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Fall Protection Citation Prevention — Part 8

April 19, 2024
Do you know how OSHA differentiates between personal fall arrest systems, positioning device systems, and warning line systems?

29CFR 1926 Subpart M provides the requirements for fall protection. Subpart 1926.502 is the meat of Subpart M. It runs for several pages and covers 11 topics. Now we’ll give three more of them a closer look:

(d) Personal fall arrest systems

(e) Positioning device systems

(f) Warning line systems

Personal fall arrest systems

These systems are designed to stop a fall — not to prevent it. Most of the requirements here apply to the equipment itself. The employer needs to ensure that equipment purchased for personal fall arrest systems meets these criteria. These requirements aren’t strictly in sequence. Some requirements apply to equipment used for specific purposes. For example, on suspended scaffolds where horizontal lifelines may become vertical lifelines, the devices used to a horizontal lifeline must be capable of being locked in both directions [1926.502(d)(7)].

A few of the requirements apply to usage. For example, body belts, harnesses, and components shall be used only for employee protection (as fall arrest devices) and not for hoisting equipment [1926.502(d)(1)].

One often overlooked usage requirement is that if the equipment catches an employee (in OSHA jargon, “subjected to impact loading”), it must immediately be removed from service. It cannot be put back into service until it’s been inspected by a competent person and deemed suitable for service [1926.502(d)(1)].

Other requirements include prompt rescue of employees who cannot rescue themselves, inspection of equipment prior to use, and not attaching personal fall arrest systems to guardrails.

Positioning device systems

A personal fall arrest system is designed to stop a free fall while a positioning device is designed to prevent it. While there are 24 requirements for personal fall arrest systems, there are only 10 for positioning device systems. Some of the requirements are identical between the two. For example, using both of these systems only for fall protection and inspecting them before use.

One difference, and there are several, is while a personal fall arrest system typically uses a 6 ft lanyard and thus a 6 ft fall is assume if the employee’s waist is no higher than the attachment point, a positioning system limits the fall to 2 ft. The same proof-testing of the D-rings to 3,600 lb applies, however. Why 3,600 lb if nobody weighs that much? Because a fall is a dynamic load with high instantaneous forces.

Warning line systems

These aim to prevent falls by keeping people away from edges. You can think of them as virtual guardrails for roofs. They won’t actually stop your body, but they should alert your brain to keep your body back. They have to be at least 6 ft from the edge [1926.502(e)(1)(i)].

No employee is allowed in the area between a roof edge and a warning line unless actually performing roofing work in that area [1926.502(e)(3)].

There are only five major requirements in this subsection, but there’s a lot of text to go with them. As the focus is primarily on roofing work, which electricians don’t do, why should you care about warning line systems? You may encounter them on rooftops where you need to perform electrical work. You might be working on HVAC, solar, power distribution, security, lighting, or exhaust systems that have wiring and/or components on the roof. Installing guard rails on rooftops isn’t always feasible. And in some case, for example, when using a crane to set a new HVAC unit or transformer on the roof, such guardrails might be temporarily removed.

The bottom line for electricians is that if you see ropes, wires, or chains attached to stanchions on a roof, consider the other side a “don’t go there” zone. It is the duty of the employer to ensure electricians know this or they may get cited by OSHA. If you’re the electrician, you have a strong motivation to obey those warning lines.

About the Author

Mark Lamendola

Mark is an expert in maintenance management, having racked up an impressive track record during his time working in the field. He also has extensive knowledge of, and practical expertise with, the National Electrical Code (NEC). Through his consulting business, he provides articles and training materials on electrical topics, specializing in making difficult subjects easy to understand and focusing on the practical aspects of electrical work.

Prior to starting his own business, Mark served as the Technical Editor on EC&M for six years, worked three years in nuclear maintenance, six years as a contract project engineer/project manager, three years as a systems engineer, and three years in plant maintenance management.

Mark earned an AAS degree from Rock Valley College, a BSEET from Columbia Pacific University, and an MBA from Lake Erie College. He’s also completed several related certifications over the years and even was formerly licensed as a Master Electrician. He is a Senior Member of the IEEE and past Chairman of the Kansas City Chapters of both the IEEE and the IEEE Computer Society. Mark also served as the program director for, a board member of, and webmaster of, the Midwest Chapter of the 7x24 Exchange. He has also held memberships with the following organizations: NETA, NFPA, International Association of Webmasters, and Institute of Certified Professional Managers.

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