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OSHA 1915.159

Personal fall arrest systems

Subpart I

30 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.159 (Personal fall arrest systems), are body belts and non-locking snaphooks allowed as part of a personal fall arrest system after January 1, 1998?

No — body belts and non-locking snaphooks are not acceptable parts of a personal fall arrest system after January 1, 1998. See the general rule in 1915.159 which states that effective January 1, 1998, body belts and non-locking snaphooks are not acceptable as part of a PFAS.

  • Employers must select harnesses and connectors that meet the rest of the criteria in 1915.159 when specifying fall arrest equipment.

Under 1915.159(a)(1)-(a)(2), what material and finish requirements apply to connectors (hooks, D-rings, etc.)?

Connectors must be strong and corrosion-resistant: they shall be made of drop forged, pressed, or formed steel or materials with equivalent strength, and shall have a corrosion-resistant finish with smooth surfaces and edges. See 1915.159(a)(1) and 1915.159(a)(2).

  • Smooth edges are required to prevent cutting or wearing of webbing, rope, or other interfacing parts.

Under 1915.159(a)(3)-(a)(4), what tensile strength and testing must D-rings and snaphooks meet?

D-rings and snaphooks must meet minimum strength and proof-test requirements: they shall be capable of sustaining a minimum tensile load of 5,000 pounds and shall be proof-tested to a minimum tensile load of 3,600 pounds without cracking, breaking, or permanent deformation. See 1915.159(a)(3) and 1915.159(a)(4).

  • Keep manufacturers’ test records or ensure purchased connectors are certified to these limits.

Under 1915.159(a)(5), how must snaphooks be sized or designed to prevent unintentional disengagement?

Snaphooks must be sized to be compatible with the member they connect to, or they must be a locking type designed and used to prevent disengagement by contact with the connected member. See 1915.159(a)(5).

  • If a snaphook could be depressed by the object it connects to, use a locking snaphook or choose a different connector that prevents accidental release.

Under 1915.159(a)(6), what connections are prohibited for non-locking snaphooks?

Non-locking snaphooks must not be engaged directly to webbing, rope, wire rope; to each other; to a D-ring already holding another snaphook or connector; to a horizontal lifeline; or to any object shaped so that the connected member could depress the keeper and release itself. See 1915.159(a)(6) and its subparagraphs 1915.159(a)(6)(i)–(v).

  • Use locking snaphooks or alternative connectors when one of these prohibited conditions exists.

Under 1915.159(a)(7), what special requirement applies to connections on suspended scaffolds or similar platforms with horizontal lifelines that may become vertical?

On suspended scaffolds or similar platforms with horizontal lifelines that may become vertical lifelines, the devices used for connection to the horizontal lifeline must be capable of locking in any direction on the lifeline. See 1915.159(a)(7).

  • This requirement prevents accidental disengagement if the lifeline orientation changes during work or suspension.

Under 1915.159(a)(8), must PFAS anchorages share the same anchorage used to support or suspend a platform?

No — anchorages used for attachment of personal fall arrest equipment must be independent of any anchorage used to support or suspend platforms. See 1915.159(a)(8).

  • Do not rely on the scaffold or platform support points as PFAS anchorages unless a separate independent anchorage meeting the standard is provided.

Under 1915.159(a)(9), what strength must anchorages meet for one employee, and what are the alternative design options?

Anchorages shall be capable of supporting at least 5,000 pounds per employee attached, or they must be designed, installed, and used either as part of a complete PFAS that maintains a safety factor of at least two and/or under the direction and supervision of a qualified person. See 1915.159(a)(9) and subparagraphs 1915.159(a)(9)(i)–(ii).

  • If you use design calculations instead of the 5,000-lb rule, have a qualified person supervise the installation and use.
  • For guidance on the role and authority of competent/qualified personnel in shipyard operations, see OSHA’s interpretation on Competent person requirements in shipyards.

Under 1915.159(b)(1), can multiple employees share one vertical lifeline?

No — when vertical lifelines are used, each employee must be provided with a separate lifeline. See 1915.159(b)(1).

  • This prevents entanglement and ensures independent fall arrest for each worker.

Under 1915.159(b)(2), what minimum tensile strength is required for vertical lifelines and lanyards?

Vertical lifelines and lanyards must have a minimum tensile strength of 5,000 pounds (22.24 kN). See 1915.159(b)(2).

  • Use manufacturer-certified components or test records to confirm compliance.

Under 1915.159(b)(3)-(b)(4), what are the strength requirements for self-retracting lifelines and lanyards?

Self-retracting lifelines and lanyards that automatically limit free-fall distances to 2 feet or less must sustain a minimum tensile load of 3,000 pounds applied with the device fully extended; those that do not limit free-fall to 2 feet, plus ripstitch or tearing/deforming lanyards, must sustain a minimum static tensile load of 5,000 pounds when fully extended. See 1915.159(b)(3) and 1915.159(b)(4).

  • Select SRLs based on whether they limit free-fall to 2 feet or less and follow manufacturer specifications.

Under 1915.159(b)(5), who must design, install, and supervise the use of horizontal lifelines and what safety factor applies?

Horizontal lifelines must be designed, installed, and used under the supervision of a qualified person and only as part of a complete PFAS that maintains a safety factor of at least two. See 1915.159(b)(5).

  • For clarification on the responsibilities of competent or qualified persons in shipyard settings, see OSHA’s Competent person requirements in shipyards.
  • Keep design calculations and documentation showing the 2x safety factor for inspection or enforcement.

Under 1915.159(b)(6), what maximum arresting forces and stopping criteria must a PFAS meet when used with a body harness?

When used with a body harness, a PFAS must limit the maximum arresting force on a falling employee to 1,800 pounds, bring the employee to a complete stop, and limit the maximum deceleration distance to 3.5 feet; it must also have sufficient strength to withstand twice the potential impact energy of the applicable free fall. See 1915.159(b)(6)(ii)–(iv).

  • If using a body belt (not recommended since belts are no longer acceptable for PFAS), the arresting force limit was 900 pounds per 1915.159(b)(6)(i).
  • Systems meeting the criteria in Appendix B are considered to comply with paragraph (b)(6). See 1915.159(b)(6) NOTE.

Under 1915.159, what must you do if an employee plus tools weigh 310 pounds or more?

If the combined tool and body weight is 310 pounds or more, PFAS that meet Appendix B criteria are deemed to comply with paragraph (b)(6) only if they are modified appropriately to provide protection for the extra weight of the employee and tools. See the note to 1915.159(b)(6).

  • Consult the PFAS manufacturer or a qualified person for required modifications, and document the changes and rationale.

Under 1915.159(b)(7), how far may an employee free fall when a PFAS is rigged?

Personal fall arrest systems must be rigged so that an employee can neither free fall more than 6 feet nor contact any lower level. See 1915.159(b)(7).

  • Position anchors and use appropriate lanyard lengths or self-retracting devices to meet this limit.

Under 1915.159(c)(1), where should the attachment point be located on a body harness and where on a body belt?

The attachment point of a body harness should be located in the center of the wearer’s back near shoulder level, or above the wearer’s head (and may be in the chest when free fall is limited to less than 20 inches); the attachment point of a body belt should be located in the center of the wearer’s back. See 1915.159(c)(1)(i) and 1915.159(c)(1)(ii).

  • Follow harness manufacturer instructions for the correct dorsal or overhead attachment points.

Under 1915.159(c)(2)-(c)(3), what materials and compatibility requirements apply to ropes, straps, and hardware?

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and harnesses must be made from synthetic fibers or wire rope, and all ropes, belts, harnesses, and lanyards must be compatible with their hardware. See 1915.159(c)(2) and 1915.159(c)(3).

  • Compatibility means the hardware (connectors, buckles, D‑rings) must not weaken or damage the webbing/rope and must operate as intended.

Under 1915.159(c)(4), how must lifelines and lanyards be protected from environmental and process hazards?

Lifelines and lanyards must be protected against cuts, abrasions, burns from hot work, and deterioration by acids, solvents, and other chemicals. See 1915.159(c)(4).

  • Use sleeves, guards, routing away from sharp edges, or select chemically compatible materials when exposure to these hazards is possible.

Under 1915.159(c)(5)-(c)(6), what inspection and post-impact rules apply to PFAS components?

Personal fall arrest systems and components must be inspected prior to each use for mildew, wear, damage, and other deterioration, and defective components must be removed from service; any PFAS subjected to impact loading must be immediately removed from service and may not be reused until a qualified person inspects and determines them suitable for reuse. See 1915.159(c)(5) and 1915.159(c)(6).

  • Train users to perform pre-use inspections and to tag/remove defective gear.
  • Keep records of inspections and qualified-person clearance after any fall or impact event.

Under 1915.159(c)(7), what rescue responsibilities does the employer have when using PFAS?

The employer must provide for prompt rescue of employees in the event of a fall or ensure that employees are able to rescue themselves. See 1915.159(c)(7).

  • Rescue plans should be site-specific, practiced, and provide timely means to get a suspended worker to medical care.
  • For guidance on the roles of competent/qualified personnel in shipyard settings, see OSHA’s Competent person requirements in shipyards.

Under 1915.159(c)(8), what minimum width is required for body belts?

Body belts used under this part must be at least one and five-eighths inches (1 5/8 inches) wide. See 1915.159(c)(8).

  • Remember that body belts are no longer acceptable as part of a PFAS after January 1, 1998 per 1915.159.

Under 1915.159(c)(9), can personal fall arrest systems be used to hoist materials?

No — personal fall arrest systems and components must be used only for employee fall protection and not to hoist materials. See 1915.159(c)(9).

  • Using PFAS components to lift materials can overload or damage them and invalidate their protective capability.

Under 1915.159(d), what training must be provided before employees use PFAS?

Before using personal fall arrest equipment, each affected employee must be trained to understand the equipment’s application limits and proper hook-up, anchoring, and tie-off techniques, and must be able to demonstrate proper use, inspection, and storage. See 1915.159(d).

  • Training should be practical and hands-on so employees can demonstrate correct donning, inspection, anchoring, and rescue awareness.

Under 1915.159(a)(9)(ii) and (b)(5), who is a qualified person and what is their role in PFAS anchor/line design and use?

A qualified person is someone with the knowledge and skills to design, install, and supervise fall-protection systems; they must direct and supervise anchorage design and horizontal lifeline systems. See 1915.159(a)(9)(ii) and 1915.159(b)(5).

  • For further explanation of competent/qualified person responsibilities in shipyard employment, see OSHA’s interpretation on Competent person requirements in shipyards.
  • Employers should document the qualifications (training, experience, credentials) of the person certifying designs or installations.

Under 1915.159(b)(6) NOTE and Appendix B, can meeting Appendix B procedures be used to show compliance with arresting-force and deceleration limits?

Yes — a PFAS that meets the criteria and protocols in Appendix B is considered to comply with the requirements of paragraph (b)(6) (arresting-force and deceleration limits). See the NOTE to 1915.159(b)(6).

  • Use Appendix B procedures and document testing or manufacturer certification showing the system meets those protocols.

Under 1915.159(b)(6)(iii) and (b)(7), what is the maximum allowed deceleration distance and free-fall distance for PFAS?

A PFAS must limit the maximum deceleration distance an employee travels to 3.5 feet, and must be rigged so an employee cannot free fall more than 6 feet or contact any lower level. See 1915.159(b)(6)(iii) and 1915.159(b)(7).

  • Consider lanyard length, anchor height, and potential slack/elongation in fall-distance calculations to ensure compliance.

Under 1915.159(c)(6), who may determine whether a PFAS component subjected to impact loading is safe for reuse?

A qualified person must inspect and determine that any PFAS or component subjected to impact loading is undamaged and suitable for reuse before returning it to service. See 1915.159(c)(6).

  • Keep inspection records and the qualified person’s determination as part of the safety file.

Under 1915.159(b)(3)–(4), can you use a self-retracting lifeline (SRL) that does not limit free fall to 2 feet?

Yes — you may use an SRL that does not limit free fall to 2 feet, but it must meet the higher strength requirement: such SRLs, like ripstitch or tearing lanyards, must sustain a minimum static tensile load of 5,000 pounds when fully extended. See 1915.159(b)(3) and 1915.159(b)(4).

  • Where possible, prefer SRLs that limit free fall to 2 feet or less to reduce fall distance and arrest forces.

Under 1915.159(a)(6)(iii), can you connect a snaphook to a D-ring that already has another connector attached?

No — snaphooks (unless locking types designed to prevent disengagement) must not be connected to a D‑ring to which another snaphook or connector is attached. See 1915.159(a)(6)(iii).

  • Use a properly sized locking connector or a certified multi‑connector device when multiple tie‑offs are required.

Under 1915.159(c)(5) and (d), how often must users inspect PFAS and what training should cover inspections?

Users must inspect personal fall arrest systems prior to each use for mildew, wear, damage, and other deterioration, and training must teach employees to understand equipment limits and demonstrate proper inspection, use, and storage. See 1915.159(c)(5) and 1915.159(d).

  • Training should include hands-on pre‑use checks (webbing cuts, stitching, hardware deformation, corrosion, labels) and steps to remove defective equipment from service.