Engineered fall protection systems were created as the result of the implementation of European Occupational Risk Prevention standards and regulations.
Once the basic risk prevention requirements had been regulated, the product standards relating to fall protection systems were developed.
Thus, there are two European standards governing fall protection systems, depending on whether the system is horizontal or vertical:
The marketing of all types of products within the European Union is governed by legislation regulating product safety related aspects. If the product in question complies with the provisions of the relevant legislation, then it can bear the CE Mark. The level of strictness of the certification procedure varies according to the type of product.
The fall protection system certification procedure is perhaps the most controversial issue in the fall protection industry, with regard to whether or not the provisions governing fall protection systems are compulsory.
In any case, it should be noted that it's a complex matter. We're now going to discuss it in the sections below.
However, before addressing the issue, we would mention that, in our opinion, the root of the problem lies in the fact that the regulations do not clearly define whether or not fall protection systems are PPE.
As you are no doubt aware, there are two types of Occupational Risk Prevention measures:
Collective measures provide protection against the hazard, with no need to use any other means (guardrails for work at height, for example).
For the same purpose, personal protection measures require a person to use a Personal Protective Equipment. A PPE is something that is fixed to the body (a harness for example).
Collective protection measures have priority over individual ones. According to the Law on Occupational Risk Prevention, PPE shall only be used when it is not possible to use collective measures to protect against the hazard in question and only if the collective protection measures are insufficient and there is no other way to protect against the hazard.
Los medios de protección colectiva son prioritarios frente a los individuales. Según la Ley de Prevención de Riesgos Laborales, sólo se utilizarán los Epis cuando ese riesgo no pueda protegerse con medios colectivos. Cuando el medio de protección colectivo sea insuficiente.
The specific PPE items for working at heights are:
These items come within the definition of what Personal Protective Equipment should be: equipment that serves to provide protection against a risk (the fall) and can only be worn by one person. For this reason, the PPE items on the list are regulated by directive 686/1989 on PPE, which is shortly to be replaced by a new version of this standard.
According to this same directive, being PPE that protect against a risk that may cause loss of life, they are classified as Category III and therefore require the strictest certification procedure in order to obtain the CE certificate.
So far, everything is clear, but what about fall protection systems?
If various persons can be hooked up to the fall protection system, is it a personal or collective means of protection?
If fall protection systems are considered to be PPE, then shouldn't they be worn by the user?
There is an endless debate on this matter.
Some countries within the European Union hold that a fall protection system is a PPE because it requires the use of other PPE, forming a system or set. Other countries, on the other hand, don't see it that way ...
The matter of whether fall protection systems are intended for one user or for several users can also be understood to go against the very nature of Personal Protective Equipment which, as its name suggests, is intended only for one user.
As things stand, there is no consensus for the unanimous approval of a standard to regulate fall protection systems and to thereby harmonise the legislation. Because, as you're no doubt aware, mandatory EU regulations must be unanimously approved in the European Commission by all representatives of the member countries.
In view of the foregoing, we have now reached our current situation.
In general, and as mentioned above, the situation is complex. In our opinion, the most serious consequence of this situation is that, today, anything goes. Any cable installed on a roof and which is certified by whoever as a fall protection system, can be used as such.
And this is serious, because it may happen that:
Fall protection systems cannot be treated as the only elements foreseen to prevent or arrest a fall. They are part of a groups of components making up a fall arrest system.
The same thing is true for the PPE classified as such for work at height
They serve no purpose unless they are part of a fall arrester system.
Personal Protection Measures are directed at providing protection against a specific hazard. For example, a face mask is intended to prevent the inhalation of toxic gases, and its purpose is to offer complete protection from this hazard.
The same is not true of a harness, which needs to be hooked to a safe anchorage point that has been manufactured and installed to withstand the impact generated by the fall.
Both also require a cushioning element, either an energy absorber or a retractable device. The set of all these components forms a fall arrest system.
A complete standard is dedicated to the regulation of systems of this type, namely EN 363. This standard includes all the fall arrest system variants that could be used when employing personal protective equipment for work at heights.
As far as standards are concerned, there is no difference between temporary and permanent lifelines.
Neither the EN 353 nor the EN 795, establish durations of time for the installation of the lines; whether they can only be used once or whether they can be used over a period of time.
With regard to vertical lifelines, it could be understood that those regulated in EN 353-2 are more temporary in nature than the rigid systems (EN 353-1), however this is not an explicit distinction.
As far as use is concerned, it is possible to make the following distinctions:
These are basically used on construction sites, where they serve to perform work that will not be repeated on a regular basis and it makes more sense to use a system of this type.
These lifelines are generally mounted in places in which periodical maintenance work is performed.
With regard to horizontal systems, EN 795 makes a clear distinction between rigid and flexible lines, while EN 353 also attempts to do so, although not with complete success.
At times, the classifications even vary from one standard to the other.
In EN 795, steel cable lines are considered to be flexible. While in EN 353 they can be used for what are known as rigid lines (EN353-1) and also for those classified as flexible (EN 353-2).
On the other hand, EN 795 establishes that flexible lines (EN 795-C) require a calculation to be made. While EN 353 does not establish this obligation. Something which, on the other hand, seems to make sense.
Lifelines can have a whole range of uses.
As already mentioned above, lifelines are intended to arrest the fall within a safe distance.
But they can also be used for work positioning and fall restraint.
This is the intended purpose of almost all lifelines.
There must be a system in place to arrest the fall at a distance that is less than the estimated fall height for the case in question.
Any type of lifeline, whether rigid or flexible, must be able to comply with the fall arrest function.
Why simply arrest a fall if it can also be prevented? A fall restraint is when the system, comprising the lifeline and PPE, is used to prevent a fall from happening.
Not all lifelines can be used for restraint purposes, neither are all PPE suitable. It must be a solution intended for a specific case. In order to achieve restraint, it is necessary to know how to use the lifeline and the PPE connecting the lifeline with the user's harness. It is not possible to achieve this effect in all the circumstances in which lifelines are installed. For example, on a crane running track, there can be no fall restraining.
As well as fall arrest and / or restraint, lifelines can also be used for rope access works.
Rope access lines are systems that make it possible to be suspended from the lifeline.
The requirements to be met by a lifeline of this type are far more restrictive than those contemplated for other systems.
The key difference with regard to a fall arrest system is that, for work positioning, which is the term used in the standard, a constant static load must be supported, in addition to the occasional dynamic load generated by the fall.