The miles of piping and pipe racks associated with oil and gas refineries are in need of constant repair, maintenance, painting, and pipe re-routing, exposing workers to fall hazards when adequate fall protection is not in place. Most of this work is done at heights, with few or no structural elements overhead from which to install fall protection. Although some some sections of pipe rack require regular, routine maintenance and inspection, your refinery may also have sections of pipe that are only visited every ten years. As a safety director, how do you balance OSHA compliance and protection of maintenance personnel with the need to provide cost effective fall protection for enormous lengths of exposed pipe?

• HLL/VLL
  • 1926.502(d)
    'Personal fall arrest systems.' Personal fall arrest systems and their use shall comply with the provisions set forth below. Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system. Note: The use of a body belt in a positioning device system is acceptable and is regulated under paragraph (e) of this section.
  • 1926.502(d)(8)
    Horizontal lifelines shall be designed, installed, and used, under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two.
  • 1926.502(d)(9)
    Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN).
  • 1926.502(d)(10) 1926.502(d)(10)(i)
    Except as provided in paragraph (d)(10)(ii) of this section, when vertical lifelines are used, each employee shall be attached to a separate lifeline.
  • 1926.502(d)(11)
    Lifelines shall be protected against being cut or abraded.
  • 1926.502(d)(12)
    Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard in the fully extended position.
  • 1926.502(d)(13)
    Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position.
• Ladders
  • 1926.1053(a)(18)
    Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels.
  • 1926.1053(a)(19)
    Where the total length of a climb equals or exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
  • 1926.1053(a)(19)(i)
    Ladder safety devices; or
  • 1926.1053(a)(19)(ii)
    Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
  • 1926.1053(a)(19)(iii)
    A cage or well, and multiple ladder sections, each ladder section not to exceed 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2 m).
  • 1926.1053(a)(20)
    Cages for fixed ladders shall conform to all of the following: