Back to Personal Fall Arrest Systems
Excerpt from Memo to Region VIII
Where an employer is using a fall arrest system that permits a fall of more
than six feet, a citation should be issued under 1926.104(d) unless the employer
shows that (1) limiting an arrested fall to six feet is infeasible; (2) the
arresting fall distance, though more than 6 feet, is as short as feasible; (3)
it has taken reasonable steps to determine that (a) the arresting forces will be
limited to 1800 pounds and (b) the system will not fail in an arrested fall.
Example of an employer that takes "reasonable steps": An
employer calculates the total arresting fall distance and the loads imposed on
the system based on measurements, product data and appropriate calculations.
Using product data, the employers determines that the components, as used, will
have the necessary strength to sustain the loads and that the arresting forces
on the worker would be limited to 1800 pounds.
Example of an employer that fails to take "reasonable steps":
An employer sets up a system that allows an arrested fall of more than six feet.
It asserts that, in its judgment, the system will work. However, it has made no
assessment of how far the arrested fall would be, what the loads of an arrested
fall would be, and failed to assess the load capacity of the system.
For additional information, see Interpretations and Clarifications - Subpart M -- Fall Protection (29 CFR 1926.500-503)