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Twice a year, Vertical Access representatives attend meetings of the ANSI Z359 committee to assist in the creation and modernization of fall protection standards. The ANSI Z359 suite of standards addresses just about all forms of fall protection equipment (harnesses, carabiners, lanyards, fall arrestors, etc) and associated work practices (rope access, rescue, management of fall protection programs, etc). Before and after these meetings, we often field questions on the difference between ANSI and OSHA. This article provides a brief overview of the two organizations and the documents they produce.
Founded in 1918, the American National Standards Institute is a not-for-profit organization dedicated to promoting “voluntary consensus standards.” Those three words, “voluntary”, “consensus” and “standards” succinctly describe the documents that ANSI produces. ANSI’s primary mission is to facilitate standards that, when adhered to, set a level of quality and safety across an entire industry. These standards address everything from mold remediation, to transportation of nuclear materials, to bakery equipment and digital encryption. The standards are consensus based because they are written and agreed upon by many members across the entire applicable industry: manufacturers, end users, testing laboratories, etc. Lastly, the standards are voluntary in that ANSI has no enforcement power.
Technically speaking, ANSI itself does not develop standards. Instead, ANSI develops and administers the procedures by which other organizations can create the actual standards. ANSI will then accredit committees formed by other organizations and ultimately approve their documents as American National Standards. These independent organizations are referred to as the secretariats to the ANSI accredited committees. For example, the American Society of Safety Engineers (ASSE) acts as the secretariat to the ANSI Z359 Committee, the committee that Vertical Access serves on to create fall protection standards.
The Occupational Safety and Health Administration (OSHA) is a governmental agency that was created by Congress in 1971 as a subset of the Department of Labor. Contrary to ANSI, OSHA’s mission is to assure safe working conditions for employees by “setting and enforcing standards”. This enforcement aspect of OSHA is its primary distinction from ANSI. Many OSHA regulations address similar topics as ANSI standards (e.g. fall protection), but where ANSI standards are voluntary, OSHA regulations are law.
ANSI standards, however, can be adopted by OSHA and become law in two primary ways. Explicitly, OSHA can reference specific ANSI (or any other organization’s) standards in OSHA regulations. This is referred to as “incorporation by reference”. Implicitly, OSHA can require adherence to ANSI standards through the General Duty Clause, which states, “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards…” This clause allows OSHA to cite employers for hazardous conditions that are not directly addressed by OSHA, but are addressed by other industry standards.
To recap, ANSI is a private organization that creates voluntary standards, while OSHA is a regulatory government body that has the power to write ANSI standards into occupational law.
Eighty fall protection professionals representing the fall protection industry throughout the US and Canada gathered in Boulder, Colorado over three days in November to continue moving forward the Z359 fall protection code from the American National Standards Institute (ANSI). Kelly Streeter travels out to this meeting twice a year to take part in this consensus standard writing process. Vertical Access originally became involved in order to be an active subcommittee member of the Z359.8 group: Safety Requirements for Suspended Rope Systems. Chaired by Loui McCurley, representing the Society of Rope Access Technicians (SPRAT), the document is nearly ready to go to the full committee for ballot.
For the past year, Kelly has been the chairperson along with co-chair Steve Hudson, from PMI, of the Z359.9 subcommittee which is tasked with creating the standard for Personal Equipment for Protection Against Falls – Descending Devices. This standard reaches far beyond the world of industrial rope access as we know it at Vertical Access and includes six different types of descenders including devices that are intended solely for rescue purposes. The benefit of these meetings is not only to work on the Fall Protection Code, but also to connect with fall protection professionals outside of the Industrial Rope Access industry.
Kelly Streeter traveled to Boulder, CO during the week of March 21st to participate in the semiannual meeting of the American National Standards Institute (ANSI) Z359 Committee on Fall Protection. Vertical Access has been an active member of the Z359.8 subcommittee, which addresses Rope Access work practices, for more than 5 years. During the last meeting in November of 2010, Kelly was elected as the chairperson of the Z359.9 subcommittee on descending devices.
The Z359.9 subcommittee is lucky enough to have an excellent seed document from the Canadian Safety Association (CSA), which adopted the ISO 22159 Descending Devices document, with a few significant changes. The mandate of the subcommittee is to review the ISO document and to edit, where necessary, to reflect the ideal environment of equipment manufactures, testing and work at height in the United States.
The ISO document identifies eight different types of descenders by characteristics such as the presence or absence of an integral line or a panic brake. Whereas the CSA opted to exclude certain types of descenders, the ANSI subcommittee is hoping to include all of the types of descenders that are currently being used in general industry today. This community is wide and varied and includes consultants investigating and documenting buildings and structures, window washers, arborists and workers in both traditional and emerging power generation industries as well as in many general industry rescue applications. Our goal is to ensure that the testing requirements for individual devices and the training requirements for each type of device are specified so that workers can continue to descend safely in the workplace.
During our meeting in March we identified next steps.
- It was decided that a sub-sub committee would be created to concentrate on reviewing the 56 pages of testing specifications currently in the document.
- Editorial work will be completed so that units reflect the ANSI specified units of measure.
- Other subcommittees will be consulted to ensure that any conflicts between the Z359.9 subcommittee and other subcommittees (specifically Z359.2 on training and Z359.4 on rescue) are identified and resolved.
Our next conference call to discuss progress on these tasks is on May 18th at 1pm EST. If anyone is interested in joining in, please contact Kelly Streeter.
The Occupational Safety and Health Administration (OSHA) held a week long public hearing on OSHA’s Proposed Rule on Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems), Docket No. OSHA-2007-0072 last week. VA Partners Kent Diebolt and Kelly Streeter both provided testimony to the panel on the last day of the hearing. Kent’s presentation concentrated on the incredible safety record of Industrial Rope Access, as recorded by IRATA, the International Rope Access Trade Association. Kent provided several exhibits that will become a part of the permanent record, including standards and documents published by IRATA, the Society of Professional Rope Access Technicians (SPRAT) and ASTM.
Kelly’s testified on behalf of the American National Standards Institute (ANSI) Z359 committee in her role as the chairperson for the Z359.7 committee on the safety requirements of descending devices.
The goal of the testimony was to educate the panel as to the wide range of industries, equipment and techniques that are affected by the limitations contained in the proposed rule.
New safety standards are under development at ANSI and Vertical Access is a member of several subcommittees, including
ANSI Z359.17 Safety Requirements for Horizontal Lifelines for Personal Fall Arrest Systems
ANSI Z359.8 Safety Requirements for Suspended Rope Work
ANSI Z359.16 Safety Requirements for Descending Devices – learn more
The American National Standards Institute (ANSI) first published a fall protection standard for General Industry in 1992. That Standard, Z359.1, was titled, “The American National Standard Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components” and was designed to categorize and standardize the wide variety of fall protection equipment in the marketplace. The full ANSI Z359 Fall Protection Code was introduced in 2007 and currently has seventeen working subgroups, eight of which are approved and effective at this time:
ANSI Z359.0 – 2007 Definitions and Nomenclature Used for Fall Protection and Fall Arrest
ANSI Z359.1 – 2007 Safety Requirements for Personal Fall Arrest Systems, Subsystems and Components
ANSI Z359.2 – 2007 Minimum Requirement for a Comprehensive Managed Fall Protection Program
ANSI Z359.3 – 2007 Safety Requirements for Positioning and Travel Restrain Systems
ANSI Z359.4 – 2007 Safety Requirements for Assisted Rescue and Self-Rescue systems, Subsystems and Components
ANSI Z359.6 – 2009 Specifications and Design Requirements for Active Fall Protection Systems
ANSI Z350.12 – 2009 Connection Components for Personal Fall Arrest Systems
ANSI Z359.13 – 2009 Personal Energy Absorbers and Energy Absorbing Lanyards