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OSHA 1915.160

Positioning device system requirements

1915 Subpart I

26 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.160(a)(1), what finish and surface condition must connectors for positioning device systems have?

Connectors must have a corrosion-resistant finish and smooth surfaces and edges to avoid damaging other system parts. See the criteria for connectors and anchorages in 1915.160(a)(1).

Under 1915.160(a)(2), what minimum tensile strength is required for connecting assemblies used in positioning device systems?

Connecting assemblies must have a minimum tensile strength of 5,000 pounds (22.24 kN). See the requirement in 1915.160(a)(2).

Under 1915.160(a)(3), how strong must an anchorage be for a positioning device system?

A positioning device system must be secured to an anchorage capable of supporting at least twice the potential impact load of an employee's fall. See the anchorage strength requirement in 1915.160(a)(3).

Under 1915.160(a)(4), can snaphooks be connected to each other in positioning device systems?

Snaphooks shall not be connected to each other unless each snaphook is a locking type designed and used to prevent disengagement. See the snaphook rule in 1915.160(a)(4).

As of what date are only locking-type snaphooks required in positioning device systems under 1915.160(a)(4)?

As of January 1, 1998, only locking-type snaphooks are permitted for use in positioning device systems. See 1915.160(a)(4).

Under 1915.160(b)(1), what minimum breaking strength must restraint (tether) lines have?

Restraint (tether) lines must have a minimum breaking strength of 3,000 pounds (13.34 kN). See the criterion in 1915.160(b)(1).

Under 1915.160(b)(2)(i), what specific drop test and arresting force limits apply to a window cleaner's positioning system?

A window cleaner's positioning system must withstand a 6-foot drop of a 250-pound weight without failure, limit the initial arresting force to no more than 2,000 pounds (8.9 kN) for a duration not to exceed 2 milliseconds, and limit any subsequent arresting forces on the falling employee to no more than 1,000 pounds (4.45 kN). See 1915.160(b)(2)(i).

Under 1915.160(b)(2)(ii), what drop test applies to positioning device systems other than window cleaners' systems?

All other positioning device systems (not window-cleaning systems) must withstand a 4-foot drop of a 250-pound weight without failure. See 1915.160(b)(2)(ii).

Under 1915.160(c)(1), how often must positioning device systems be inspected and what should you look for?

Positioning device systems must be inspected before each use for mildew, wear, damage, and other deterioration; defective components must be removed from service. See 1915.160(c)(1).

Under 1915.160(c)(2), what must be done if a positioning device system or component is subjected to impact loading?

Any positioning device system or component subjected to impact loading must be immediately removed from service and not used again for employee protection unless a qualified person inspects it and determines it is undamaged and suitable for reuse. See 1915.160(c)(2).

Who can determine if a system component subjected to impact is safe to reuse, and what guidance explains the role of a capable person in shipyard standards?

A qualified person must inspect and determine whether a component subjected to impact loading is undamaged and suitable for reuse; the shipyard standards recognize that a competent person can specify necessary protections and precautions. See 1915.160(c)(2) and OSHA's Competent person requirements in shipyards letter of interpretation for how a competent/qualified person may be expected to evaluate hazards and protective measures.

Under 1915.160(d), what training topics must employees receive before using a positioning device system?

Employees must be trained in the application limits, proper hook-up, anchoring and tie-off techniques, methods of use, inspection, and storage of positioning device systems before using them. See 1915.160(d).

Does 1915.160 require employers to remove defective components found during pre-use inspection?

Yes. Defective components identified during the required pre-use inspection must be removed from service. See 1915.160(c)(1).

Under 1915.160(a)(1) and (a)(2), how do connector finish and strength requirements work together to protect system parts?

Connectors must have corrosion-resistant finishes and smooth edges to avoid damaging interfacing parts, and connecting assemblies must meet a minimum tensile strength of 5,000 pounds so that safe engagement and load-bearing are maintained. See 1915.160(a)(1) and 1915.160(a)(2).

If an employer wants to rely on a portable piece of equipment as an anchorage, what does 1915.160(a)(3) require?

Any anchorage—fixed or portable—used for securing a positioning device system must be capable of supporting at least twice the potential impact load of an employee's fall; the anchorage must therefore be evaluated and ensured to meet that capacity. See 1915.160(a)(3).

Under 1915.160(a)(4), are locking snaphooks allowed to be connected to one another?

Locking snaphooks that are designed and used to prevent disengagement may be connected to each other; non-locking snaphooks must not be connected. See 1915.160(a)(4).

Under 1915.160(b)(2)(i), what is the test weight used for positioning device system drop tests?

Both the window cleaner's and other positioning device system drop tests use a 250-pound (113.4 kg) test weight. See 1915.160(b)(2)(i) and 1915.160(b)(2)(ii).

Under 1915.160(b)(2)(i), what are the allowed limits for subsequent arresting forces after the initial arrest for window cleaners' systems?

After the initial arrest, any subsequent arresting forces imposed on the falling employee must not exceed 1,000 pounds (4.45 kN). See 1915.160(b)(2)(i).

Does 1915.160(b) offer any alternative means to show compliance with the drop-test performance criteria?

Yes. Positioning device systems that comply with the provisions of section 2 of non-mandatory appendix B to this subpart are deemed to meet the 1915.160(b)(2) requirements. See the note in 1915.160(b).

Under 1915.160(c)(1), what kinds of deterioration should be checked in the pre-use inspection of webbing or ropes?

You should inspect webbing and ropes for mildew, wear (such as abrasion or fraying), cuts, chemical damage, and other signs of deterioration that could reduce strength; remove any defective components. See 1915.160(c)(1).

How should an employer ensure the person who inspects a component after impact is qualified, considering shipyard competent person guidance?

The employer should assign a qualified person with the technical knowledge and authority to evaluate the component's condition and accept or reject it for reuse; OSHA's shipyard interpretation explains that a competent person must be capable of recognizing and evaluating hazards and specifying necessary protections. See 1915.160(c)(2) and the Competent person requirements in shipyards letter of interpretation.

Under 1915.160(d), must training include storage practices even though the standard doesn't give storage details?

Yes. The standard requires that training cover storage of positioning device systems, so employers must train employees on appropriate storage practices even though specific storage methods are not prescribed in the text. See 1915.160(d).

If a system component has been involved in a fall incident, can it be returned to service immediately after a visual check by the user?

No. A component subjected to impact loading must be removed from service and may only be returned to use if a qualified person inspects it and determines it is undamaged and suitable for reuse; a user-only visual check is not sufficient under 1915.160(c)(2).

Under 1915.160(a) and (b), are positioning device systems allowed to arrest a fall, and what controls exist on arresting forces for window-cleaning systems?

Positioning device systems have specified performance criteria: window cleaner systems must pass the 6-foot/250-pound drop test and limit initial arresting force to no more than 2,000 pounds (8.9 kN) (duration ≤ 2 milliseconds) and subsequent arresting forces to no more than 1,000 pounds; other systems must pass the 4-foot/250-pound drop test. See 1915.160(b)(2)(i) and 1915.160(b)(2)(ii).

Under 1915.160(c), what immediate action must workers take if they find mildew or damage during pre-use inspection?

They must remove the positioning device system or damaged components from service and not use them until repaired or replaced; defective components are not to be used. See 1915.160(c)(1).

How does 1915.160(a)(2) interact with manufacturer specifications when choosing connectors and connecting assemblies?

Connectors and connecting assemblies must meet the minimum tensile strength requirement of 5,000 pounds per 1915.160(a)(2), so you should select hardware that both meets the standard and is compatible with manufacturer guidance for the system to ensure safe performance.