Why the 3M SRL recall is about more than the equipment

recallAs you may have heard, 3M has issued a stop use and recall of its DBI-SALA® Twin-Leg Nano-Lok™ edge and the Twin-Leg Nano-Lok™ Wrap Back Self-Retracting Lifelines—likely the most significant recall in the history of fall protection in terms of units, cost to the manufacturer and users’ business disruption.

As part of a personal fall protection system, SRLs connect to or near the dorsal D-ring of a worker’s harness. Both recalled products incorporate an energy absorber that reduces the energy exerted on the user to keep impact forces below the 1,800-pound injury threshold for most of the population. According to 3M’s stop use and recall notice, the company “determined that in a fall and under certain conditions, the energy absorber of these devices may not properly deploy which could expose the worker to serious injury or death.”

Kudos to 3M
Let’s give 3M credit for demonstrating integrity in acknowledging the issue and proactively communicating the recall. Remember: The recall wasn’t prompted by an injury or fatality. 3M discovered the issues during testing. Thank goodness the defect was discovered before any workers were hurt, or worse.

What it means
I hope I’m not being cynical toward the fall protection industry, but I wonder if there are products from other manufacturers that—when put to the rigors of 3M’s testing—would be recalled for the same or similar reasons. My reading of the recall notice leads me to believe that this issue is not related to a test method or design requirement outlined in the ANSI Z359.14-2014 standard. So, if I’m right, this means the test 3M performed is above and beyond what is required by Z359.

While most manufacturers likely perform tests beyond what is required, there is a lot of variation, and as important, IT IS NOT REQUIRED. Throughout the field of fall protection, individuals and organizations are beginning to realize how critical it is to test equipment as it is expected to be used, rather than assuming the manufacturer’s testing is enough. While I think there will be revisions to Z359.14 at some point in the coming months or years, you must insist on more from your manufacturer of choice to truly increase safety and reduce risk for your workers at height.

What to do now
If you have the affected equipment, follow the guidelines in the recall notice. And, regardless of what model of equipment or manufacturer you use, think about the following:

  • Always try to find safer ways, such as engineering controls, to protect workers. When PPE is needed, elevate your anchorage to minimize the risk of worker injury or equipment damage.
  • Make sure your use is clearly aligned with the manufacturer’s instructions.
  • If your use IS NOT clearly aligned or you have questions, ask for additional testing by the manufacturer.
  • Have your qualified person observe the use and discuss the application. And, as discussed in a blog post by my colleague Kevin Wilcox, make sure the qualified person is a true professional—ideally, both a professional engineer and certified safety professional who can address the strength, processes and behavioral aspects of a COMPLETE personal fall protection system.
  • Be intentional about NOT USING improvised anchorages. Insist that each system is designed by a qualified person, including training, inspection, specification of the anchors and equipment and with clear procedures for use and rescue.
  • Perform a site assessment to increase your knowledge of your hazards and decrease the chance that fall protection systems are improvised by the user or site supervisor.

As always, LJB is driven to reduce risk for workers at height. If you’d like someone on our team to help you understand or address risk, or develop a new solution, please don’t hesitate to reach out.

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