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OSHA 1915.151

Scope and definitions for PPE

Subpart I

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.151(a), does this PPE subpart apply to shipyard work performed offsite or at remote locations?

Yes. This subpart applies to all work in shipyard employment regardless of geographic location, so shipyard activities performed offsite or at remote locations are covered by 1915.151(a).

  • Employers must follow the requirements of Subpart I for any work that qualifies as shipyard employment, no matter where the work is being done.

Under 1915.151(b), what is an "anchorage" for fall-protection systems?

An anchorage is a secure point of attachment used for lifelines, lanyards, or deceleration devices. 1915.151(b) defines it as such.

  • Anchorages must be strong and reliable enough to support the fall-protection components they hold; employers should ensure anchor points are selected or designed to meet the loads anticipated for the work.

Under 1915.151(b), what is a "body belt" and can it be used for fall arrest?

A body belt is a strap that secures around the waist and provides a point for attaching a lanyard, lifeline, or deceleration device; however, the use of a body belt for fall arrest is prohibited as of January 1, 1998. The definition and prohibition are in 1915.151(b) and the remainder of the section.

  • Body belts may still be used for certain positioning systems (see definition of "positioning device system"), but they cannot be used to arrest a fall.

Under 1915.151(b), what is a "body harness" and how does it differ from a body belt?

A body harness is a system of straps secured about the employee to distribute fall-arrest forces over the thighs, shoulders, chest, and pelvis, and it has means to attach to other fall-arrest components. The definition is in 1915.151(b).

  • Unlike a body belt (which fastens only around the waist), a body harness spreads forces across the body and is the required component for fall arrest (body belts are prohibited for fall arrest after Jan 1, 1998).

Under 1915.151(b), what is a "connector" and what are common examples?

A connector is a device used to couple parts of a personal fall arrest or positioning device system together. 1915.151(b) lists examples such as carabiners, buckles, D-rings sewn into harnesses, and snaphooks spliced or sewn to lanyards.

  • Connectors can be independent components (like a carabiner) or integral parts of other equipment (like a D-ring on a harness). Employers should ensure connectors are compatible and rated for the intended loads.

Under 1915.151(b), what is a "deceleration device" and what are typical types used in shipyards?

A deceleration device is any mechanism that dissipates energy during a fall or limits the energy imposed on an employee during fall arrest. 1915.151(b) gives examples such as rope grabs, ripstitch lanyards, specially woven lanyards, tearing/deforming lanyards, and automatic self-retracting lifelines/lanyards.

  • Employers should select deceleration devices appropriate to the task and ensure they are installed and used according to manufacturer instructions and applicable standards.

Under 1915.151(b), how is "deceleration distance" measured during a fall?

Deceleration distance is the additional vertical distance a falling employee travels, excluding lifeline elongation and free fall distance, from the point the deceleration device starts to operate to when the employee comes to a full stop. The definition and measurement are in 1915.151(b).

  • It is measured between the attachment point location at activation onset and the attachment point location when the employee is fully stopped.

Under 1915.151(b), what does "equivalent" mean when used in this subpart?

"Equivalent" means an alternative design, material, or method that the employer can demonstrate will provide an equal or greater degree of safety than the method or item specified in the standard. The definition appears in 1915.151(b).

  • If using an "equivalent," the employer must be able to show (document) that the alternative provides at least the same level of protection as the specific standard requirement.

Under 1915.151(b), what is "free fall" and what specifically is the "free fall distance"?

Free fall is the act of falling before a personal fall arrest system begins to apply force, and free fall distance is the vertical displacement of the fall arrest attachment point on the body belt or harness between the onset of the fall and just before the system begins to apply arresting force. Both definitions are in 1915.151(b).

  • The free fall distance excludes deceleration distance and lifeline/lanyard elongation, but it does include any slide or extension of a deceleration device or self‑retracting lifeline before it engages.

Under 1915.151(b), what is a "lanyard" and how is it typically used?

A lanyard is a flexible line of rope, wire rope, or strap, usually with a connector at each end, used to connect the body belt or harness to a deceleration device, lifeline, or anchorage. The definition is in 1915.151(b).

  • Lanyards are commonly used to link a worker's harness to an anchorage or to a deceleration device and must be selected and used so that they do not allow an excessive free-fall distance.

Under 1915.151(b), what is a "lifeline" and what are the differences between vertical and horizontal lifelines?

A lifeline is a flexible line for connection to an anchorage at one end (vertical lifeline) or to anchorages at both ends (horizontal lifeline) that serves as a means to connect other components of a personal fall arrest system to the anchorage. The definition appears in 1915.151(b).

  • Vertical lifelines hang from a single anchorage and are typically used for fall arrest or work positioning at a single point.
  • Horizontal lifelines stretch between two anchorages and allow movement along the line; they must be designed/installed to handle the dynamic forces of a fall.

Under 1915.151(b), what are considered "lower levels" where an employee could fall?

Lower levels are areas or surfaces to which an employee can fall; examples include ground levels, floors, ramps, tanks, materials, water, excavations, pits, vessels, and structures. This definition is in 1915.151(b).

  • Employers must consider all possible lower-level hazards (including water and materials) when planning fall protection and rescue.

Under 1915.151(b), what components make up a "personal fall arrest system"?

A personal fall arrest system consists of an anchorage, connectors, and a body belt or body harness, and it may include a lanyard, deceleration device, lifeline, or a suitable combination of these components. The definition is in 1915.151(b).

  • Note that because body belts are prohibited for fall arrest (see 1915.151(b)), modern fall arrest systems should use a body harness to arrest falls safely.

Under 1915.151(b), why did OSHA prohibit the use of body belts for fall arrest after January 1, 1998?

OSHA prohibits the use of body belts for fall arrest because they do not distribute fall forces across the body the way a harness does, increasing the risk of injury; the prohibition and effective date are stated in 1915.151(b).

  • Employers must use body harnesses (not body belts) for fall arrest systems to meet the safety objective of limiting injury from fall forces.

Under 1915.151(b), what is a "positioning device system" and can a body belt be used for it?

A positioning device system is a body belt or body harness system rigged to allow an employee to be supported at an elevated vertical surface (for example, a wall or window) so they can work with both hands free while leaning. The definition is in 1915.151(b).

  • The definition explicitly allows either a body belt or a body harness for positioning systems; however, remember that a body belt is not permitted for fall arrest.

Under 1915.151(b), who is a "qualified person" and how does that differ from a "competent person" in shipyard standards?

A qualified person is someone who, by degree, certificate, or extensive knowledge, training, and experience, has demonstrated the ability to solve or resolve problems related to the subject matter and work; this definition is in 1915.151(b).

  • A "competent person" is a related but distinct term defined elsewhere in Part 1915 (see the OSHA interpretation on competent person requirements in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18), and in some Subparts a competent person must also meet additional qualifications (see 29 CFR 1915.3 and 1915.4 in that interpretation).

  • If an employer relies on a qualified or competent person to specify protective measures or evaluate hazards, that person must have the demonstrated knowledge and experience to do so.

Under 1915.151(b), what is a "restraint (tether) line" and is it necessarily designed to stop a fall?

A restraint (tether) line is a line from an anchorage (or between anchorages) that secures an employee so they cannot walk or fall off an elevated surface; the definition is in 1915.151(b).

  • The standard notes that a restraint line is not necessarily designed to withstand forces resulting from a fall, so employers should not rely on a restraint line for fall arrest unless it is specifically designed and rated for fall forces.

Under 1915.151(b), what is a "rope grab" and how does it function in fall arrest?

A rope grab is a deceleration device that travels on a lifeline and automatically engages and locks by friction to arrest a fall; it usually uses inertial or cam/lever locking or both, as described in 1915.151(b).

  • Rope grabs must be compatible with the lifeline they travel on and used according to the manufacturer's instructions to ensure they will lock effectively in the event of a fall.

Under 1915.151(b), may an employer use an "equivalent" fall‑protection design instead of the exact item called out in the standard?

Yes, an employer may use an "equivalent," but they must be able to demonstrate that the alternative design, material, or method provides an equal or greater degree of safety compared to the specific method or item in the standard; see the definition of "equivalent" in 1915.151(b).

  • The employer should document the basis for equivalence (testing, engineering analysis, manufacturer data) so it is clear that employee protection is not reduced.

For PPE covered under Part 1915, is an employer allowed to require employees to pay for the PPE or charge a deposit?

No, generally employers must pay for required PPE, but they may use certain deposit or return systems as long as those systems do not effectively charge employees for required PPE; see the OSHA interpretation on employer payment for PPE at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and Part 1915 coverage at 1915.

  • OSHA's payment rule (2007 final rule) requires employers to pay for PPE required by OSHA standards unless a specific exception applies.
  • Employers may retain ownership of PPE and require its return on termination; they may use a deposit system to encourage returns, but the system must not result in employees being involuntarily charged for PPE.

Under 1915.151(b), does the definition of "free fall distance" include extension of a self‑retracting lifeline before it engages?

Yes. The definition of free fall distance excludes deceleration distance and lifeline/lanyard elongation, but it does include any deceleration device slide distance or self‑retracting lifeline/lanyard extension that occurs before the device operates and fall arrest forces start, as stated in 1915.151(b).

  • When calculating total fall clearance, account for free fall distance, deceleration distance, lifeline elongation, and required safety margins to prevent striking lower levels.