This is the second part of a two-part article on PPE by the author. The first, “What PPE Must an Employer Provide?” ran in the April 2022 issue of TCI.
Where was I? In the April issue, we discussed the employer’s responsibilities for personal protective equipment (PPE). We continue the topic this month with an emphasis on climbing equipment and inspection.
A mechanic should have his or her own tools. Same thing for tree workers, right? Wrong. When you think about PPE, what do you think of? Head protection, eye protection, hearing protection, chain-saw chaps or pants, hi-viz clothing and maybe boots. But what about a carabiner? Surely that can’t be considered PPE. That’s gear, right?
Here’s the bottom line – if it keeps you from falling, it’s PPE. Pop open the booklet on most carabiners, positioning devices or harnesses, and what will you find? “This fall protection is used for PPE,” or something to that effect. That simple connection makes a huge difference in the mindset of climbing equipment.
Don’t think of it as, “PPE and gear.” There’s “traditional PPE” and “fall-protection PPE.” Both protect the user, and the employer has an obligation to supply both. Sorry employers. Also, not sorry.
OSHA 1910.132 states that PPE “shall be provided by the employer at no cost to the employee.” OSHA citations are a great thermometer for the safety temperature of the overall industry. What’s top of the list? PPE. Fall protection. Coincidence? Nope.
So, you’ve issued an employee some climbing gear. Maybe they know a knot or two. Done? Time to get in the tree? No.
OSHA 1910.132(f)(1) states, “The employer shall provide training to each employee who is required by this section to use PPE.” The section then goes on to describe the requirements for training. Use, maintenance, proper fit, lifespan and retirement criteria all fall under the obligations of the employer when issuing PPE.
What else is required? ANSI Z133-2017 3.1.2 states, “Employers shall instruct their employees in the proper use, inspection and maintenance of personal protective equipment (PPE).” 8.1.3 goes further with, “Arborists shall inspect climbing lines, work lines (line, work line), work-positioning lanyards and other climbing equipment for damage, cuts, abrasion and/or deterioration before each use and shall remove them from service, per the manufacturer’s guidelines, if applicable, if signs of excessive wear or damage are found.”
So we know that climbing equipment is PPE. We know training is required. We know that part of the training is how to inspect. Now, how do we inspect? We could spend days discussing the intricacies of every cordage type, carabiner gate style and mechanical device, but we’ll start with the basics.
Is it fit for the purpose? Sounds simple, but these days all kinds of new equipment is being introduced into tree care, particularly from other industries or disciplines. Just because a particular cordage has the correct rating and diameter does not mean it is fit to handle the heat incurred when using it as a friction hitch. Ask yourself, is the working load limit sufficient for the work? Is it compatible with other components?
An alarming issue that is on the rise is copycat equipment that can easily be ordered online. It may look like equipment made by a reputable manufacturer, but on closer inspection it can be of subpar quality. The best way to verify if things are fit for their intended purpose is to check the document that accompanies the equipment. If there is not a technical notice or user instructions, then immediately look for a manufacturer’s website with documentation on the device. If you cannot find any information on a device or component, please do not use it!
Once you’ve established what it is and how to use it correctly, it’s time to inspect.
Start with head protection. A visual and tactile inspection should expose any defects that could affect the performance of the PPE. Is the shell cracked, fractured or showing signs of significant impact? A more thorough inspection can be done with suspension-style helmets than with the foam style. On brighter-colored helmets, you can see discoloration on the inner shell when there has been a significant impact on the outer shell. What would be cause for retirement of the helmet? Check the document from the manufacturer that came with the helmet.
Harnesses. So many wonderful types. They used to be so simple. The materials used to be steel, leather and canvas – easy to understand, easy to inspect. Now we have aluminum and synthetic materials and attachment points that involve screws. However, the actual inspection process hasn’t changed much.
Start with the bridge or main attachment point. Harness bridges are a common item to be failed in the gear-inspection process. Generally, textile inspection is similar for a harness bridge, rope, work-positioning lanyard and friction-hitch cordage. Are there cuts? Frays? An important question to ask is this: Is the bridge material the same as specified by the manufacturer for that particular harness? Not every piece of cordage that meets the breaking-strength requirements in Z133 is fit for the purpose of a harness bridge.
Webbing, straps and buckles must all be checked, too. Do the buckles correctly latch every time? What condition are the straps in? Move the harness around to check – many modern harnesses have wear points that run through rings and need to be moved to check the condition.
Rope and cordage. So many options – 3-strand, 12-strand, 16-strand, 24-strand, 32-strand, 48-strand, hollow-braid, single-braid, double-braid, kernmantle – it can be overwhelming. The inspection criteria are similar for all types.
The two pieces of equipment I see needing retirement most often are work-positioning lanyards and the ends of rope close to a splice. Climbers tend to justify keeping a rope past its usable condition because a splice is a useful feature with modern systems and devices. Work-positioning lanyards take abuse from handsaw cuts and tend to get hung up on chain saws while traversing through the canopy. Again, tactile and visual inspection should be adequate to uncover any defects.
One item in the process is often overlooked – irregular diameter. This can be an indication that the rope was overloaded at some point. How many strands can be cut before retirement? It depends on the manufacturer and construction of the rope. Check the manufacturer’s specifications for answers.
Connecting links. Shiny aluminum, am I right? Frames need to be checked for cracks, pitting, excessive wear and corrosion. The most common reason for retirement is generally gate function. The gate must automatically close completely – every time, and from all opening distances. A good way to test the gate function is to open the gate only slightly several times, rather than the full distance of the hinge. If the gate is contacting the nose of the carabiner when closing, it may mean the carabiner has been loaded incorrectly and misaligned the gate.
Can you clean a carabiner that is not performing to standard? Yes. Check the manufacturer’s documents, not only for guidelines on cleaning procedures and maintenance, but also the type of lubricant. Graphite powder used to be the industry standard, but manufacturers have been moving away from that recommendation.
Fall-protection equipment inspection is not a “should,” it’s a “shall.” Users and employers are obligated to ensure that PPE is in safe working condition. When equipment is questionable, the best course of action is to replace it. Replacing equipment is an easy decision when the alternative is an employee being injured due to a fall.
Mike Tilford, CTSP, is director of general tree care for SavATree, a 36-year TCIA member company headquartered in Bedford Hills, New York. He is an ISA Certified Arborist, a Municipal Specialist, a Certified Tree Worker – Climber Specialist and an ITCC head judge and gear inspector.
Best Practices of Safety in Arboriculture
This captivating manual is basically an illustrated guide to the Z133 Safety Standard with additional action steps to mitigate risk. Trainers can pair this manual with the Tailgate Safety Training Program and/or other industry references as a way to freshen daily/weekly crew training sessions. Click here code to view this product in TCIA’s online store.