When considering fall
protection solutions, people often consider Personal Fall Arrest Systems and
rails as the only two options available. In some cases, that might be true, but
in other cases it puts an undue burden on the person trying to come up with the
solution by eliminating other safe, compliant options. In some cases, a
Positioning Device System may be one of those options.
Positioning Device
Systems are briefly mentioned in OSHA’s fall protection standard for
Construction [29 CFR 1926.502(e)] under fall protection and OSHA’s shipyard
standards [29 CFR 1915.160] under personal protective equipment. Positioning
Device Systems are not to be confused with travel restraint – a situation in
which workers on an elevated surface uses a body belt or harness with a lanyard
to keep themselves from being able to reach the fall hazard. Travel Restraint
is useful in areas where sufficient anchor points for fall arrest are not
available or where a fall could cause other problems, such as causing a boom
lift to tip. Positioning Device Systems are different, though, and serve a very
specific purpose.
According to the
definition found in the standards, a positioning device system is a “body belt
or body harness rigged to allow an employee to be supported on an elevated
vertical surface, such as a wall, and work with both hands free while leaning.”
Think about an iron worker who is tying re bar for a pour-in place wall. That iron worker needs to scale the existing re bar, get to the work location and have
some type of support without setting up scaffolding, since the work moves
pretty quickly. In order to do this, they take advantage of the aforementioned
Positioning Device System. The system allows them to hook their body belt or
harness to the re bar, then lean back. It keeps them in place so they can do
their work while using both hands.
Notice the use of the
words ‘body belt’. This is one of the only situations in which a body belt is
allowed to be used. The Positioning Device must be rigged so that no more than
a 2 foot free fall may occur. This means that the forces incurred by the body in
the event of a fall would be much less than those incurred while using a
Personal Fall Arrest System. In addition, there is limited possibility of
movement, meaning that a fall while using a Positioning Device would most
likely be because the worker’s feet slipped from their perch. The resulting
fall would be a short distance, feet-first, straight down. A fall while using
Fall Arrest could be feet first or head first and could result in swing. The
short free fall distance and the limited movement allow the body belt to still
be a viable option.
Aside from the body
belt and the allowable free fall distance, the requirements for a Positioning
Device System are pretty much identical with those for a Personal Fall Arrest
System. What the components need to be made of, the minimum load capacities and
strength of the components, and how the hooks may be connected are identical in
the two sections. Because of the inherent dangers of an actual fall, the
Personal Fall Arrest System has many additional requirements, but the fact that
almost everything found in the two sections is identical should make utilizing
Positioning Devices simple, since most safety professionals are already very
familiar with Fall Arrest.
Positioning Devices
may not come into play often, depending on what field you are in, or they may
be every day fixtures in your workplace, but either way it’s important to
exhaust all your options. An unseasoned safety professional who hasn't run into
Positioning Device Systems before might be tempted to immediately issue a
violation due to the body belt, so it’s important to understand the applicable
regulations. Help keep your workers safe by fully understanding the solutions
available to them.
