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OSHA 1910SubpartIAppD

Fall protection test methods

Subpart I

21 Questions & Answers
10 Interpretations

Questions & Answers

Under Appendix D to Subpart I of 29 CFR 1910 — What is the purpose of the test methods in this appendix?

The appendix provides non-mandatory test procedures you can use to determine whether a personal fall protection system meets the performance criteria in paragraphs (d) and (e) of 1910.140.

  • These test methods are guidelines (not new regulatory requirements) but are intended to show how to evaluate personal fall arrest and positioning systems for compliance with 1910.140(d) and (e).
  • See the appendix title in Appendix D to Subpart I of Part 1910 for context and scope.

Under Appendix D to Subpart I of 29 CFR 1910 — What test weight specifications must I use for the strength and force tests?

Use the specific test weights given in the appendix: 300 pounds ±3 pounds (≈136.4 kg ±1.4 kg) for the strength test, and 220 pounds ±3 pounds (100 kg ±1.6 kg) for the lanyard force test (220 pounds ±2 pounds for other systems). See the appendix for exact tolerances. (Appendix D to Subpart I of Part 1910; 1910.140(d)).

  • The appendix also requires the test weight to be a rigid, metal cylindrical or torso-shaped object with a girth of 38 inches ±4 inches.

Under Appendix D to Subpart I of 29 CFR 1910 — How rigid must the fixed anchorage be for tests?

The fixed anchorage used in tests must be rigid and deflect no more than 0.04 inches (1 mm) when a 2,250‑pound (10 kN) force is applied. (Appendix D to Subpart I of Part 1910; 1910.140(d)).

  • This requirement ensures test results reflect the performance of the fall protection system rather than anchorage deformation.

Under Appendix D to Subpart I of 29 CFR 1910 — What lanyard length should be used when measuring free fall in lanyard system tests?

For lanyard system tests the lanyard length should be 6 feet ±2 inches (1.83 m ±5 cm) measured from the fixed anchorage to the harness attachment. (Appendix D to Subpart I of Part 1910; 1910.140(d)(2)).

  • Measure from the anchorage to the body-harness attachment point to set up the test.

Under Appendix D to Subpart I of 29 CFR 1910 — What free fall distance is used for the lanyard force test and when is a longer free fall rigging required?

The standard lanyard force test uses a 6 foot (1.83 m) free fall distance from anchorage level to hanging location for the 220‑pound test weight. If the system’s deceleration device does not automatically limit free fall to 2 feet or the connection distance exceeds 1 foot, the test weight should be rigged to free fall 7.5 feet (2.3 m) from a point 1.5 feet (46 cm) above the anchorage to a hanging location 6 feet below the anchorage. (Appendix D to Subpart I of Part 1910; 1910.140(d)(2)).

  • The rigging must allow an unobstructed fall (no interference or hitting the ground).

Under Appendix D to Subpart I of 29 CFR 1910 — How are deceleration devices with integral lifelines or self‑retracting lifelines tested?

Deceleration systems that automatically limit free fall to 2 feet or less should be tested with the test weight rigged to free fall 4 feet (1.22 m); for self‑retracting lifelines the test weight may be supported, the unit allowed to retract as in normal use, and then released so the device arrests the fall; force and deceleration distance are measured during that event. (Appendix D to Subpart I of Part 1910; see 1910.140(d)(2)(ii)).

  • The appendix explains how to simulate normal retraction and measure arresting forces and elongation for these devices.

Under Appendix D to Subpart I of 29 CFR 1910 — What maximum arresting force indicates failure during the force test when using a body harness?

A system fails the force test when the recorded maximum arresting force exceeds 2,520 pounds (11.2 kN) when using a body harness. (Appendix D to Subpart I of Part 1910; 1910.140(d)(4)).

  • The appendix also requires recording maximum elongation and deceleration distance during the test.

Under Appendix D to Subpart I of 29 CFR 1910 — How many drops and what condition of equipment are required for each test?

Each test consists of a single drop using a new, unused system; a fresh system must be used for each individual drop. (Appendix D to Subpart I of Part 1910; 1910.140(d)(1)).

  • This avoids repeated damage or altered performance affecting results.

Under Appendix D to Subpart I of 29 CFR 1910 — What are the test weight shape and girth requirements?

The test weight must be a rigid, metal cylindrical or torso‑shaped object with a girth of 38 inches ±4 inches (96 cm ±10 cm). (Appendix D to Subpart I of Part 1910; see the general test conditions).

Under Appendix D to Subpart I of 29 CFR 1910 — What instrumentation requirements are specified for measuring load during tests?

Load‑measuring instrumentation used in tests must have a frequency response of 120 Hz. (Appendix D to Subpart I of Part 1910).

  • Using proper instrumentation ensures accurate capture of short-duration arresting forces.

Under Appendix D to Subpart I of 29 CFR 1910 — When does a test constitute failure because of detachment?

If any weight detaches from the harness during the strength test, the system is judged to have failed. (Appendix D to Subpart I of Part 1910; see the strength test provisions).

Under Appendix D to Subpart I of 29 CFR 1910 — How should rope‑grab deceleration devices be tested for repeat locking performance?

Rope‑grab devices should be moved along a lifeline 1,000 times over the same length of line a distance of not less than 1 foot (30.5 cm), and the mechanism must lock each time; unless the device is permanently marked for a specific lifeline type, several lifeline types (different diameters/materials) should be used in testing. (Appendix D to Subpart I of Part 1910; 1910.140(e)(2)).

  • This confirms reliable locking across expected lifeline conditions.

Under Appendix D to Subpart I of 29 CFR 1910 — How are self‑activating deceleration devices designed for multiple arrests evaluated?

Self‑activating deceleration devices intended for more than one arrest must have their locking mechanisms cycle and lock 1,000 times as they would in normal service. (Appendix D to Subpart I of Part 1910; 1910.140(e)(3)).

  • This tests durability and reliable performance over repeated uses.

Under Appendix D to Subpart I of 29 CFR 1910 — What free fall setup is specified when a connection link or lanyard determines the fall distance?

When a deceleration system uses a connection link or lanyard, the test free fall distance should equal the connection distance (measured from the centerline of the lifeline to the harness attachment), subject to the appendix’s maximum test fall limits. (Appendix D to Subpart I of Part 1910; see 1910.140(d)(2)(ii)(A)).

  • The appendix caps the test free fall at a 6 foot maximum for the test weight except where other specific provisions apply.

Under Appendix D to Subpart I of 29 CFR 1910 — What maximum free fall is allowed for force tests?

The appendix directs the use of the maximum free fall distance physically permitted by the system during normal use up to a 6 foot (1.83 m) maximum for the test weight, unless other specific rules apply for special devices. (Appendix D to Subpart I of Part 1910; 1910.140(d)(2)(ii)).

  • For some connection‑link systems or integral lifeline systems, the appendix specifies alternate distances as explained in the standard text.

Under Appendix D to Subpart I of 29 CFR 1910 — Are test systems required to remain serviceable after the drop?

No — the appendix explicitly states that following the test the system need not be capable of further operation. (Appendix D to Subpart I of Part 1910).

  • Tests are designed to evaluate performance to the point of arrest; many tests are destructive by design.

Under Appendix D to Subpart I of 29 CFR 1910 — How should deceleration devices be evaluated for the environmental conditions they will face in service?

Deceleration devices should be evaluated or tested under the environmental conditions (rain, ice, grease, dirt, and lifeline type) for which the device is designed. (Appendix D to Subpart I of Part 1910; see the deceleration device general provisions).

  • Testing under representative conditions helps ensure the device will lock and arrest falls reliably in actual use.

Under Appendix D to Subpart I of 29 CFR 1910 — How are window cleaner belt positioning systems tested and what force limits apply?

Window cleaner belts are tested using a 250‑pound (113 kg) weight dropped 6 feet (1.83 m) with the weight placed in the waistband and the belt terminals at maximum span; failure is any breakage or slippage that frees the weight. Arresting forces must not exceed 2,000 pounds (8.5 kN) for more than 2 milliseconds on initial impact, nor exceed 1,000 pounds (4.5 kN) for the remainder of the arrest. (Appendix D to Subpart I of Part 1910; see 1910.140(e)(2)).

  • This test simulates the belt being loaded as when worn by a window cleaner.

Under Appendix D to Subpart I of 29 CFR 1910 — What are the positioning system drop test requirements for other positioning systems (not window‑cleaner belts)?

Most other positioning systems (except restraint line systems) must pass a drop test where a 250‑pound (113 kg) weight free falls 4 feet (1.2 m); failure is indicated by breakage or slippage sufficient to let the weight fall free to the ground. (Appendix D to Subpart I of Part 1910; see 1910.140(e)(3)).

  • The body belt or harness should be affixed to the test weight as it would be to an employee.

Under Appendix D to Subpart I of 29 CFR 1910 — What are the lifeline vertical distance limits when testing rope‑grab mechanisms?

For rope‑grab deceleration systems, the lifeline length above the grabbing mechanism centerline to the lifeline’s anchorage must not exceed 2 feet (0.61 m) during testing. (Appendix D to Subpart I of Part 1910; see the lanyard/rope‑grab test setup requirements).

Under Appendix D to Subpart I of 29 CFR 1910 — If I need plain‑language guidance about when fall protection is required on a low‑slope roof, what practical point does OSHA give?

OSHA advises that stepping from a portable ladder onto a low‑slope roof and walking to a work area does not automatically require fall protection, but work performed less than 6 feet from a roof edge must be protected and work 15 feet or more from the edge may require protection depending on whether the work is infrequent and temporary; employers must assess each situation and provide fall protection where required by [1910.28]. See OSHA's interpretation about fall protection on low‑slope roofs for a practical example. (OSHA interpretation on fall protection on low‑slope roofs; 1910.140).

  • Employers must perform a hazard assessment and follow applicable OSHA requirements when work near the roof edge creates a fall hazard.