Understanding Occupational Safety and Health Administration (OSHA) requirements and American National Standards Institute (ANSI) standards for fall protection, as well as identifying the risks of your jobsite and application through a comprehensive hazard assessment, are important factors in helping keep workers safe at height and choosing the proper PPE for your organization.

THE RIGHT FIT

Released in December 2024 and effective January 13, 2025, the revised standard clarifies the language around PPE fit. Specifically, 1926.95(c) now states that “Employers must ensure that all personal protective equipment: (1) Is of safe design and construction for the work to be performed; and (2) Is selected to ensure that it properly fits each affected employee.” Prior to the change, 1926.95(c) did not include the language about proper fit. 

In its December 2024 comments on the rule change, OSHA explained that “the proposed language appropriately clarifies employers’ obligations under the standard.”  According to OSHA, this is not a “substantive” change because it “has historically interpreted 1926.95 as requiring that PPE properly fit each employee, has published guidance to that effect, and has issued citations to employers in the construction industry who failed to provide properly fitting PPE.” However, the standard prior to the change did not explicitly state that PPE must properly fit. 

OSHA also cites the safety implications of improperly fitting PPE as a reason for being more explicit in this case, explaining that “Improperly fitting PPE may fail to provide any protection to an employee, reduce the effectiveness of protection, present additional hazards, or discourage employees from using such equipment in the workplace.”

In the notice of proposed rulemaking, OSHA explained that “proper fit” in the construction industry means that the PPE: 

  • “is the appropriate size to provide an employee with the necessary protection from hazards”; and
  • “does not create additional safety and health hazards arising from being either too small or too large.”

Some PPE products offer various sizes. It is important to choose appropriately sized protective gear to attain the best possible protection. One area where sizing comes into play is fall-protection harnesses.

UPDATES TO FALL ARREST

ANSI is a private, non-profit organization that administers and coordinates the U.S. voluntary standards and conformity assessment system. The American Society of Safety Professionals (ASSP) is a global association which supports occupational safety and health (OSH) professionals in their efforts to prevent workplace injuries, illnesses, and fatalities. Along with ANSI and a representative group of users, manufacturers, and other stakeholders, the ANSI/ASSP standards are developed. 

The latest edition of ANSI/ASSP Z359.14, published in July 2021, features several updates to Types, Classes, and Performance Requirements of Self-Retracting Devices (SRDs). Organizations may still have some questions about how these changes impact their PPE selection, as the deadline for manufacturers to comply with this edition was August 2023. 

Types: SRD “Types” are simply a way of helping the manufacturer determine what type of tests they should perform based on the SRD design. The 2021 updates have added a new type of SRD and removed another from the previous list.

Added: Type SRL-P. A device compact enough and approved by the manufacturer to be worn on a full-body harness.

Removed: Type SRL-LE. Now a type SRL—defining Leading Edge—is covered in the new classes of SRDs.

Classes: In the 2021 revision, Classes are now used to describe products for overhead only products (Class 1) and leading edge rated products (Class 2). These classes ultimately explain how much free fall the unit can handle and if it has been tested for a fall event over an edge.

New: Classes are separated as Class 1 and Class 2.

Removed: Classes A and B have been removed.

Performance Requirements: There are no longer multiple performance requirements depending on Class. SRDs must now comply with specific limits for Maximum Arrest Force, Average Arrest Force, and Maximum Arrest Distance.

PPE SELECTION ON YOUR JOBSITE

Conducting a comprehensive hazard assessment can be an important first step in selecting fall protection solutions. Determining the unique risks and concerns associated with your specific jobsite and application, and understanding the relevant OSHA requirements and ANSI standards, can help identify which fall harnesses, SRDs, and additional safety equipment and training may be right for your organization. Many—if not most—applications follow the “ABCs of Fall Protection” requiring an (A) Anchorage connector, (B) Body harness, and (C) Connecting device, such as an SRL or PFL. 

Considerations for Selecting Harnesses: Factors to consider may include potential hazards in the specific application—such as working at height, welding, or arc flash—and wearer comfort, mobility, and how easily the harness can be adjusted for a fit that lasts throughout the workday. In light of OSHA’s recent rule regarding PPE fit, identifying a manufacturer with a wider variety of size options may also be an important factor.

Considerations for Selecting SRDs: Considerations for SRDs can include distance from connection point and whether or not the device is designed for leading edge or non-leading edge. This is indicated by features such as color-coded housing or iconography, in addition to the Class shown on the product label. To help simplify PPE selection on the jobsite, safety managers may wish to seek out products with different color housings for SRDs certified for leading-edge versus non-leading-edge applications. This helps to simplify PPE selection on the jobsite. Application is another important consideration; for example, in cases where welding or arc flash are potential risks, specialized SRDs that are better suited to withstand these conditions are available.

On a final note, another important factor to consider in fall protection product selection is the anticipated timing and deadlines for when you may require those new products to be available on-site. In other words, you may need it now. Look for a manufacturer with a dedicated inventory of their latest and most popular products in place, with transparency around stock and order lead times, so you can help your team start the job on time with the proper equipment.

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Dennis Capizzi is senior marketing manager for fall protection PPE, MSA Safety Incorporated, a global leader in the development, manufacture, and supply of safety products that protect people and facility infrastructures. For more, visit www.msasafety.com.