FAQs on new OSHA Fall Protection Regulations: Vol. 5 – OSHA clarifications

Many organizations have struggled to interpret some of the new requirements outlined in OSHA’s update to the General Industry Walking-Working Surfaces and Personal Fall Protection Equipment Standards (29 CFR part 1910, Subparts D&I). In response to specific questions asked by the International Safety Equipment Association (ISEA), OSHA has released correspondence that clarifies two key items from the new regulation.

Issue 1: “Proof Testing” of Snaphooks and Carabiners

From the regulation released earlier this year, OSHA 1910.140(c)(8) states that the “gate strength of snaphooks and carabiners must be proof tested to 3,600 lbs. in all directions.” Literally, this means that every gate must be loaded to 3,600 lbs before being put into service, which could, ironically, render them unfit for use – clearly not what OSHA intended. OSHA has now clarified that their intent was that the snaphooks be designed with the required strength of 3,600 lbs, and the design is validated through verification testing.  A much better requirement, and one that LJB certainly supports.

Issue 2: Definition of a “qualified person” to train workers on hazards and equipment

In section 1910.30(a)(2) of the new regulation, OSHA states that a “qualified person” must train workers on fall hazards and fall protection equipment. ISEA pointed out that the construction fall protection regulation and the ANSI/ASSE Z359standard allow these tasks to be completed by a “competent person”—a term that is defined in both documents along with ANSI Z359.2 listing stated responsibilities. ISEA’s question asked for clarification on whether someone who meets the Z359.2 requirements for a competent person is considered “qualified” to train workers.

OSHA’s response indicates that they “consider that a trainer who is a designated competent person and meets all of the qualifications for trainers and competent persons in ANSI/ASSE is a ‘qualified person’ for purposes of the final rule. We hope this response will help those evaluating training options realize the one and two-day competent person training courses are simply not enough to truly be effective.

It’s important to note that this particular interpretation does not mean that the defined terms Qualified Person and Competent Person are interchangeable—simply that a Competent Person that meets ANSI’s criteria is “qualified” for the specific training requirements outlined in the new OSHA rule. Other tasks that require a Qualified Person—including design of anchorages or a horizontal lifeline—must still be performed by an individual that meets the definition of an OSHA Qualified Person.

It’s LJB’s opinion that an even better option is to require that your Qualified Persons meet Z359.2’s requirements as well. Too many times I’ve heard people say that they were confident in their systems because “a P.E. designed it”.  Unfortunately, the P.E. may only have addressed the strength aspect of the system, and not other important factors such as procedures, compatibility, fall clearance, swing fall, rescue, training, or anything else that might affect the ability of the system to save a person’s life. Someone who meets the ANSI Z359 definition of a Qualified Person would be much more likely to understand and address these important factors.

An official Letter of Interpretation has not been posted to the OSHA website, so if you would like a copy or have any questions about these issues, please don’t hesitate to contact me.




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