“How safe is our staff?” Every site owner, operator, and manager considers this question at one point or another. There is another organization asking this question, too, but on a much larger scale: OSHA. There is a lot to cover in terms of OSHA and the aerial adventure industry; here, we’ll focus on harnesses. What are the harness requirements and available equipment options for use within the confines of aerial adventure parks and zip lines?
OSHA and ANSI
Let’s break open the textbook for a minute to see which standards and documents apply because, after all, employers are liable for everything in them.
OSHA 1910, the “General Industry” section, applies to employees within an operation such as an aerial adventure park or a camp. OSHA 1926, the “Construction” section, applies to all employees and workers performing construction work. It is almost inevitable that many operations will, at one point in their existence, engage their employees in construction work, whether it is new construction or maintenance that is better categorized as a major modification. To clarify: general scheduled or repeated maintenance falls under OSHA 1910.
One other standard of note: the ANSI Z359.11 standard, which focuses on the design, performance, and testing of full-body harnesses. It is through this document and the resulting test certifications that sites can be assured their harnesses meet or exceed the requirements set forth by OSHA. Again, to clarify: OSHA is the required code that informs employers of the bare minimum precautions to be taken, while ANSI Z359.11 certifies the products for use within the specified systems for OSHA compliance.
HARNESS DEFINITION AND REQUIREMENTS
OSHA [1910.140(b)] defines a harness as “…straps that secure about the employee in a manner to distribute the fall arrest over at least the thighs, pelvis, waist, chest, and shoulders, with a means for attaching the harness to other components of a personal fall protection system…”
The main takeaway from this definition is its requirement for full-body harnesses for employees working and operating at height—a requirement hotly debated in the aerial adventure industry.
Loui McCurley of PMI Rope notes that “many of us come from a recreational background and don’t understand why we should have to follow OSHA.” Many owners, operators, and builders developed their skills and passion for the industry on a recreational level with rock climbing or a similar sport where they maintained a comfortable relationship with heights and their equipment, mainly their sit harness.
A secondary takeaway is that the intended use of the harness, and the personal fall protection system in which it will be integrated, both dictate design and feature decisions. In particular, the attachment method statement requires a qualified person to assess the needs of the fall protection system connectors and where on the harness those attachments must be located. This is where people start to step into the gray areas of the harness world, as there are many OSHA-compliant harnesses that would fulfill the definition in OSHA 1910—but not fulfill the needs of the personal fall protection system or the operator. One specific example of this: a FrenchCreek Production Model 530 harness, which meets both OSHA standards and ANSI Z359.11, lacks a waist loop attachment point—and that makes it unsuitable for zip line use.
Another OSHA requirement may not be obvious at first. Section 1910.140(c)(22) calls for an attachment point located in the center of the back near shoulder level, more commonly referred to as a dorsal attachment. However, OSHA allows the attachment point to be located at the pre-sternal position if the free fall distance is less than or equal to two feet. This exception can greatly aid in the design of a personal fall protection system, and the best method of attachment, when an employee must “participate” in an activity (such as zip lining) with the same or similar equipment as the participants.
Zip line specifics. Additionally, to make things a tad bit confusing, OSHA released a supplemental pamphlet in 2016 addressing the protection of workers (operators, guides) specifically within zip line operations. Though the pamphlet is brief, it does address the use of seat harnesses, stating, “seat harnesses may only be used in conjunction with safety nets or with lines that prevent workers from moving beyond the edge,” which is simple to say yet blurry in practice. In effect, OSHA is stating that seat harnesses can be used in zip line operations, but only if platforms are outfitted with OSHA-compliant safety nets or OSHA-compliant travel restraint systems that prevent a worker from reaching the edge. This opens a whole can of worms, but may serve some sites well in their search for OSHA compliance.
You may be asking, “Where does ANSI Z359.11 come into the equation?” The ANSI standard fulfills a large gap left open by both the OSHA standards regarding specific design requirements, performance metrics, and a testing certification, also known as a stamp or label certificate.
ANSI is not an all-encompassing answer to all OSHA-based harness or fall protection systems questions, but it is a means of ensuring OSHA compliance and safety for harness wearers. The requirements of ANSI Z359.11 include, but are not limited to, harness materials, material breaking strengths, dorsal attachment point (middle of the upper-back), load bearing sub-pelvic strap, and a webbing assembly that minimizes the possibility of releasing the torso (aka leg loops of some sort). In addition, each element of the harness is subjected to static and/or dynamic load tests corresponding with the element’s use and the load types it will be subjected to during use. After the tests have been passed and the design of the harness complies with the requirements of ANSI Z359.11, the harness will receive a tag. With ANSI Z359.11, you can rest assured that the manufacturer has done its job, and your employees are in safe hands.
So why all the confusion when things seem so simple with the definition provided by OSHA? Well, it’s never as simple as it appears. Here are a few of the gray areas our industry faces daily.
Guide vs. Operator vs. Maintenance. There is a constant debate about which category of employee should comply with which standard. This is further complicated by the type of element the employee is engaging with—a zip line, aerial trekking course, or climbing wall. Each of the permutations can produce a different answer, so how does a responsible manager determine what to do? The simple answer is: education and assessment. Often, it is worth the expense to bring in an industry professional to help determine the needs of the operation and navigate the local OSHA enforcement body. If this is not an option, OSHA offers an On-site Consultation Program to small businesses at no cost.
Manufacturers. From a manufacturer’s perspective, OSHA’s simple harness definition can cause headaches. As Blair Williams of Edelrid explains, “With OSHA there is no clear differentiation between quantifiable performance requirements and application-related requirements or recommendations.” In contrast, the EN standard includes technical, quantifiable requirements as well as required application-related testing methods. This combination provides manufacturers greater clarity. Fortunately, ANSI Z359.11 helps to clear up any confusion on the operator side, because it is an easy way to guarantee the harness will meet OSHA requirements.
Enforcement. The aerial adventure industry in the U.S. is plagued by issues and gray areas anytime the words standards, regulations, and enforcement are uttered simply because there is no uniformity from state to state. One would think that the federal government and Department of Labor would be able to deliver this uniformity, but they don’t. Williams alludes to this struggle by pointing out that “OSHA positions themselves, in most cases, as a recommending agency vs. an enforcement body.” However, no one can be sure which “hat” the local OSHA inspector is going to decide to wear. If a certain OSHA region acts as more of a recommending agency, their actions may perpetuate a lack of safe practices and compliance. On the flip side, if a certain OSHA inspector gets more active as an enforcer than his or her education on this industry supports, the impacts can come crashing down on the operating site costing, or wasting, precious time and money.
The best way to navigate the gray area of enforcement is to get to know your local OSHA office and inspectors by requesting a free On-site Consultation Program from your Regional or Area office. It is far better to ask for their help in establishing a safe workplace than to be surprised by large fines and big delays in operations.
Now, let’s dig into some of the harness features that the manufacturer catalogs are always touting and will help you choose the best harness for your employees.
Comfort. Comfort may not immediately seem like a “feature,” but when you start exploring the world of OSHA harnesses, there is a wide spectrum of harness designs based on industry needs. Blain Pettit of FrenchCreek Fall Safety (and Adrenalin Gear) notes that the harnesses they design for the aerial adventure industry “must be easy to don, adjust, and be extremely comfortable for both long and short durations,” because of the varied nature of the work.
Comfort is a result of three elements: padding (size, rigidity, placement), adjustability of harness for all areas (including multiple sizes), and overall design, such as the shape of the neck strap. More padding does not necessarily equal a better harness, as it is critical to consider the temperature effects and sweat-promoting areas of the harness padding in warmer climates, among other factors.
Attachment points. When considering a harness, it is important to consider how it will integrate with the overall fall protection system in place, as well as the equipment the operator will be required to interact with during normal operation and emergency response. Again, this is a balance of having enough attachment points to safely perform the work, but not so many that it is cumbersome to work within the constraints of the harness.
For OSHA 1926 and ANSI Z359.11, the dorsal attachment is required, and will be featured on almost every professional work harness regardless of intended use. Most employees in a general aerial adventure operation will also need a pre-sternal or waist attachment to properly attach to the required course equipment.
Beyond these two main attachment point considerations, one must consider the various modes in which the harness must perform, including rescues, site-required operator equipment (first aid, water, rescue device, gloves, radio, etc.), and the different types of courses or attractions. Additionally, it is critical to educate yourself and your staff on which attachment points are rated for what type of attachment, as many inspectors have witnessed, to their horror, employees attaching their lifeline to a gear loop and expecting it to hold.
Buckle style. Sometimes the smallest of details make the biggest impact, and this is true of harnesses, especially when you must wear one for your entire shift. The ease of donning and adjusting a harness is often dictated by the buckle style chosen by the manufacturer and employer. Whether the buckles are self-locking double-back (adjustable but closed-loop), automatic (seatbelt style), tongue style (standard belt), or pass-thru buckles, take the time to consider the advantages and disadvantages of each buckle style for the harness’s intended use.
Our industry is still growing and evolving daily, and the agencies around us are still learning the ropes while trying to figure out the best ways to protect workers and participants. As this evolution continues, gray areas will continue to emerge and disappear. With the increasing number of employers and employees engaged in the aerial adventure industry, there comes a greater exposure to risk that justifies the increase in safety and regulation.
Training will take on greater importance as well. Those of us who have been involved in the industry for many years or decades cannot take our years of experience for granted. As a new and growing generation of employees moves in with a minimal level of knowledge, employers must take head-on the charge of protecting and training and equipping their employees to the best of their ability, and to the degree that experts and regulators have determined to be appropriate.