National Safety Stand Down
For the past several years, OSHA has promoted an annual National Safety Stand-Down. The focus of this year’s National Stand-Down was to raise awareness of preventing fall hazards in the construction industry. During the stand-down, employers and employees are asked to take a break in the work day to talk about issues related to fall protection, like ladder safety, scaffolding safety, and roof work safety. This year, the National Safety Stand-Down ran from May 2nd to the 6th. The reason that OSHA continues to promote the stand-down is that falls continue to be the leading cause of death in the construction industry, accounting for 337 out of 874 (39%) of the fatalities recorded in 2014 (the most current year for which statistics are available). The stand-down is a voluntary event, but it is a great opportunity for employers to discuss prevention measures concerning fall hazards faced by their employees.
One challenge encountered by the industrial painting industry is maintaining 100% fall protection while complying with 29 CFR 1926.502(d)(6)(iii), Fall Protection Systems Criteria and Practices. In the industrial painting industry, the most commonly used lanyard to achieve 100% fall protection is the dual lanyard. The dual lanyard has many applications, including providing the appropriate level of fall protection when workers are transitioning from a platform to a pic board. However, the industry continues to struggle with the challenge of safely transitioning from a retractable lanyard to an elevated platform or pic board.
Before we start talking about solutions or alternatives to this industry challenge, we need to consider the equipment that is involved. As mentioned above, the typical approach appears to be the use of a dual lanyard along with the retractable lanyard. The concern in this scenario is that both devices have a snap hook that is attached to the same dorsal dee-ring. To make the connection / disconnection accessible, a dee-ring extension is commonly used, and both snap rings are attached to that dee-ring. However, this practice does not appear to be in compliance with 29 CFR 1926.502(d)(6)(iii), which states that unless the snap hook is a locking type and designed for the connection, the snap hook shall not be engaged to a dee-ring to which another snap hook or connection is attached. Therefore, the question still remains – how do we stay in compliance with OSHA standards and achieve 100% fall protection when transitioning from a retractable lanyard to an elevated platform or pic board?
One potential solution entails the use of a three-legged lanyard that consists of one snap ring that ties into the dee-ring.
The three legs consist of the standard 6’ dual lanyard and a third leg that functions as a dee-ring extension. This system provides the user with the convenience of a dee-ring extension along with the versatility of a dual lanyard. This approach appears to conform to the requirements of 29 CFR 1926.502 (d)(6)(iii).
For more information on the benefits of this approach or any questions regarding fall protection, contact your Corporate Safety and Health Officer or a safety professional.