There is much confusion surrounding OSHA regulations regarding re-certification of engineered fall protection systems and inspection requirements for the personal protective equipment (PPE) used in conjunction with these systems. The question, “When must I recertify or inspect?” seems simple, but the answers are a bit complex because you won’t find an OSHA regulation specifying inspection and re-certification timetables. Instead, you’ll find language stating engineered systems and PPE must be inspected /and /or re-certified by a competent person on a schedule specified by the manufacturer. At DFP, we recommend inspection and recertification on an annual basis. It is also important for employees to visually inspect their PPE and the fall protection system before each use. Although this language sounds vague, you should also know that while OSHA does not mandate a specified inspection and re-certification schedule that is universally applicable to all fall protection equipment manufacturers, their inspectors do insist on record keeping. In short, you must document compliance with manufacturer inspection and re-certification guidelines to avoid citations and penalties.
In a previous post, we highlighted our new, wireless technology called I-Safe that utilizes RFID tags to maintain a paperless log documenting inspection cycles. This system is fast and easy to use, but we understand that the high-tech approach isn’t everyone’s cup of tea. For those looking for a simpler approach, we provide downloadable PPE inspection logs. Remember, to be in compliance, these inspections must be completed by a “qualified person.”
For DFP installed engineered systems, we keep duplicate records documenting specifications as well as repair and re-certification paperwork that may be required during an OSHA inspection. All too often, EHS managers mistakenly assume PPE is safe and compliant because the equipment arrived with packaging or accompanying product literature referencing OSHA compliance. The only way to remain in compliance is to follow the recommended inspection schedule (under the watchful eyes of a competent person) and to document this activity.
If you are purchasing your PPE from a catalog house or an online retailer, you are quite possibly missing important steps in the compliance process. Remember, re-certification and inspection require time and money, but it is impossible to place a price tag on a human life, so get these tasks done to ensure everyone goes home safe each night. To learn more about inspection and re-certification requirements or services, contact the fall protection experts at Diversified Fall Protection for more information.