New ANSI Z359 Updates

The use of scissor lifts, boom lifts and other mobile elevated work platforms (MEWPs) is becoming increasingly popular on jobsites and facilities across the nation. They are effective in elevating workers closer to where tasks need to be performed, but proper precautions must be taken to ensure workers are protected from falling out of the lift when operating at heights. Accidental falls and equipment tip-overs are the main causes of MEWP fatalities, accounting for 51% of total fatalities according to a study by the Census of Fatal Occupational Injuries.

In August 2023, the ANSI Z359.14-2021 standard regarding self-retracting lifelines (SRLs) updated its equipment classification and labeling requirements. This article will discuss these updates to the ANSI standard and its effects on fall protection requirements in MEWPs.

Changes to ANSI Z359.14

Formerly, ANSI recognized two classifications of SRLs: Class A and Class B. Class A SRLs had a deceleration distance of 24 inches and 1,350 pounds average arresting force (AAF), while Class B SRLs had a deceleration distance of 52 inches and 900 pounds AAF.

These originally differentiated SRLs based on their minimum fall clearance required, with Class A being preferred for areas where fall clearance was more limited. However, neither was rated for foot-level tie-off. When SRLs are connected to overhead anchorages, their brakes can activate immediately and much less fall forces will be generated by the system. But when SRLs are connected to lower or foot-level anchorages, the user will suffer “freefall” until they pass underneath their SRL, and the dispensed lifeline accelerates to a point where the internal brake activates. During that freefall, additional force is generated that must be absorbed by the system, or else it will make its way to the user’s body and potentially cause injury.

For a worker needing to connect to an anchor below their dorsal D-ring or working near sharp edges, manufacturers introduced leading edge units, or the SRL-LE. Either Class A or Class B SRLs could become an SRL-LE [leading edge] if the manufacturer added an external shock pack between the SRL block and the user connection and tested the lifeline cable against a working surface edge as small as 0.005 of an inch in diameter, among other testing criteria.

Without being familiar with proprietary label markings or knowing what physical characteristics to look for on the SRL housing, many workers were unaware if their units were permitted for LE work or foot-level tie-off scenarios. Since there was no industry consensus on how to mark SRL-LE versus standard SRLs, it was ultimately up to employers to educate their workers on the equipment they supplied and ensure employees could tell the difference – and hope there was no confusion when they went up at heights to perform the work.

Updates to ANSI Z359.14 

The new ANSI update aimed to make it clearer for frontline workers to know which SRL was suitable for their use. Now, SRLs are reclassified as Class 1 or Class 2.

Instead of differentiating SRLs between their minimum required fall clearance, they are differentiated by their tie-off capabilities

Class 1 SRLs are only permitted to tie off to anchors at or above the dorsal D-ring on a body harness. Class 2 SRLs are additionally rated for tie-off within 5 feet below the dorsal D-ring (otherwise known as foot level). When the SRL is not tied off overhead or at dorsal D-ring height, more freefalls will occur during the fall, and more fall forces will be generated. If that fall is also occurring near a sharp edge, the increased forces on the lifeline could potentially sever the lifeline after the fall is arrested. The additional shock pack that is incorporated with Class 2 SRLs serves to absorb the extra load on the connection device and prevent it from failing during fall arrest.

A simple way to remember between the two classes: Class 1 has one option for tie-off (at or above the dorsal D-ring) and Class 2 has two options for tie-off (at or above the dorsal D-ring, or within 5 feet below the dorsal D-ring). When supplying fall protection equipment, only supply Class 1 SRLs if it is guaranteed the worker will never have to tie off to an anchor point beneath their dorsal D-ring. Class 2 SRLs can be used in any application, but Class 1 SRLs require overhead anchorage.

Additionally, SRLs must be clearly marked with their SRL class on the product. ANSI set forth strict guidelines on contrasting colors, where Class 1 SRLs are printed on a white square with black text, Class 2 SRLs are printed on a black square with white text. If workers are properly educated on the difference between the two SRL classifications, what those differences mean for use out in the field, and how to identify between the two SRLs, they should be able to confirm the SRL they are about to use will properly arrest their fall and help prevent injury.

The new ANSI standard also recognizes three new types of SRLs: SRL, SRL-P, and SRL-R. Standard SRLs refer to Class 1 or Class 2 units that are a standalone unit. These are typically larger SRL blocks with 20 feet to 100 feet or more of lifeline and are permanently mounted on their anchorage for later use. If a worker is unable to reach the SRL to connect, it is recommended to add a tagline to the snaphook to lower it down when connecting to their body harness. SRLs should be stored with the lifeline completely retracted when not in use to protect the integrity and longevity of the internal spring and brake components.

SRL-P are “personal” units. These refer to small, back-worn units that can be semi-permanently attached to the user’s harness directly beneath the dorsal D-ring. These can also be Class 1 or Class 2. These units are preferred for workers constantly moving from anchor point to anchor point that must maintain 100% tie off and are ideal for workers frequently entering/exiting MEWPs. This solution keeps the dorsal D-ring free and open for a rescue device to retrieve fallen workers.

SRL-R are “rescue” units. These units could also be Class 1 or Class 2, but most will be Class 1. These units have an integrated winch that can be utilized to rescue fallen workers. However, it should be noted that utilizing the winch function on these units is for emergencies only, and the SRL must be repaired or recertified by the manufacturer once the winch is used. The winch is designed to be used once to rescue a worker, not for repeated use or as a material winch to raise/lower workers or materials into confined spaces.

SRLs for Mobile Fall Protection

Now that we understand the differences between SRLs, which is the best connection device when operating a MEWP? 

First, it’s important to understand Occupational Safety and Health Administration (OSHA) requirements when it comes to fall protection in different MEWPs. Fall protection is required on aerial boom lifts. However, Federal OSHA does not explicitly require fall protection on standard scissor lifts, but that can cause confusion when a scissor lift manufacturer includes an engineered anchor point.

OSHA also has mandates that require workers to follow manufacturer instructions. If the product manual instructs users to tie off to the anchor point when OSHA does not explicitly require it, which one takes precedence? Consider this, if we knew the worker was guaranteed to fall during this use, would we want them to be tied off or not, if a suitable anchorage exists? However, choosing the best connection method is just as important. For example, using a 6-foot shock-absorbing lanyard when the MEWP is elevated to no less than 18 feet could still put the user at risk of hitting the ground and sustaining serious injuries from their fall.

Fall positioning or restraint, the concept of restricting a user from moving away from their anchor point, will always be preferred to fall arrest. During fall arrest a fall could occur at any time, and we must mitigate those potential injuries. A fixed-length or adjustable lanyard with no shock absorption can attach to the side D-ring or dorsal D-ring on the user’s harness and, when properly tensioned, can prevent the user from exiting the platform. Furthermore, if work is being performed under U.S. Army Corps of Engineers EM385 jurisdiction, fall restraint may be the only form of fall protection permitted on aerial boom lifts.

However, if fall arrest is chosen and we look to the new ANSI Z359 update, a Class 2 SRL would be necessary for a MEWP, since most anchor points on lifts are either attached to the midrail or on the base of the platform. While the MEWP’s railings may not be considered sharp edges, the SRL is located beneath the user’s dorsal D-ring, and additional fall forces can be expected. Selecting a Class 2 SRL-P would provide the user with the means to connect to their anchorage immediately upon using the MEWP and provide some shock absorption if an accidental ejection occurred.

Conclusion

Managing a proactive, comprehensive fall protection program is a difficult task that requires a solid understanding of how to protect workers while adhering to ever-changing regulatory compliance updates effectively. And when it comes to work that must be performed at heights, we must be sure we are providing those workers with the equipment, training and resources to perform their tasks safely. Companies like Diversified Fall Protection can help retrofit facilities to ensure minimum legal requirements are met and workers are properly protected. Together, the work we perform today can potentially save lives tomorrow.