3.3 Inspecting harnesses, lanyards and SRLs

1 What OSHA requires, and what it leaves open

Three paragraphs carry the whole subject.

• 1926.502(d)(21) — inspect the system prior to each use for wear, damage and other deterioration; remove defective components from service.
• 1926.502(d)(19) — components subjected to impact loading must be immediately removed from service and not used again for employee protection until inspected by a competent person and determined to be undamaged and suitable for reuse.
• 1926.503(a)(2)(ii) — the employer's training program must cover the correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used. Inspection is a trained skill, not an intuition.

Where do the actual thresholds come from? Two places, in this order.

The manufacturer's instructions. They are equipment-specific and they are the document OSHA will ask for. They set the reject criteria, the periodic formal inspection interval, and any service life the maker imposes.

The consensus standard ANSI/ASSP Z359, which the fall protection industry writes its instructions against. Z359 is a copyrighted private standard: it is named here and not reproduced. If your program references it, buy it.

OSHA does publish one list of its own, in non-mandatory Appendix C to Subpart M, and it is worth having in front of you.

2 OSHA's own defect list

Appendix C, paragraph (g), states that a component must be withdrawn from service immediately if it shows any of the following conditions:

Appendix C is guidance, not a rule. But it is OSHA's guidance, published in the Code of Federal Regulations, and if a harness on your job shows one of those nine conditions and stays in service, that list is what the argument will be about.

3 Walking a harness

Do it the same way every time, and do it with the harness in your hands rather than on a hook. Two or three minutes, start to finish.

1. 1
   Labels first. Are the manufacturer's markings legible — model, size, date of manufacture, the standards it was built to? An illegible label means you cannot establish what the reject criteria or the service life are, and that alone takes it out of service.
2. 2
   Bend the webbing into an inverted U and work along every strap, both faces, six to eight inches at a time. Cuts, frays, pulled or broken stitches, abrasion, glazing, chemical staining, and any hardness or stiffness. Pay particular attention where webbing passes through hardware and behind the back pad.
3. 3
   Stitching. Look at every stitch pattern, especially at the dorsal D-ring pad and at each buckle. Broken, pulled or missing stitches are a reject.
4. 4
   Hardware. D-rings, buckles, adjusters, keepers: cracks, sharp edges, distortion, corrosion, wear grooves, and free movement. A D-ring that has been pulled out of plane has been loaded.
5. 5
   Impact indicators. Most harnesses have a folded-and-stitched indicator at the dorsal D-ring that pulls out when the harness takes a fall. If it has deployed, the harness is scrap under 1926.502(d)(19).
6. 6
   Fit and function. Put it on. Chest strap at mid-chest, leg straps snug, dorsal D-ring between the shoulder blades. A harness that cannot be adjusted to fit the worker will not hold them correctly in a suspension.

4 Lanyards, SRLs and connectors

Shock-absorbing lanyards. Inspect the webbing legs the same way as harness webbing. Then the shock pack: is the cover intact, is the stitching under it undisturbed, has the pack begun to tear open? A partially deployed pack has taken a load and is finished. Check the snaphooks at both ends — gate action, spring, throat, keeper — and check that the labels are still readable.

Self-retracting lifelines. Pull the line all the way out and let it retract under control: it should pay out smoothly and retract fully without hesitation. Then jerk it sharply — it must lock. Inspect the full length of the cable or webbing for broken wires, kinks, birdcaging, corrosion, cuts and abrasion. Check the housing for cracks and loose fasteners, and check the impact indicator on the swivel or the hook. An SRL that does not retract fully or does not lock goes to the manufacturer, not back on the hook.

Anchor connectors. These are the components that get inspected least and are just as much part of the system. Beam straps: webbing and stitching, and the D-ring or eye at each end. Beam clamps and trolleys: jaw wear, thread condition, distortion. Cast-in and permanent anchors: corrosion, movement, missing hardware, and whether the periodic inspection required by the installer has actually been done.

Compatibility. Appendix C paragraph (c) warns that components are not always interchangeable, and that substitutions or changes require evaluation or testing by a competent person. A hook whose throat is too wide for the anchor eye it is used on is a compatibility defect even though every part passes inspection individually.

5 Two inspections, not one

OSHA does not require you to document the pre-use check, and most well-run programs document it anyway — not for the inspector, but because a signed line means it happened.

6 Failing a component properly

Removal from service fails in practice for one reason: the rejected gear stays reachable. A harness in the corner of the gang box with a strip of tape on it goes back into use within a week.

1. 1
   Take it off the job. Not to a shelf, not to the truck bed. Off.
2. 2
   Destroy it if it is scrap. Cut the webbing through in two places. Anything that took an impact load is scrap unless a competent person determines otherwise under 1926.502(d)(19) — and for a shock pack that has deployed, there is nothing to determine.
3. 3
   Quarantine what needs a decision. Gear awaiting a competent person's determination or a return to the manufacturer goes in a labeled container, tagged "DO NOT USE," away from serviceable equipment.
4. 4
   Replace it before the shift. A crew one harness short will improvise, and the improvisation is what hurts someone.
5. 5
   Record what and why. A one-line log of removals is the cheapest way to notice that one storage location is destroying webbing, or that one crew's lanyards keep coming back cut on the same edge.
6. 6
   Store the good gear properly. Clean, dry, out of sunlight, away from chemicals, heat and sharp edges, hung rather than compressed. Storage is where most Appendix C deterioration originates.