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OSHA 1910SubpartIAppC

Personal fall protection guidelines

Subpart I

16 Questions & Answers
10 Interpretations

Questions & Answers

Under Appendix C to Subpart I of Part 1910 (Personal Fall Protection Systems Non‑Mandatory Guidelines), what planning should be done before installing anchorage points on a new building?

You should plan anchorage locations during the building design so suitable, strong anchorage points are available later for maintenance work. The Appendix recommends locating suitable anchorage points during construction and planning ahead to ensure later use for tasks like window cleaning; see Appendix C to Subpart I of Part 1910 and 1910.140. Practical steps include identifying load paths, specifying anchor strength and attachment details, and documenting anchor locations for future users.

Under 1910.140(c) and Appendix C, how should employers choose a fall protection system for corrosive or wet environments?

Choose equipment rated for the environment and avoid materials that will degrade or conduct electricity in that setting. Appendix C says employers should evaluate workplace conditions (acids, moisture, oil, grease, etc.) and select systems suited to those conditions; see Appendix C to Subpart I of Part 1910 and 1910.140(c). Actions to take:

  • Specify corrosion‑resistant connectors, coated wire rope, or synthetic lines where chemical or moisture exposure exists.
  • Avoid wire rope where electrical hazards may be present (Appendix C guidance).
  • Get manufacturer guidance or test data showing the component performance in the expected environment.

Under the testing considerations in Appendix C, must an employer rely on supplier test data before buying fall protection equipment?

Yes — employers should insist on recognized test performance data from the supplier, or otherwise perform their own testing. Appendix C recommends that before purchasing, employers obtain supplier test information showing the equipment meets 1910.140 criteria; if such data are not available, the employer should test the equipment to ensure compliance. Also consult Appendix D test methods where applicable (Appendix C guidance via 1910.140).

Under Appendix C component compatibility considerations, can you connect a lanyard between a harness and a self‑retracting decelerating device?

Generally no — do not connect a lanyard between a body harness and a self‑retracting decelerator unless the manufacturer specifically allows it. Appendix C warns that interchanging components can change system performance and specifically says a lanyard should not be connected between a harness and a self‑retracting deceleration device unless the manufacturer permits it, because that connection can create additional free fall that the system was not designed to arrest; see Appendix C to Subpart I of Part 1910 and 1910.140. Always follow manufacturer instructions and have a competent person evaluate component swaps.

Under Appendix C and 1910.140, is it acceptable to use a body belt for personal fall arrest?

No — body belts are not acceptable for personal fall arrest unless the system and component meet the applicable strength and performance requirements and the use is specifically permitted. Appendix C cautions that positioning components (like pole straps or rebar hooks) and older body belts should not be used in personal fall arrest systems unless they meet the strength and performance requirements of part 1910, including 1910.140. Where a full‑body harness is required by the equipment design or standard, use a harness that meets the manufacturer's and 1910.140 requirements.

Under 1910.30 and 1910.132 and Appendix C, what training must an employer provide before an employee uses a fall protection system?

Employers must train employees on the limits, proper anchoring and tie‑off, estimating free fall distance, methods of use, and inspection and storage before they use fall protection. Appendix C lists training elements and states employers must ensure employees are trained as required by 1910.30 and 1910.132; see Appendix C to Subpart I of Part 1910. Training topics include system limits, proper D‑ring use, free fall calculations (including elongation and deceleration), inspection, storage, and site‑specific hazards.

Under Appendix C inspection considerations, when must personal fall protection equipment be inspected and what defects require removal from service?

Inspect personal fall protection systems before initial use in each shift and immediately remove from service any component with cuts, tears, abrasions, mold, undue stretching, corrosion, distorted hooks, broken springs, unfitted buckle tongues, loose mountings, non‑functioning parts, or other deterioration. Appendix C requires pre‑shift inspections and lists specific damage conditions that mandate removal from service; see Appendix C to Subpart I of Part 1910 and 1910.140. Tag or destroy removed components to prevent reuse.

Under Appendix C(h) and 1910.140(c)(21), what rescue planning is required when using personal fall arrest systems?

Employers must provide for prompt rescue of an employee after a fall and evaluate whether rescue personnel or equipment (or self‑rescue devices) are needed because employees may be unable to self‑rescue. Appendix C stresses that as required by 1910.140(c)(21), employers must plan for prompt rescue, consider availability of ladders or rescue teams, and where appropriate provide devices that allow self‑rescue; see Appendix C to Subpart I of Part 1910. Also consider the OSHA letter on fall protection on low slope roofs for practical examples of when fall protection and rescue planning may be required.

Under Appendix C(i) and (j), how much does using a knot or tying around a sharp edge reduce lifeline strength, and what should employers do about it?

A knot in a lanyard or lifeline can reduce strength by 50% or more, and tying around rough or sharp edges can drastically damage lines; employers should avoid these tie‑offs or compensate by using stronger lines, reducing lanyard length, padding edges, or using engineered tie‑off devices. Appendix C warns that knots and rough/sharp tie‑offs greatly reduce strength and recommends alternatives such as [snaphook/D‑ring connections], steel cable tie‑offs, or abrasion‑resistant straps; see Appendix C to Subpart I of Part 1910 and 1910.140. If knots are used in emergencies, a competent or qualified person must inspect each knot to ensure it meets 1910.140 strength requirements.

Under Appendix C(j) and 1910.140(c)(3), must each worker on a vertical lifeline have their own lifeline?

Yes — each employee on a vertical lifeline must have a separate lifeline. Appendix C states that, as required by 1910.140(c)(3), each employee must have an individual lifeline when the lifeline is vertical because multiple tie‑offs to a single vertical lifeline can pull others during an arrest and cause falls; see Appendix C to Subpart I of Part 1910.

Under Appendix C(j) and related text, who must design horizontal lifelines and why?

A qualified person must design, install, and supervise use of horizontal lifelines because geometry and sag can greatly amplify loads and create complex forces. Appendix C explains that horizontal lifelines can be subjected to much larger loads depending on sag angle and elasticity, and therefore "must be designed, installed and used under the supervision of a qualified person"; see Appendix C to Subpart I of Part 1910 and 1910.140(c) Employers should test installed lifelines and anchors prior to use and increase lifeline and anchorage strength when multiple workers tie off to the same line.

Under 1910.140(c)(10) and Appendix C, what snaphook or carabiner connections must be avoided to prevent roll‑out?

Avoid direct connections of snaphooks or carabiners to webbing, rope, or horizontal lifelines; avoid two or more snaphooks on one D‑ring; avoid snaphooks connected to each other; and avoid mismatched dimensions that allow the gate to turn and depress unless the connector is specifically designed for that use. Appendix C lists the prohibited connections from 1910.140(c)(10) because they can cause roll‑out; see Appendix C to Subpart I of Part 1910. Use appropriate locking connectors designed for the intended connection.

Under 1910.140(d)(2) and Appendix C, what is the maximum allowed free fall distance and how should tie‑offs be located to meet it?

Personal fall arrest systems must be rigged so an employee cannot free fall more than 6 feet (1.8 m), and the tie‑off point should be at or above the harness connection to avoid added free fall. Appendix C reiterates the 1910.140(d)(2) requirement that free fall never exceed 6 feet, and explains that tying off to the walking‑working surface or too low will add free fall distance (for example, a 6‑ft lanyard plus harness drop), so locate anchors at or above the harness D‑ring and account for lanyard elongation and deceleration distances; see Appendix C to Subpart I of Part 1910.

Under Appendix C(o), how much lifeline should be left below a rope‑grab deceleration device, and why?

Leave a minimum of 12 feet (3.7 m) of lifeline below the securing point of a rope‑grab device (or extend the lifeline to the ground or next work level) to prevent the device from sliding off the end and letting the worker pass the end of the line. Appendix C states the 12‑foot recommendation and suggests terminating the line to prevent the rope‑grab from disengaging; see Appendix C to Subpart I of Part 1910 and consult the rope‑grab manufacturer for exact requirements.

Under Appendix C(k), what special considerations apply when tying off to an eye‑bolt?

Treat an eye‑bolt as strongest along its axis — its shear strength is much lower — and ensure the eye diameter and shape won't allow snaphook roll‑out. Appendix C warns that eye‑bolt strength is rated along the bolt axis and is greatly reduced when loaded at right angles, and employers should also avoid eye sizes or shapes that permit snaphook accidental disengagement (roll‑out); see Appendix C to Subpart I of Part 1910 and 1910.140. Use properly rated anchor hardware installed to manufacturer or design specifications.

Under Appendix C(n) and 1910.140(d)(2), how should employers account for lanyard elongation and deceleration device stopping distance when positioning work above hazards?

Employers must add lanyard stretch and deceleration device stopping distance to the free fall to calculate total fall distance and maintain enough clearance from lower obstructions so the employee will not strike anything before the fall is arrested. Appendix C explains that elongation and deceleration distance must be included with free fall when determining clearance and required fall‑arrest distance; see Appendix C to Subpart I of Part 1910 and 1910.140(d)(2). Obtain elongation and deceleration values from the manufacturer and add them to the planned free fall to determine safe anchorage height and clearance.