load-bearing part of a harness.
- Do not anchor both legs of lanyard at same height as this may increase arrest forces.
- Have a training self-retracting device unit available that can be disassembled so that users can learn its vulnerabilities and inner workings.
6. Using damaged and recalled equipment.
The wear and tear that equipment experiences over time impacts its effectiveness. From UV exposure to corrosion and everything in between, many factors can impact equipment condition.
To protect equipment against UV exposure, moisture and elements that can cause corrosion, it must be stored properly when not in use. In addition, users should be trained on what to look for when inspecting that equipment to ensure that it is in proper working order to operate safely.
To ensure that equipment is suitable for use:
- Have competent persons conduct detailed, comprehensive formal equipment inspections on at least an annual basis.
- Register the products in use to be aware of a product recalls or advisories. If products are not registered, ensure that the competent person annual equipment inspection includes reviewing product inventory against product recalls.
- Develop and maintain a relationship with a manufacturer, distributor, training entity or consultant organization to remain current on advisories and advances in technology.
- Store equipment in an environment that is as protected as possible.
7. Improper fit of equipment.
Even if equipment is in good condition, if not worn properly it presents hazards for users. For example, wearing gear loosely introduces more potential energy, which then becomes kinetic energy should a fall occur.
Other issues, such as the position of the dorsal D-ring or the chest retainer strap, can present significant hazards. If a dorsal D-ring is too high, it could hit the back of a worker’s head during a fall. If too low, the worker may be facing the ground after arrest, increasing the probability of suspension trauma. If a chest retainer strap is too high, it can choke the worker. If too low, it can pull apart and allow the worker to fall out of the harness.
To help ensure proper fit, perform a five-point fit check to assess these criteria:
1. D-ring between shoulder blades
2. Shoulder straps cannot be pulled off of the shoulders outward
3. Subpelvic strap under buttocks
4. Four fingers between leg straps and leg (but not able to pull away from leg)
5. General observation of harness fit, looking for potential issues such as twisted straps and loose leg straps to ensure symmetry
In addition to the fit of equipment itself, it’s important to examine the physical condition of workers when assigning tasks. This includes any underlying medical conditions such as hypertension, vertigo or previous back injuries. It’s important to engage with medical personnel to establish a medical clearance process for equipment users to properly control and mitigate medical risks.
8. Misuse of leading-edge self-retracting devices.
Working in a horizontal arrangement requires that only self-retracting lifelines (SRLs) designed for leading edge or that are edge rated be used. Furthermore, lack of an energy absorber between the edge point and the worker puts the worker at risk of receiving the full impact of the fall.
To avoid a leading-edge failure:
- Ensure that equipment that could go over a leading edge is rated for that type of use (e.g., SRL-LE).
- Use an edge protector to minimize the potential damage on lanyards going over an edge.
- Ensure that there is an energy absorber at the worker’s body to minimize the potential for additional forces on the body.
9. Not meeting warning line system requirements.
A common mistake among fall protection equipment is the use of warning line systems, exclusion zones and handrail systems that do not provide protection nor meet regulatory requirements.
In accordance with OSHA (2106a) 1910.29(d)(2), warning line systems must meet the following requirements:
- Located 34 to 39 in. off the surface (roof) and visible from 25 ft. away.
- Flagged every 6 ft.
- Tensile strength of 500 lb.
- Tip over force of 16 lb.
To avoid misuse of warning line systems, the roofing company should understand the requirements for warning line systems, use parachute or 550 cord for the warning line and label it “warning line system in use.”
10. Poorly designed horizontal lifelines.
While horizontal lifeline systems are thought of as a simple, low-cost fall protection solution, they are at times not designed properly. This can lead to overloading of the anchorage structure or cause someone who has fallen to hit the ground due to the increased anchorage system displacement.
The involvement of a qualified person is crucial to ensure that energy equations are considered and that the systems is designed, implemented and used properly. OSHA (2016b) 1910.140 (c)(11)(i) requires that a qualified person be involved in this process and that they:
- Specify all equipment components used in a horizontal lifeline system, including immediate anchorages, pass through devices and anchorage connectors.
- Develop detailed use and rescue procedures that provide design basis (e.g., number of users, maximum weight, clearance requirements, inspection requirements) to ensure that systems are not used outside the manner in which they were designed.
The key to addressing each of these issues is ensuring that users have the training and supervision to identify the proper equipment to use and how to use it so that they can do their jobs safely. Although organizations should strive to avoid putting workers in situations where they need fall protection systems, when those cases do arise, they should see that the systems in place are designed, implemented and used correctly.
Understanding Fall Protection
Our resources will help you properly design, implement and use fall protection systems.