Fall Protection PPE and Third-Party Testing
This article is posted with permission from the American Society of Safety Engineers (ASSE), publisher of Professional Safety. Click here to read this article as it appeared in the January 2008 issue of Professional Safety.
By W. David Lough
For years, it has been a buyer beware mentality for SH&E professionals responsible for procurement of workplace fall protection equipment. The acquisition of equipment that does not meet the standards implied by the manufacturer is a real concern to the consumer-whether the consumer is a large entity making a million dollar purchase or a small business spending its safety budget for the year.
Unless the SH&E professional making the purchase is well educated in fall protection systems and equipment, it is possible that equipment which does not meet ANSI standards will be purchased. Companies that wish to provide standardized equipment to their employees have had a difficult time doing so because proper quality control procedures are not in place at all manufacturing levels and are not required by ANSI/ASSE Z359.1.
THE ANSI/ASSE STANDARD
ANSI recently revamped and expanded the Z359 series of standards into the Z359 Fall Protection Code. The code now incorporates equipment-testing procedures and design requirements, as well as guidance and clarification on training, procedure writing, positioning and travel restraint systems, rescue and numerous other issues that have historically been confusing in the world of fall protection.
In the past, ANSI has not required third-party testing of fall protection equipment, which means that manufacturers perform their own compliance testing. Testing facilities, testing practices and testing methods vary among manufacturers, leading to inconsistent results from manufacturer to manufacturer.
A new standard currently in draft form as ANSI Z359.7, Third-Party Certification of Fall Protection Products and Components, would change that by providing minimum requirements for third-party certification. Third-party certification of fall protection equipment would mean that an unbiased testing facility (outside of the manufacturer) would assess whether the equipment meets the design, performance and testing requirements of the applicable standard. This would assure the consumer that the intent of the standard is being met as attested to by an unbiased certification organization, meaning the consumer need not rely solely on a manufacturer’s affirmations.
This is not an uncommon practice for standards organizations. For example, the Canadian Standards Association (the ANSI equivalent in Canada) has long provided testing certification for its many standards through an in-house testing facility and accredited testing laboratories.
In addition, some of the larger fall protection equipment manufacturers, such as Sperian (Miller brand) and MSA (among others), have had third-party testing conducted on their products to ensure uncontested compliance with the standards. Many of these manufacturers are taking this proactive stance as members of the Safety Equipment Institute (SEI), a nonprofit organization established to administer third-party certification programs to test and certify a broad range of safety equipment. SEI’s certification programs are accredited by ANSI.
Under ANSI Z359.7, organizations such as Underwriters Laboratories, SEI and affiliated testing labs that are permitted to perform the physical testing would adhere to this document. The standard would dictate that all certifications of fall protection equipment to the applicable ANSI standard be performed by a certification organization which meets specific requirements.
The standard could be written to prevent manufacturers from testing their equipment to select portions of the standard, then certifying that their equipment is compliant to the entire standard. In addition, it could help to ensure that manufacturers do not use the ANSI designation in any statements about their product unless the product has been certified as compliant by an appointed certification organization.
Requirements for the testing laboratories with regard to equipment calibration, proper testing facilities, documentation, quality assurance and staff qualifications will also be detailed. Certification organizations would need to meet stringent requirements to ensure that they are not affiliated with any manufacturer and do not gain financially from a product meeting the applicable ANSI standard. It could also be their responsibility to ensure that the testing laboratory is in compliance with the standard.
QUALITY CONTROL Q&A
The new standard will set guidelines for providing quality control for fall protection equipment. Quality control or quality assurance programs are not required to meet the present ANSI Z359.1 standard. It is left to the integrity of manufacturers and the checks and balances that they enforce to ensure a consistently high-quality product which meets the standard’s requirements. Many of the larger manufacturers are ISO 9001 certified and already have rigorous quality control systems; however, many smaller manufacturers do not.
Commonly asked questions regarding quality control include the following:
Q: If a product was tested to the applicable standard 5 years ago, how do I know whether it still meets the standard’s requirements?
A: Currently, consumers do not know how long it has been since the manufacturer has tested its product to ensure that it still meets the applicable ANSI standard. The frequency of testing is not detailed in ANSI Z359.1.
Common practice among manufacturers is to perform testing on each lot, although depending on the manufacturer, this may or may not occur. Common practice also changes depending on the product. In many cases, each carabiner may be tested to a proof load, but this cannot be the same for a personal energy-absorbing lanyard. ANSI Z359.7 could detail requirements for annual audits and recertification of equipment, and a mandatory quality assurance program to be maintained by the manufacturer.
Q: Who do I call if I suspect that a piece of equipment with an ANSI logo is not ANSI-compliant?
A: Currently, if a question arises concerning a product and compliance, or the right of the manufacturer to attest that its product meets or exceeds a standard, the consumer has no avenues through which to report the issue and get a consistent result. The manufacturer may contend that its interpretation of the standard, design and testing requirements for the equipment meets the Z359.1 requirement. How does a consumer contest this point? ANSI does not have the resources or testing facilities to investigate such discrepancies.
The new standard could dictate that one responsibility of the certification organization is to ensure that products marked with its logo as well as the ANSI standard are in compliance. Products simply marked with the ANSI standard may not be third-party certified and may not meet the new standard.
Q: What happens when a manufacturer changes a component on a piece of fall protection equipment? Is it still certified?
A: No. The new standard may require that when a product is updated or changed, or when new models are introduced, new samples will have to be inspected, assessed and tested in accordance with the applicable standard.
Q: If a piece of fall protection equipment is faulty or a product recall is issued, how do I know that the manufacturer will notify the users?
A: No current ANSI requirement ensures that a manufacturer will notify users when a faulty or noncompliant piece of equipment is identified. The draft ANSI Z359.7 standard could require the manufacturer to provide corrective action and notifications to the public when a potential product safety issue is recognized. This safety alert and/or product recall system could be part of the overall quality control program. The system may be required to detail methods for notifying distributors and users, timeframes for notifications as well as procedures for removing the product from service and replacement plans.
ABOUT THE AUTHOR
W. David Lough is the VP of Operations for Gravitec Systems Inc., a Poulsbo, WA, consulting company that specializes in fall protection engineering, training and equipment. He has been designing, consulting and training on fall protection systems for more than 13 years and is on the ANSI Z359 Accredited Standards Committee. Lough has also aided in writing Canadian Standards Association documents and has written several articles on fall protection.