When OSHA published its proposed rule for Walking-Working Surfaces and Fall Protection last year, it was the culmination of a regulatory project that’s been brewing for decades. For the members of the Fall Protection Group of the International Safety Equipment Association (ISEA), it was a mark of success in efforts to get the agency to focus on protecting workers from falls.
The OSHA proposal updates the general industry requirements for the use of fall protection (subpart D) and adds a fall protection section to the PPE standards in subpart I. Current subpart D standards date from the birth of OSHA in the early 70s, and proposed revisions in 1990 and 2003 stalled because they weren’t keeping up with technology.
In an effort to get OSHA to move forward on the fall protection rule, members of the Fall Protection Group came to Washington during 2007 and 2008 and lobbied Congress to spur OSHA to action. Their efforts resulted in letters from a congressman and a senator to the secretary of labor, urging the department to assign a high priority to the rule.
ISEA members were pleased to see the publication of the Walking-Working Surfaces proposed rule last May. In comments to the agency and testimony at a January 2011 public hearing, ISEA recognized the importance of “comprehensive, relevant and practical OSHA regulations” to protect workers from fall hazards.
The Fall Protection Group took a position that the OSHA rules should apply equally to anyone who works at height. Some employer groups are seeking blanket exemptions based on training, the work environment or the type of work being done. ISEA believes that these general exemptions are improper and unnecessary where there are technologically feasible, practical and affordable means of preventing fall injuries.
In its written comments, the group also cited numerous examples of modern technologies not mentioned in the proposal, and urged OSHA to review the current fall protection standards being developed by the ANSI Z359 committee, to ensure that its regulations match up with the voluntary standards that are used in the marketplace. OSHA still has a number of issues to wade through, as was made clear at the hearing. However, there is a light at the end of the tunnel. Assistant Secretary David Michaels has stated that a final Walking-Working Surfaces rule would be published in FY12.
ANSI standards for fall protection
ISEA’s support for voluntary standards comes from its membership and participation in the ANSI Z359 committee, which is developing component standards for what it calls the Fall Protection Code, and the ANSI A10 committee for safety in construction and demolition operations, which develops the A10.32 standard for fall protection in construction. The association is officially represented on these committees, and some member companies are individual members as well.
As an ANSI-accredited standards developing organization, ISEA understands the process by which all parties come together to reach consensus on a voluntary standard. The association combines this procedural knowledge with the technical and market expertise of its member companies to provide an efficient and effective way for manufacturers’ views to be heard and considered. By monitoring the development process of each standard, ISEA staff can ensure that comment deadlines are met, and that the ISEA position or vote reflects the consensus of the product group.
One issue in which the association has been especially active is the proposal for a standard for qualification and verification testing of fall protection products, which will be known as ANSI Z359.7. This standard would set uniform testing and lab accreditation requirements for all products that are marked as compliant with any of the other Z359 standards. Its purpose reflected concerns from users on the committee that there are products in the marketplace that do not meet the standards. However, early drafts contained requirements that would have been burdensome to manufacturers and difficult if not impossible to regulate, while offering no significant additional assurance of product quality or conformity.
ISEA and its members worked with other committee members to peel away confusing or contradictory requirements, explaining how fall protection equipment is tested and how manufacturers’ quality management systems assure ongoing product conformity. A breakthrough was reached when the project subgroup approved a manufacturer proposal to extend the mandatory recertification testing interval for products manufactured under a registered quality assurance program.
Market data and information
Will these new standards and regulations drive market growth? ISEA members have access to market programs that help them evaluate market trends, identify market opportunities and promote their products. Each quarter, participating companies report sales, in units and dollars, in five categories: systems, body wear, connective devices, anchorage connectors and confined space equipment. They then get a summary of the totals for each category. While these results do not reflect the entire industry, members find them valuable because they can track their own company’s results against the totals by quarter or year, and determine how their results compare with the trends. These reports are available only to participating ISEA member companies, and are never used for any other purpose.
The Fall Protection Group has also been revising its Use and Selection Guide for Fall Protection Equipment, to bring it up to date with standards and regulations. It expects to make the guide available online when it’s completed.
This combination of standards development, standards-related regulatory advocacy and market insight shows the value of the association in promoting members’ common interests and the broader interest of worker health and safety. ISEA Fall Protection Group members are united in their determination to extend the benefits of modern fall arrest technology to all workers and workplaces. For more information about the Fall Protection Group or any other ISEA activity, go to www.safetyequipment.org.