# Fall Protection No-No



## MNicolai

Found this disaster-in-waiting on a job site recently. Fall protection faux pas that appeared to be put in place by one of the subcontractors in a remote part of the campus, outdoors.

By my count there are at least four things done improperly here. Five if you consider that one of the rules of this site was all lanyards were to be self-retractable and a shock-absorbing lanyard shouldn't have been in-use.

Anyone want to venture a guess what the issues with this are?





(Before anyone asks, photo was taken after-hours while the user of this lift appeared to be long gone. I showed this photo to the construction manager for their team to appropriately address.)


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## rsmentele

I can think of two obvious issues...

Carabiners are not usually rated for weights required to deal with shock loads, also, this isn't a locking carabiner, it also doesn't even look like one approved for any sort of weight handling. In fact, that looks like one of the carabiners that is made to carry around cables.

Also, the attachment point is also not a proper point, it is not rated for any shock load/ fall arrest. The lanyard should always be attached to the manufacturer designed fall arrest attachment point. Knowing those types of lifts, that is just aluminum round stock (and thin walled at that) that weld is going to snap right away offering no fall protection, (if the 'Carabiner' doesn't fail first)


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## Colin

Yikes! Quicker to point out the correct things than the incorrect...

But anyway, last time I checked OSHA said a guard rail is generally considered adequate protection and the infamous "qualified person" should evaluate whether additional protection is needed. If the answer is yes (why not?) then a restraint system would be better than fall arrest, no?


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## porkchop

Colin said:


> Yikes! Quicker to point out the correct things than the incorrect...
> 
> But anyway, last time I checked OSHA said a guard rail is generally considered adequate protection and the infamous "qualified person" should evaluate whether additional protection is needed. If the answer is yes (why not?) then a restraint system would be better than fall arrest, no?



I've never never been told the guard rail is an acceptable anchorage point, and most lifts I've used specifically warn against it in the accompanying documentation. Many have a labeled anchorage point closer to mast that is stronger and closer to the lift's center of gravity.
I might agree that restraint could be an improvement as it prevents the person's body from leaving the lift bucket, but really that is the point of the guard rails to begin with.


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## techieman33

Colin said:


> Yikes! Quicker to point out the correct things than the incorrect...
> 
> But anyway, last time I checked OSHA said a guard rail is generally considered adequate protection and the infamous "qualified person" should evaluate whether additional protection is needed. If the answer is yes (why not?) then a restraint system would be better than fall arrest, no?




porkchop said:


> I've never never been told the guard rail is an acceptable anchorage point, and most lifts I've used specifically warn against it in the accompanying documentation. Many have a labeled anchorage point closer to mast that is stronger and closer to the lift's center of gravity.
> I might agree that restraint could be an improvement as it prevents the person's body from leaving the lift bucket, but really that is the point of the guard rails to begin with.



I think that Colin is saying this his understanding of things is that no harness is required at all. That the cage around the platform is enough protection. Not that it is safe to clip into the cage.


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## Colin

techieman33 said:


> I think that Colin is saying this his understanding of things is that no harness is required at all. That the cage around the platform is enough protection. Not that it is safe to clip into the cage.



Yes, that's what I was saying.

The rules are confusing, as usual, but there are OSHA letters that try to clarify. It's my understanding that you are required to be harnessed or belted to a restraint if in a boom type lift due to the tendency of a boom basket to bounce and possibly throw you over the railing. However, it seems that scissor or mast lifts don't fall under the same rule.


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## sk8rsdad

Rules vary by jurisdiction. The rule for mast or scissor lifts in Ontario states that a harness is required when moving laterally at work height above 3 metres, so going up and down does not require a harness, regardless of height.


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## Colin

Actually, reading all the OSHA standard interpretations and the ANSI standard A92.2 they are bizarrely coy about where mast lifts fit in. Plenty of clarity on scissor lifts falling under scaffold rules, but mast lifts aren't mentioned specifically, and in some OSHA responses to industry questions they even seem to overtly refuse to get into it. The only explicit info I've found on mast lifts comes from manufacturers, like here, where they do lump mast lifts in with scissor lifts.


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## masterelectrician2112

I'll point out another problem:
Whether a harness is required in that lift or not, that's no way to store the harness...


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## MNicolai

Seems we've hit most of the big concerns.

Here's my collection of issues:

1) The carabiner is wildly inappropriate for use as fall protection, but....
2) ...that aside, the gate of a carabiner used for fall protection must be closed and locked.
3) The guardrails are not suitable as fall protection lanyard attachment points. Sometimes one-man lifts have appropriate attachment points on the mast-side of the bucket that could be used for this. If the lift does not have a manufacturer-approved attachment point, the user should be connecting their self-retracting lanyard to structure above their work area.
4) Harness was left in the lift under the destructive UV rays of the sun.
5) As I said before, the construction manager wants everyone on the job site using self-retractable lanyards. Most of the working conditions on-site are within 12' of the ground, making shock-absorbing lanyards inappropriate and ineffective. A self-retracting lanyard will cease a fall much sooner and requires significantly less clearance between the user's working height and the ground.

The lift manufacturer is very explicit that a fall protection harness is not required in the one-man vertical mast lifts. However, it is a 100% fall protection job site for anyone working above 6' per the construction manager. If for some reason the lift doesn't have a suitable attachment point or no suitable structure is nearby to attach to, the appropriate course of action for the user would be to have the construction manager waive the requirement. Proceeding without their blessing or with an egregiously unsafe attachment point is grounds for being removed from the job site and sent home for the day.


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## Dionysus

MNicolai said:


> The lift manufacturer is very explicit that a fall protection harness is not required in the one-man vertical mast lifts. However, it is a 100% fall protection job site for anyone working above 6' per the construction manager. If for some reason the lift doesn't have a suitable attachment point or no suitable structure is nearby to attach to, the appropriate course of action for the user would be to have the construction manager waive the requirement. Proceeding without their blessing or with an egregiously unsafe attachment point is grounds for being removed from the job site and sent home for the day.



In a lift technically FALL PREVENTION or RESTRAINT is the name of the game as opposed to FALL ARREST, but I agree that 100% fall protection (as practicable) should always be observed. Technically in a lift you don't need a HARNESS, but a belt and restraint lanyard, even though the rail heights in lifts are sufficient for fall prevention you should be tied off. Not the rule everywhere, but it is here. However most inspectors insist on a full harness, some seem to want fall arrest (even though that is not going to help you more at all in a lift for a few reasons).

I like the idea of being attached to an SRL attached above the lift, but of course then you are unprotected until you can get the SRL up in the air and such. Still at 12' restraint to me is better than arrest. If you can't fall in the first place, you don't need to arrest a fall. The attachment points in lifts are more designed with restraint in mind, not arrest. Many I've seen are clearly not rated for arrest, and where it's located you are getting HURT. Better to restrain from fall with a non-shock-absorbing restraint lanyard (of the correct length for the lift) in my mind. Now in a situation where the lift can tip, being attached to a high point in the structure is by far the best....

Anyways yes very very wrong. Especially that 'biner. Too many workers don't seem to remember their fall arrest training and leave their harnesses exposed to the outdoors. Good on you bringing this to the attention of the supervisor. Then again that is exactly who should of spotted this.


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## StradivariusBone

Dionysus said:


> In a lift technically FALL PREVENTION or RESTRAINT is the name of the game as opposed to FALL ARREST



That's how I've always been taught. I fail to see the sense in using a fall arrest harness in a mast lift. However, a fall prevention restraint- one that has a lanyard short enough to prevent you from doing something really stupid (like climbing out of the bucket) makes more sense. 

Our Genie has a ring that is not rated for fall arrest in any way, however you could clip a shorter or retractable locking lanyard and it would prevent stupidity. This debate has come up often on the booth, but I have yet to see anything official from Genie that you can/should use a fall arrest harness in a mast lift. That being said, I'll eat crow if somebody can show otherwise.


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## Dionysus

StradivariusBone said:


> That's how I've always been taught. I fail to see the sense in using a fall arrest harness in a mast lift. However, a fall prevention restraint- one that has a lanyard short enough to prevent you from doing something really stupid (like climbing out of the bucket) makes more sense.
> 
> Our Genie has a ring that is not rated for fall arrest in any way, however you could clip a shorter or retractable locking lanyard and it would prevent stupidity. This debate has come up often on the booth, but I have yet to see anything official from Genie that you can/should use a fall arrest harness in a mast lift. That being said, I'll eat crow if somebody can show otherwise.



EXACTLY. Fall Prevention and Fall Restraint should always come first, Fall Arrest when neither of those can offer adequate protection or are not practical. 

I talked to someone at DBI/SALA (a trainer slash consultant) about this once and this is exactly the way he said it should be... But for some reason the MOL here wants people wearing fall arrest in lifts and it boggles my mind. Even the "green book" agrees with me. They even want you clipped off with fall arrest when driving a lift when fully "down". Yes I got caught driving a lift out of the way, just got a stern talking to thankfully. The fines here are very steep... And then you see some people up on a roof without harnesses. Of course if they get caught they'll never be able to pay the fine it would be so nasty, but there they are...

They just changed the rules here, but you have to go to "approved training" to find that out, which is not cheap so I haven't actually bothered. I think training for fall prevention and fall arrest should be free if required blanket across everyone. I guess thats just me though. But if you want things followed, and care SO MUCH about workers having the training...


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## StradivariusBone

We recently had an "approved training" after an incident where a untrained individual had an incident in a lift and insurance freaked out that we weren't following OSHA on training users of personnel lifts. However, the course was for scissor and boom lifts and the instructor had never even used a mast lift before. He was however very knowledgable on OSHA regs and industry standards. 

We noted that the ring on the Genie we were using in training would not support a free fall and he agreed, but then commented on the retractable locking lanyards and how that would stop you as soon as you began to fall, possibly before your force exceeded the limit of the point. However, it would not prevent you from climbing out of the bucket in the first place. I've been told our insurance company is the one who wants everyone in fall arrest regardless of the fall prevention used. 

They wanted to charge us for the training as well, but relented. At the very least that should be tax-deductible.


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## egilson1

So a few things I'll mention about PFAS in lifts relating to the picture. I will mention this is based on OSHA and limited to the U.S.

1. Based on OSHA and ANSI you are not allowed to connect one "connecting" device to another. So using the connector on the lanyard to attach to the larger carabiner is right out. Regardless of if that larger carabiner is appropriately rated for PFAS, which is is clearly not.

2.

MNicolai said:


> 3) The guardrails are not suitable as fall protection lanyard attachment points. Sometimes one-man lifts have appropriate attachment points on the mast-side of the bucket that could be used for this. If the lift does not have a manufacturer-approved attachment point, the user should be connecting their self-retracting lanyard to structure above their work area.


Attaching to the building structure while in a lift is a no-no. This is only permissible when transferring from a lift to structure or back, and then you have to maintain 100% tie off. The reasoning for this is should the lift happen to move for any reason you don't become the weakest link in a "Lift tethered to the building" chain. Imagine what would happen if your foot, leg, or arm became stuck in the lift as it moved away from the structure.

3. As has been mentioned, the key in lifts is not actually fall ARREST, but fall RESTRAINT. A short non-shock absorbing lanyard or self retractable life line connected to a belt is more appropriate than a 6' shock absorbing lanyard attached to a dorsal ring on a full body harness.

4. The letter of the OSHA law is fall restraint is needed in Boom lifts at all times. Scissor lifts are classified as movable scaffold as mentioned, so as long as the railings are in good working order, you do not need fall restraint. Man lifts such as the Genie AWP series are like scissor lifts in terms of fall restraint. Railings are good as long as they are "used" properly. The attachment point on them is for fall restraint not fall arrest so using the 6' lanyard and full body harness set up is not an acceptable solution.

5. Lets harp on the fall restraint vs. arrest thing a little more. If you us a fall arrest system in a left, you MUST have a written rescue plan as defined by ANSI Z359. And you have to train on the rescue plan. No such requirement for fall restraint. With the body belt and short lanyard/SRL there is never a fall, and no need to rescue a victim.

6. If the client requires a harness/belt in every lift, so be it. BP (British petroleum) has this requirement on ALL job sites, including when they do a corporate event. So fall restraint for everyone in anything that goes up that isn't a ladder. Just make sure your doing it the right way so that it actually will work to prevent injury.


As always, I am sure i forgot something so please ask questions. After 5 years of writing the PFAS standard for portable structures and becoming a Arial & scissor lift trainer I am sure things have leaked their way out of my noggin.

Regards,
Ethan


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## MNicolai

StradivariusBone said:


> This debate has come up often on the booth, but I have yet to see anything official from Genie that you can/should use a fall arrest harness in a mast lift. That being said, I'll eat crow if somebody can show otherwise.



See here: http://www.swt.usace.army.mil/Portals/41/docs/business/safety/genie.pdf


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## MNicolai

Side note to this discussion: One thing on fall arrest harnesses I don't see mentioned often. Whenever you put one on, you should empty your pockets. Knives, keys, screwdrivers, what have you -- in the event of a fall, you don't want anything in your pocket skewering you and possibly severing your femoral artery.


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## StradivariusBone

You should also make sure the straps are snug and correctly positioned at the bottom of the harness. One of the more exciting (read: horrifying) parts of the class was the instructor sharing a photo of someone who had taken the fall with certain "parts" taking the brunt of the shock load. Let's just say internal became external. 

The instructor took a disturbing amount of joy in seeing our reaction faces to that particular slide. :shock:


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## cmckeeman

Dionysus said:


> I like the idea of being attached to an SRL attached above the lift.


From my understanding, when working in a lift, OSHA doesn't want you clipping off to anything outside the lift.
Edit: I see someone else has already said this


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## Dionysus

cmckeeman said:


> From my understanding, when working in a lift, OSHA doesn't want you clipping off to anything outside the lift.


Very true. OSHA does not and for good reason. You can pull yourself out of the lift if you forget to unclip before moving. 
Then again not everyone falls under OSHA. OSHA does not apply to me.
Generally clipping off out of the lift is the last thing I would want anyone to do... very bad.


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## techieman33

MNicolai said:


> Side note to this discussion: One thing on fall arrest harnesses I don't see mentioned often. Whenever you put one on, you should empty your pockets. Knives, keys, screwdrivers, what have you -- in the event of a fall, you don't want anything in your pocket skewering you and possibly severing your femoral artery.



As a guy who spends most of his time on the ground I whole heartily agree with this for a different reason. I don't want something falling out of their pocket and landing on my head. We had a guy on one outdoor site drop something from his pocket two days in a row once, it was ridiculous. He spent the rest of the 1st day on the ground, the 2nd day they let him go up after he swore his pockets were empty, well they weren't. Luckily no one got hurt. He doesn't climb for that company anymore. 


StradivariusBone said:


> You should also make sure the straps are snug and correctly positioned at the bottom of the harness. One of the more exciting (read: horrifying) parts of the class was the instructor sharing a photo of someone who had taken the fall with certain "parts" taking the brunt of the shock load. Let's just say internal became external.
> 
> The instructor took a disturbing amount of joy in seeing our reaction faces to that particular slide. :shock:



The first time I put on a harness my boss at the time jerked me up by the harness to let me know a little what it would feel like. It wasn't a pleasant feeling.


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