Positioning device systems guidelines

The appendix provides non-mandatory testing and inspection guidelines employers can use to help comply with the positioning device system requirements of 1926.502(e). See the Positioning Device Systems - Non-Mandatory Guidelines for Complying with 1926.502(e) and 1926.502(e).

• These are guidance procedures (not additional rules) intended to assist employers in demonstrating compliance with the performance requirements in 1926.502(e).

Appendix D recommends specific drop-test methods and also says employers may use the test procedures in paragraphs (b)–(e) of Appendix C (which address personal fall arrest systems) together with the Appendix D procedures to determine compliance with 1926.502(e)(3) and (4). See Appendix D to Subpart M and 1926.502(e)(3).

• In practice this means doing a single-drop test with a specified test weight and setup described in Appendix D, or using PFA test procedures from Appendix C where appropriate.

A single-strap positioning device must be tested with one end attached to a fixed anchorage and the other end connected to a body belt or harness exactly as it would be used to protect employees. See Appendix D to Subpart M and 1926.502(e).

• Adjust the strap and make attachments the same way workers would use them during normal operations so the test reflects real-world use.

A double-strap (two‑strap) positioning device should be tested with one end of the strap attached to a rigid fixed anchorage and the other end hanging free, with the body belt or harness attached to the strap the same way it would be used to protect employees; both strap ends must be adjusted to their maximum span. See Appendix D to Subpart M and 1926.502(e).

• Setting the straps to maximum span helps verify the device’s capacity under the most demanding configuration.

The fixed anchorage used for testing must be rigid and must not deflect more than 0.04 inches (1 mm) when a force of 2,250 pounds (10 kN) is applied. See Appendix D to Subpart M and 1926.502(e)(3).

• If the anchorage deflects more than this limit under the specified load, it is not acceptable for the Appendix D test setup.

The test weight must be 250 pounds plus or minus 3 pounds (113 kg ± 1.6 kg) and must be a rigid object with a girth of 38 inches plus or minus 4 inches (96 cm ± 10 cm). See Appendix D to Subpart M and 1926.502(e)(3).

• The girth requirement helps replicate how a human body interacts with the device during a fall or arrest event.

Each test consists of dropping the specified weight one time without failure of the system being tested. See Appendix D to Subpart M and 1926.502(e)(3).

• Appendix D also requires a new (unused) system be used for each single-drop test.

The test weight must be hoisted exactly 4 feet (1.2 m) above its “at rest” position and dropped to permit a vertical free fall of 4 feet (1.2 m). See Appendix D to Subpart M and 1926.502(e)(3).

• Accurate measurement of the hoist and free-fall distance is required so the test consistently simulates the dynamic forces the device must withstand.

The test is failed whenever any breakage or slippage occurs that permits the weight to fall free of the system. See Appendix D to Subpart M and 1926.502(e)(3).

• Any component that allows free fall or otherwise does not hold the test weight reliably is a failure and the system must not be used to protect employees.

No; following the Appendix D test, the system need not be capable of further operation, but any incapacities or damage must be readily apparent. See Appendix D to Subpart M and 1926.502(e)(4).

• Employers must ensure test failures or damage are obvious (tagging, marking, or destruction) so a failed system cannot be mistakenly returned to service.

Any component showing significant defects—such as cuts, tears, abrasions, mold, undue stretching; alterations or additions that affect efficiency; deterioration; fire, acid, or corrosive damage; distorted hooks or faulty hook springs; tongues unfitted to buckle shoulders; loose or damaged mountings; non‑functioning parts; or wearing/internal rope deterioration—must be withdrawn from service immediately and tagged or destroyed. See Appendix D to Subpart M and 1926.502(e)(5).

• Withdrawn components should be clearly marked as unusable to prevent accidental reuse.

Appendix D says positioning device systems must be regularly inspected as required by 1926.502(e)(5), but it does not set a specific interval; employers must establish a regular inspection schedule appropriate to the equipment and use conditions. See Appendix D to Subpart M.

• Typical practice is to perform inspections before each use and periodic detailed inspections by a competent person, and to document inspection frequency consistent with the employer’s written procedures.

Yes; Appendix D explicitly states that the test procedures in paragraphs (b)–(e) of Appendix C (which relate to personal fall arrest systems) may be used along with Appendix D procedures to determine compliance with positioning device system requirements in 1926.502(e)(3) and (4). See Appendix D to Subpart M and 1926.502(e)(3).

• Combining these methods can be helpful when a device shares components or functions with personal fall arrest equipment.

Yes; Appendix D requires that a new system be used for each drop test. See Appendix D to Subpart M and 1926.502(e)(3).

• This ensures that test results reflect the performance of an undamaged system and prevents cumulative damage from multiple drops affecting results.

Appendix D specifies a rigid test weight with a girth of about 38 inches to better simulate how a human body or body harness distributes force against straps and connectors during a fall arrest or arrest-like event. See Appendix D to Subpart M and 1926.502(e)(3).

• The girth and rigidity replicate contact geometry so the test more accurately reflects field performance of positioning devices on a person.

If internal rope deterioration or other significant internal wear is detected, the component must be withdrawn from service immediately and should be tagged or marked as unusable or destroyed. See Appendix D to Subpart M and 1926.502(e)(5).

• Do not attempt to return internally deteriorated ropes to service; replace them with new, inspected components.

Appendix D is non-mandatory guidance that provides recommended test and inspection procedures employers may use to help comply with the mandatory requirements in 1926.502(e). See Appendix D to Subpart M and 1926.502(e).

• Employers can use these methods or other equivalent procedures that demonstrate compliance with the performance requirements of the standard.

The body belt or harness must be attached to the test strap in the same manner it would be used to protect employees in actual use. See Appendix D to Subpart M and 1926.502(e).

• Correct attachment reflects realistic load paths and ensures the test evaluates how the system performs under real use conditions.

Employers must immediately withdraw any component with distorted hooks or faulty hook springs from service and tag or mark it as unusable or destroy it, per the inspection guidance in Appendix D. See Appendix D to Subpart M and 1926.502(e)(5).

• Distorted hardware can fail under load; do not attempt field repairs that could hide the distortion—replace the component.

No; if a system fails the Appendix D drop test (for example by permitting the test weight to fall free due to breakage or slippage), that system does not meet the performance reflected by the Appendix D procedures and must not be used to protect employees. See Appendix D to Subpart M and 1926.502(e)(3).

• Employers must either use a system that passes the applicable test methods or provide other means that demonstrably meet the performance requirements of 1926.502(e).

Appendix D requires that positioning device systems be regularly inspected as required by 1926.502(e)(5), but it does not specify a particular job title; employers should ensure inspections are done by a competent person qualified to detect defects and determine fitness for service. See Appendix D to Subpart M.

• Employers should train inspectors to recognize the specific defects listed in Appendix D and to document inspection results per company procedures.