OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

March 14, 1995

J. Nigel Ellis, Ph.D., CSP, P.E.,
CPE President Dynamic Scientific Controls
P.O. Box 445
Wilmington, DE 19899-0445

Dear Dr. Ellis:

This is in response to your December 14, 1994, letter requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) standards addressing training for employees using personal fall arrest equipment.

With regard to whether a personal drop experience is necessary to meet the training requirements of section 1926.503, please be advised that it is not. The training requirements in Section 1926.503 are only intended to supplement and clarify the requirements of 1926.21 regarding the hazards addressed in subpart M. Section .503 identifies components of the requisite training, but does not specify the details of the training program. However, one of the required components of the training provision dictates that if employees use fall arrest equipment they must be trained in the proper use of such equipment. This training must include as a minimum, lectures and demonstrations that include wearing the equipment in conditions that are as close as reasonably possible to jobsite conditions. Although not required by the standard, a low impact, safely designed controlled drop which simulates a fall arrest using a self-retracting lanyard or shocks absorbing lanyard will significantly increase the users understanding of and confidence in the fall arrest system.

If we can be of any further assistance please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,



Roy F. Gurnham, P.E., J.D
Director Office of Construction and Maritime
Compliance Assistance




14 December 1994

Dale Cavanaugh
OSHA USDOL
Room N3610
222 Constitution Avenue NW
Washington DC 20210

Dear Mr Cavanaugh,

re: OSHA Subpart M Fall Protection Training, 1926.503; specifically

Personal Fall Arrest Systems (PFAS) training

Please provide us OSHA's position on the experience of a safely designed, controlled personal drop simulating a fall arrest to competently meet the requirements of the PFAS training section of the new standard.

We request a prompt response.

Sincerely,



J. Nigel Ellis, Ph.D., CSP, P.E.,
CPE President

NOTES: Please read Don Jacklich's speech notes from Fall Protection Symposium, San Diego, October 1994 (ref 1926.503(a)(2)(iii) use and operation of PFAS and adequate compliance with 503(c) Certification of training).

Review letter from J. Nigel Ellis to Gerry McPherson confirming quality control for training program protocols regarding equipment maintenance in addition to strong personal experience endorsement.

JNE personal experience for 25 years: Training by lecture and even putting on the harness is insufficient in predicting whether the procedures will be properly followed where the actual exposure occurs. For example, aerial lift and/or elevated platforms and/or manbasket exposures provide critical instructor feedback on each individual trainee's reaction to exposure at elevated work areas to indicate how the employee will perform under actual jobsite conditions. Rescue personnel and firefighters are other classes of workers where actual job conditions are simulated during training to predict competent performance.

Answer proposed for OSHA response:

When personal fall arrest systems (PFAS) are used, 1926.503(a)(2)(iii) requires that a worker can only be certified as trained if they have been trained by an instructor competent in PFAS.

Employers have a duty to train employees in the proper use of PFAS if they are required to use PFAS as part of their jobsite personal protective equipment (PPE). Prior to training employees to use PFAS, employers must ensure that employees have no physical or psychological impairments that would preclude the employees from safely using PPE in a jobsite fall hazard situation.

ANSI Z359.1 para 7.3 states "Prior to work requiring PFAS, users shall be trained by a competent person to select, inspect, use, store and maintain the equipment according to the requirements of this standard and the manufacturer's instructions".

Major manufacturers of PFAS strongly recommend that trainees experience a safely designed, controlled drop simulating a fall arrest as part of a training program leading to the worker being certified by the employer as being "trained" according to 1926.503(b).

It is OSHA's position that employees being trained in the safe and proper use of PFAS per 1926.503(a)(2)(iii) should experience training that as close as reasonably possible simulates "actual" jobsite conditions to ensure predictability of fixture performance at the jobsite. This training should include a low impact, safely designed, controlled drop which simulates a fall arrest using a self-retracting lanyard/lifeline or shock absorbing lanyard. This experience will help to ensure that employees being trained know how to use the PPE to minimize the recognized fall hazards on the job.