To reiterate, the ANSI Z359 Standard was approved on May 31, 2007. It was published in four components, as follows:
Here is a summary of our opinion of the major changes:
Z359 is expected to mandate a giant step forward from existing OSHA policy. Current OSHA policy has traditionally allowed certain specific industries (like the Construction Industry) to determine their own needs for fall protection. OSHA has always allowed a few industries to establish National Consensus Standards for their particular industries, however the potential expansion of that policy has been criticized by many safety professionals who have publicly decried the practice, claiming that OSHA should not expand on that practice by allowing the proverbial "mouse to design the mousetrap".
More Uniform Policies
With the new proposed regulations, a uniform policy for fall protection is anticipated for general industry with fewer exceptions. The Construction Industry and The Sports Industry (e.g. Mountaineering, Track and Field, etc.) are expected to be allowed to continue to set their own standards, where and when applicable, since they were specifically excluded from the recommendations of ANSI Z359.
Walking/working surfaces atop trains, trailers, rooftops and many other applications which were not necessarily considered OSHA violations in the past are widely expected to be incorporated into the new fall protection policies, eliminating many of the loopholes that have been accepted practices for certain industries in the past.
More Innovation & Creativity Will be Required
When we consider the overwhelming cost of the fall protection equipment that would be required to deliver 100% fall protection coverage over certain vast areas, such as trying to cover a 110 car long grain industry train which extends well over a mile in length, the grain industry's argument seems incredibly valid. But this is an example in which a reasonably effective compromise can be reached.
When you take a moment to consider the alternatives to full length coverage, it really isn't quite that cost prohibitive. Several major grain handling companies, for example, have already begun to address this issue by introducing policies that restrict people from climbing and walking on top of a long train of rail cars except where a more limited span of coverage may be affordably provided (see image above). Revised handling procedures will likely have to be introduced as well, but the compromise solution seems more practical and acceptable when it includes requiring those personnel accessing long trains to limit their travel to more limited but affordably protected areas.
A written rescue/retrieval policy must be provided to all employees who use a fall protection system. Within the previous OSHA policy, it was a requirement to establish a policy although it was not required to establish that policy in writing.
More Mandatory Requirements
Certain mandatory requirements for the design and manufacture of fall protection equipment have been established by ANSI to regulate the fall arrest equipment manufacturers. Several American companies have produced fall arrest systems that simply do not meet minimal ANSI standards for acceptable design, testing and installation. Minimal engineering and labeling criteria standards have now been established, although it remains to be seen how OSHA will regulate and enforce the recommendations of the ANSI Standards.
Historically, the larger manufacturers have typically conscientiously forced themselves to meet rigid design, manufacturing and testing standards, yet there are manufacturers who have successfully avoided any type of controls for years. Fall protection equipment manufacturers are watching OSHA closely to see if those systems that are built from cheap, substandard and virtually ineffective equipment will be removed from the market with the introduction of the new standards. With the new ANSI standards being clearly defined for compliant manufacturers, OSHA has an opportunity to establish certain basic manufacturing and testing procedures which should eliminate the installation of substandard equipment from the fall protection industry.
General Instructions in English will have to be provided by the equipment manufacturers for fall protection components and systems and shall be affixed to the equipment prior to shipment. Those instructions must include, among other data:
A competent person must inspect the fall protection equipment no less than annually. Documentation on annual inspections must be kept by the rescuers organization, which shall consist of no less than the identity of the equipment, inspection date, name of the competent person conducting the inspection, and the results of that inspection.
Training on harness suspension issues is required. Suspension trauma is the dangerous condition caused by poor blood circulation typically caused by an extended period of suspension in a harness. Fall victims are to be instructed to move their legs and try to push against a safe foothold, and fall victims should also try to raise their legs up as far and as often as possible toward a sitting position to facilitate circulation. Rescuers of fall arrest victims must be properly trained to address the issues of suspension trauma. New guidelines suggest keeping the victim in an upright position for 30 minutes, after which he is moved slowly and carefully to a kneeling position, then sitting, and finally to a prone position, after which the victim should be seen by a physician. This is done to avoid the sudden rush of blood to vital organs when a victim is removed from suspension. Rescuers should maintain documentary proof of their training procedures and their training sessions.