What we should learn from the SRL recalls

LJB-PPE_inspection-1200pxThe recent recalls of self-retracting lifelines (SRLs) by 3M and Honeywell have prompted some clients to ask, “Is the personal protective equipment industry struggling with quality issues?”

While the back-to-back recalls are certainly disturbing, there is more to the story than a few PPE flaws. And, there is a lot more that you can do to protect workers at height beyond ensuring properly functioning equipment.

Let’s start with that quality issue.

The quality aspect

The recall of the Honeywell SRLs sounds like the result of a traditional quality issue: There’s a problem with a specific element of the product within certain lots. I’m not sure how the problem was discovered, but it wasn’t due to an injury or fatality. Honeywell did well to develop a fix and quickly spread the word.

The 3M SRL recall seems to have resulted from issues discovered during testing—testing that 3M conducted voluntarily and that likely isn’t required by any fall protection regulations or standards. One of the key takeaways from the issue with the 3M SRLs is how critical it is to test equipment not only how the manufacturer intends it to be used, but also how the manufacturer expects it to be used. While there is a subtle difference, the latter is more user-focused.

Fundamentally, the industry must continuously improve quality and testing. And, part of the responsibility of users is to voice their concern to the PPE manufacturing community. If you know a product is often used incorrectly or outside the manufacturer’s limitations, let the manufacturer know and encourage the company to perform and share relevant test results.

The bigger picture

Beyond any issues with quality, manufacturing, and testing is this crucial takeaway: PPE is only one option to protect workers at heights. Although PPE is the solution of choice for many organizations, it is actually the least effective and the most easily defeated safety measure you can use.

Safety Hierarchy of Controls

Safety Hierarchy of Controls

The safety Hierarchy of Controls is a methodology that ranks safety solutions in terms of effectiveness and “defeatability.” Because we know that using PPE neither removes the person from the risk, or the risk from the person, following the Hierarchy of Controls is integral to our philosophy for helping clients develop safety solutions.

Many organizations lean toward PPE as a less expensive option than an engineered solution. However, when using PPE, there are significant recurring direct and indirect costs—costs you don’t incur in engineering controls or elimination solutions. Fall protection PPE is not intuitive to use, so training, monitoring and replacement costs can be significant.

A common process in the safety industry is identify → evaluate → control. Too often, we find that organizations identify a hazard and rush to judgment on how to control it, without really evaluating the best ways to minimize risk. PPE solutions are appropriate in many circumstances, but they should not be the first—or only—abatement option considered.

If you think your organization is at risk by relying too heavily on PPE, or if you want an unbiased opinion about your PPE use, let us know. We can serve as a third-party evaluator to determine where you can decrease risk by implementing more effective, less “defeatable” solutions.

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