Vol. 6 – OSHA clarifies RDS certification requirements

For more information on the elements of a complete system, refer to this recorded webinar: http://bit.ly/FPAnchWeb

As many in the fall protection industry expected, OSHA has published a letter of interpretation (LOI) in response to a question about testing anchorages for rope descent systems (RDS). You can read it for yourself here, but when you do, I caution you to be attentive to the details.

You’re probably familiar with those optical illusions where we THINK we see something that isn’t really there, or MISS something that becomes ridiculously obvious once it’s pointed out to us (remember the gorilla playing basketball?) The same thing can be said about the OSHA regulation. You must study it carefully to understand what the requirements are. You can read in previous blog posts about how OSHA doesn’t use the phrase “load testing” when describing certification, yet many people continue to THINK it does.

In the LOI, OSHA clarifies and reinforces three important aspects of the standard:

  1. Certification must be performed by a qualified person
  2. Load testing” is not required nor prescribed by the standard
  3. “Testing” refers to any scientifically valid testing criteria

I’ll address each of these in reverse order. When OSHA uses the phrase “scientifically valid testing criteria,” they are effectively RULING OUT any notion of certifying that an unknown anchor can support a load greater than applied test load. We’ve seen many reports claiming that an anchor can support 5,000 lbs., with no evidence apart from the fact that it supported an applied load of 2,500 lbs. This would not be a scientifically valid test. Note that even if a test load of 5,000 lbs. is applied, the way it’s applied and the data that’s collected are critical to making it a useful, scientifically valid test.

The most important bit of information in the LOI is also perhaps the easiest to overlook: neither the question nor the answer describes the use of load testing to determine strength of an unknown anchorage. Rather, both the question and the answer refer to testing of an anchorage “with an ultimate capacity of 5,000 pounds…” Perhaps it is subtle, but the implication is that you already know what the ultimate capacity is – presumably through the application of proper engineering techniques and visual confirmation – and any load testing being done is to confirm workmanship or some other reason.

Last, OSHA once again stresses that the certification must be done by a qualified person. Not wanting to repeat myself, I’ll refer you to this previous blog post for more information on what a qualified person needs to do. The reliability of the certification is dependent on how thoroughly the qualified person understands the entire system – not just the strength – and what to do about managing the risks inherent in working at heights.

If you ask someone who claims to be a qualified person to provide you certification of your fall protection anchorages, and the response you get centers around load testing of the anchorages, I’d advise you to keep looking for a truly qualified person. You don’t have to look too far – LJB has an established and growing team of qualified persons eager to help you address your work at heights challenges.

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