1. How does the new 1910 Subpart D – Walking Working Surfaces standard impact the use of fall protection?
2. What are some of the key points an employer should be aware of when selecting fall protection equipment?
3. Are there any future changes you are aware of that would impact the use or selection of fall protection.

Jason Giefer, 3M
The Walking Working Surface Regulation (WWSR) has various implications regarding the use of fall protection. The billboard industry is most impacted by the need for a fall protection system on fixed ladders as the “qualified climber” exception is phased out by the new standard. By November 19, 2018 all fixed ladders will be required to have protection.

Snap hooks on fall protection connectors, such as lanyards, must maintain a gate (latch) strength of 3,600lbs per the new WWSR. Employers must ensure workers who use personal fall protection and work in other specified high hazard situations are trained about fall hazards and fall protection equipment systems used.

When selecting fall-protection equipment, regulatory approvals and third-party testing should be a high-level consideration. Next, find equipment and related accessories appropriate for the work task. For example, climbing systems require use of a front (or sternal) D-ring. The best fitting, most comfortable harness is nearly useless without a front D-ring when climbing a ladder with a ladder climbing system. Finally, proper fit is paramount; get help from the manufacturer if questions arise.

The WWSR came to fruition after careful thought and deliberation. A wide-reaching regulation is not likely to arrive anytime soon. The American National Standards Institute (ANSI) has recently released standards for Climbing Ladder Fall Arrest Systems (FAS). If planning to incorporate Ladder Climbing Fall Arrest Systems, systems that comply to the current ANSI Z359.16 standard will help to ensure the latest safety enhancements are incorporated into the system purchased.

Jim Poage, Formetco
The new WWSR standard makes the use of fall protection equipment even more critical than it was in the past, especially concerning fixed ladders. Either a ladder safety device or the use of a stagger climbing method must be employed to protect workers if the fixed ladder climb distance exceeds 24 feet. The proper selection of fall prevention equipment along with training on the use of the equipment is required by an OSHA qualified person is necessary.

There are several areas that need to be considered when selecting fall-protection equipment. One is fit. One size does not fit all, and selecting equipment that has the ability to adjust to the user is critical. Also, limitations of equipment. One example of this is the use of self-rescue harnesses. On most of the harnesses, once the release pin is pulled, the user will descend until all of the Kevlar cord is unreeled or they stop the unreeling by standing up and removing the harness. Because there is no way to apply a brake during descent, it should be part of the employee use training to ensure the user knows when they can safety descend when performing self-rescue.

There are two areas the ANSI committee on fall protection are focusing; harnesses that lack adequate back belts, which would prevent reverse “roll out” from the harness when suspended; and improper use of Self Retracting Lanyards (SLRs). Many SLRs are not rated to be used in situations where the user has to attach to a cable or anchorage point below “D-ring” level. There have been tests performed that show the lanyard shearing off on impact.