FAQs on new OSHA Fall Protection Regulations: Vol. 6 – Rope Descent System Anchorages

This post in our blog series on new OSHA fall protection regulation focuses on common questions related to fall protection anchorages.

Most questions on this topic stem directly from the language below from 29 CFR 1910.27(b)(1)(i):

“Before any rope descent system is used, the building owner must inform the employer, in writing, that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 pounds…”

Many organizations are looking for answers now since OSHA has given a date of November 20, 2017 to comply with this rule. The future deadline is given to provide additional compliance time, since many of the organizations that commented on the rule during the draft phase said most buildings where they use rope descent systems do not currently have certified anchorages.

The subject of testing is one of the biggest question marks for many organizations. Please note that OSHA does not explicitly require 100% field testing of the anchorages post installation. OSHA does not directly say why, but I believe it is for the following reasons:

• Testing to 5,000 pounds could damage anchor or structure
• Testing isn’t always necessary, depending on the available documentation from design and installation – although from my experience this is usually not provided thoroughly enough

When deciding whether or not you need to test, you need to have a professional engineer—and ideally one very experienced in fall protection—planning and performing these tests. I have seen anchorages tested by others, and I really question the effectiveness of what was performed.

What is certification, and what does it cost?

Unlike the hazard assessments, OSHA does not provide an example of a compliant anchorage certification. The language in the rule states that building owners must notify contractors and workers “in writing” that requirements are met, so some form of written documentation is required. LJB provides our clients with a certification record that contains information on system design, system use and rescue procedures, training and equipment inspection logs and more. If you want complete guidance on anchorage certification, I refer you to ANSI Z359.6-2016. The standard takes the OSHA requirements for anchorages and creates specific and detailed guidance for how to achieve compliant certification.

In regards to cost, OSHA provided cost estimates for certifying existing anchorages in the commentary section. We believe the estimates are low, so we don’t recommend using their information alone, without corroborating it with any actual provider.

Please subscribe or check back next Wednesday morning for the next installment in this blog series, which focuses on new requirements related to guardrail. And, if you have your own specific questions, please comment below.