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Fall Protection inspections and Competent Persons: An Inspection Journey
Working with fall protection equipment requires responsibility. Knowing how your equipment works and how to inspect your equipment is vital to a safe day working at heights. While all fall protection manufactures recommend a visual inspection prior to every use, OSHA requires an annual inspection of fall protection by a “competent person”.
What is a fall protection competent person?
A competent person is someone with formal training or ample experience with fall protection that an employer has deemed worthy of inspecting fall protection equipment and the removal of fall protection items that fail their inspection. Formal training often consists of 3 days of classes with a fall protection manufacture which entails the “A-B-C-D’s” (Anchorage, Bodywear, Connectors, and Decent) of fall protection as well as how to properly use/inspect each of these items to ensure they are in good working condition.
This blog will discuss what to look for on different pieces of fall protection while performing inspections and an explanation of why items that fail inspections are taken out of service.
When inspecting webbing, for example, a pass-through choker strap, you want to be sure there is no fraying or cuts on the webbing and that there is little to no foreign substances on the webbing. Tears or cuts in webbing will cause a loss in strength of the unit. In the event of the fall, a tear can turn into a catastrophic failure when dealing with forces greater than 800lbs. Foreign substances can also lead to losses in strengths. Caustic and acidic substance can degrade webbing and can lead to holes in material and significant loss in malleability which prevents the webbing from preforming as intended.
Steel is incorporated in almost every piece of fall protection equipment. When inspecting steel, the primary thing to look for is rust and corrosion. Rust can occur when steel is exposed water or the outdoors for long periods of time. Fall protection equipment that has any rust should be taken out of service. You may have heard someone say, “that is only surface rust” and doesn’t need to be taken out of service or it can be “rubbed off”; this is incorrect. Rust and corrosion are chemical reactions that take place on the steel. Without a microscope there is not a way to see how deep the rust has penetrated the steel. In every instance of inspecting fall protection equipment, it is wise to error on the side of caution and remove items that are debatably okay for use. Along with rust, you want to look for bends or distortions in the metal. Make sure that all moving parts on your equipment are moving freely in their correct positions.
Aluminum is often used in fall protection to make equipment lighter weight for the user. While aluminum is a high strength metal, there are different attributes to look for than steel when inspecting. Aluminum is a brittle metal and will not bend like steel; this means aluminum will crack as opposed to bend. These cracks can be small and hard to see so it is important to look closely at all aluminum parts. Small cracks can form from freezing temperatures or extended stress.
Cable is often used in self retracting lifelines (SRL’s), and horizontal Lifelines (HLL’s). Cable is the primary reason for an SRL to be taken out of service. Cable is composed of many strands of steel, working together, to create a strong, malleable tether from your bodywear to your anchor point. When inspecting, you are looking for frays, kinks, and corrosion. Even one strand of steel that is broken on your cable can affect the integrity of the cable. Kinks work in the same way. Bending a cable too far puts significant stress on the strands which can cause weak points in the cable. Corrosion and rust on cable is a serious safety concern as each individual strand can rust through completely in a short amount of time.
Harnesses are comprised of polyester webbing and should be treated much like the webbing section previously discussed checking for tears and foreign substances through the entire harness. Secondly, check your back D-ring for deformations, bends, and cracks. Check the chest and leg connections to make sure they are working properly and not rusty or corroded. If your harness has tongue buckle leg straps, check gromets are secured. Lastly, be sure to check manufacture data i.e., serial number and part number are easily definable.
There are several different attributes to look at when inspecting SRL’s and any one failure results in the unit being taken out of service. Firstly, you want to look at the snap hook. Snap hooks will often have load indicators built in to show the user that the piece has previously been involved in a fall or has had significant stress to the internal parts and cable. The load indicator will have a red ring that is exposed after the snap hook has been involved with a fall. (pictured below) Snap hooks will also have a spring-loaded gate, so it is important to check that the snap hook fully opens and closes, and the gate is not bent and lines up properly into its locked position.
If the snap hook is in good working condition, you want to move up to the cable. Pull out all the cable from the SRL housing, inspecting the condition of the cable as you pull. It is also important to check that the locking mechanism of the SRL is working properly by quickly pulling out cable to engage the pawls. If pulling the cable quickly does not engage the locking mechanism, there could be an internal issue and the unit should be taken out of service immediately sent to the manufacture for repair. Lastly once the cable is fully drawn out of the housing, be sure there is not a red indicator on the end of the cable. Seeing red at the end of the cable means the SRL could have been over-extended causing an internal pin to shear which prevents the cable from having too much stress on the swagged end of the cable. In this event you will also need to send the unit back to the manufacture for repair. Lastly, let the unit retract the cable, testing the locking mechanism intermittently. Make sure the unit retracts properly and does not allow slack. Slack can be caused by a worn-out power spring which is an integral part of the locking process. If slack is made while retracting, take the unit of service and send it for repair.
If the cable looks good and there are no frays, kinks or corrosion, the unit locks properly, and there is not a visible indicator at the end of the cable, then you can move to the housing. The housing keeps internal components together and out of the elements. When inspecting the housing, you want to verify all hardware is firmly in place and the housing does not have cracks or dents. Also, make sure the bushing that the cable passes through is not worn through to the housing. Hardware keeps everything in its correct position, even one missing screw can cause internal parts to shift and not work properly. Dents in the housing can cause the housing to contact spinning internal parts and cause friction which can lead to improper retraction. Lastly you want to verify that the model number, serial number, and manufacture date are easily readable on the unit. This data is need by the manufacture to facilitate repairs and notify customers of potential recalls and stop-use notification.
Inspections are necessary to create a safety culture within any business using fall protection and can ultimately be the difference between life and death. Being “better safe than sorry” is imperative to ensure an employee’s safety.