With their new standard, 1910.140-Personal Fall Protection Equipment, OSHA has met a critical need for general industry employers who have employees performing work at heights. Much of the new standard is old-hat…information we were already familiar with as a result of applying fall protection requirements previously found in the construction industry standards (1926, Subpart M). However, one statement goes against conventional wisdom and bares further scrutiny by employers who plan to permit the use of knots in life-safety systems. OSHA states at 1910.140(c)(6), “A competent person or qualified person must inspect each knot in a lanyard or vertical lifeline to ensure that it meets the requirements of paragraphs (c)(4) and (5) of this section before any employee uses the lanyard or lifeline.”
I had always been told, and always taught, that knots reduce the strength of a lanyard or lifeline by as much as 50% and, therefore, were not allowed to be used in fall protection components. So, why would OSHA require the inspection of knots if knots aren’t allowed?
The popular consensus standard, Z359.1-2007, does not allow the use of knots. OSHA gave this consideration when studying comments and available information from such industry experts as the Society of Professional Rope Access Technicians (SPRAT) and the Cordage Institute. Based on their study, OSHA determined it is safe to use knots in some circumstances as long as they meet the breaking strength requirements in 1910.140(c)(4) and (c)(5). So, in keeping with their efforts to make the standard as much performance-based as possible, OSHA decided to allow the employer to decide if knots used in a given situation are safe. But, you can’t simply have the local Boy Scout troop give it their blessings. Employers who allow the use of knots must assure they are inspected by a competent or a qualified person and deemed to be strong enough to meet the minimum requirements.
Just to remind you, a competent person is “a person who is capable of identifying existing and predictable hazards in any personal fall protection system or any component of it, as well as in their application and uses with related equipment, and who has authorization to take prompt, corrective action to eliminate the identified hazards.”
A qualified person is “a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.”
OSHA further states the worker making the knot must be adequately trained to know the strength of the rope being used and take into consideration any strength reduction that may occur if a knot is used.
So, unless you have knot experts on the payroll, it may be better to simply prohibit the use of knots in components of life-safety systems such as travel restraint, fall arrest and positioning systems. Feel free to contact me at (800) 717-3472 or btaylor@ei1.com should you have questions and need further clarification.