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Fall Arrest

Published: 10th Jul 2004 in Health and Safety International

Fall Arrest

Life hangs by a thread - or a fall arrester?

Fall arresting systems save many lives. Many tests and experiments are carried out in laboratory and on site to gain experience. This is a report from TÜV Austria, Notified Body under the European Directive for Personal Protective Equipment (89/686/EEC).

Safety is a human right…

but it is not a mathematical value. Laws contain general requirements for safety but in case of accidents each case is to be considered separately and expertise is needed. Court decisions often create insecurities for people responsible for the safety of products as well as for the users of these products. How do you decide the right way to prevent accidents from falls from height?

Legal requirements and standards

The Directive 89/686/EEC for PPE

PPE against falls from height are covered by this Directive and considered as category III. This means, that all these products need:

  • a type examination certificate and
  • supervision of the production

both carried out by a Notified Body. The products have to be marked clearly with the CE mark, containing the identification number of the Notified Body that carries out the supervision of the production.

The scope of the Directive is wide and covers PPE for use at the workplace as well as for use at sports and leisure activities, i.e. mountaineering equipment in particular.

Because it is not always clear for manufacturers which kind of PPE is covered by the conformity assessment procedure for Cat III in detail, the Coordination Group VG 11 of Notified Bodies published the "Recommendations for Use", listing the PPE against falls from height covered by the PPE Directive and belonging to Category III.

Occupational PPE:

  • Guided type fall arresters on a rigid anchorage line (EN 353-1)
  • Guided type fall arresters on a flexible anchorage line (EN 353-2)
  • Lanyards (EN 354)
  • Energy absorbers (EN 355)
  • Work positioning system (EN 358)
  • Retractable type fall arresters (EN 360)
  • Full body harness (EN 361)
  • Connectors (EN 362)
  • Anchorage devices, class B + E (EN 795)
  • Low stretch kernmantel ropes (EN 1891)
  • Sit harnesses (EN 813)
  • Descenders (EN 341)
  • Deck safety harnesses and lines (EN 1095)

Mountaineering PPE:

  • Accessory cords (EN 564:1997)
  • Tapes (EN 565:1997)
  • Slings (EN 566:1997)
  • Mountaineering ropes (EN 892:1996)
  • Harnesses (prEN 12277:1997)
  • Connectors (prEN 12275:1997)
  • Chocks (EN 12270:1997)
  • Frictional anchors (EN 12276:1997)
  • Ice anchors (EN 568:1997)
  • Pitons (EN 569:1997)
  • Pulleys (EN 12278:1997)
  • Rope clamps (EN 567:1997)
  • Energy absorbing system for use in Klettersteig climbing (EN 958:1997)
  • Ice tools (prEN13089:1996)

Rescue equipment according to standards EN 1496, EN 1497 and EN 1498 is not considered to be PPE. This formal decision of the Standing Committee 89/392/EEC (Commission Machinery Directive) creates problems in cases where equipment is also used as PPE. For these cases it must be certified for the PPE functions. It is being considered to include rescue equipment in the revised PPE Directive, which is in preparation.

Descender devices, which can also be used for lifting persons, are also covered by the Machinery Directive 98/37/EC, Annex IV. This means that an EC-type examination by a Notified Body under the Machinery Directive has to be carried out as well. This kind of equipment is mostly used for work in canalisation shafts or in manholes.

Exclusions from the PPE Directive (e.g. armed and police forces) are not given to fire-fighters. The equipment they use is PPE with regard to the Directive. Depending on their nature they have to be considered as category II or III. This is a very general view of the Commission and excludes all exceptions; for instance, the Equipment used by the firefighters from Paris or by the sailor's firefighters from Marseille has to conform to the PPE Directive, even though both belong directly to the French Ministry of Defence.

Components of PPE like rope clamps, trolleys on anchor lines or fall arresters are to be considered and tested together with the whole PPE. Nevertheless they can be removable and are also placed on the market as separate items. In the latter case it seems useful to have a CE mark and instruction on the component as well, provided the instruction gives clear requirements for the use in the completed PPE (description of the rope to be used, maximum loads and load cycles, etc). Unfortunately, opinion about this marking is not uniform in all Member Countries.

Anchorages devices according EN 795 class A, C and D are not PPE. Any EC-type examination issued for these classes has to be withdrawn. This is an official decision of the EU Commission.

Emergency parachutes and hang-gliders, etc are not PPE. The Directive stipulates that such equipment must be attached to a reliable anchorage point. At TÜV Austria there are investigations about these products in preparation.

The European standards (EN)

PPE is presumed to conform to the basic health and safety requirements referred to in Article 3 of Directive 89/686/EEC if it conforms to the harmonised standards to which a reference has been published in the Official Journal of the European Communities.

Attention should always be given to which components are placed on the market respectively which is the whole PPE system brought into service for use.

CE marking has to apply to the complete PPE product placed on the market. The product has to be accompanied by an instruction manual, including all components of the complete PPE.

The European standards for PPE are to be used in combination. There are specific standards for specific products (see list of PPE above) and there is a common standard for test methods (EN 364) and for marking and information/instruction (EN 365). Requirements for materials to be used, dimensions, conditions for the tests and limit values on the energy and forces the PPE has to withstand are laid down in the specific product standards.

Which references are to be used when there are no standards? In every case, whether a harmonised standard exists or not, it is the requirement of the Directive that must be satisfied. Respecting a harmonised standard gives only an assumption of conformity to the Directive. Standards other than harmonised standards do not give a presumption of conformity but may provide usable references.

When harmonised standards are lacking, other standards, such as state of the art, pertinent technical documentation or analogies relating to equipment for which a standard exists provide useful references on how to demonstrate respect of the essential requirements.

Revision of standards - what changes?

Current certificates remain valid, provided there is no safety reason for the revision. However, manufacturers have the responsibility to keep abreast of changes and to modify their products in the light of these changes to continue to supply safe products, which may necessitate the issuing of a new certificate.

The Certification procedure

EC-type examination is required for all products in Category II and III, in other words all PPE listed above. For PPE in Category III supervision of production is also required.

The Certification procedure consists therefore of two parts:

  1. EC-type examination:
    • After choosing a Notified Body the manufacturer or his authorised representative sends a sample of the PPE (including technical documentation and instruction) to the Notified Body for testing
    • The Notified Body carries out all tests required (normally according to EN) and checks the information provided for this PPE. In case of a positive test result they issue an EC-type examination Certificate.
  2. Supervision of production:
    • After choosing a Notified Body for supervision (can be the same as for type-examination) the manufacturer has the choice of ordering:A. a regular re-test (at least annually) of PPE samples chosen by the Notified Body (Directive Art. 11A) orB. a supervision (at least one annual audit) of his quality assurance system (Directive Art. 11B)
    • The Notified Body carries out respectively:A. the appropriate tests necessary to check if the conformity of the products with the type examination is still givenB.1 assessment of the quality assurance system andB.2 supervision of the system by regular audits to check if the system still guarantees the conformity of the product with the type examination

The manufacturer or his authorised representative receives a report about the result of the supervision from the Notified Body.

The identification number of the supervision Notified Body has to be applied together with the CE marking on the PPE before placing it on the market.

Does an existing ISO 9000 quality system replace supervision by a Notified Body?

A quality system cannot replace the requirements of the Directive. The Notified Body is able to take into account existing certificates relating to QA systems (ISO 9001/9002/9003) if it is convinced of the qualification of the certification body (accreditation, mutual recognition and others).

What are the "appropriate tests" for Art. 11 A?

The fundamental tests specified in the relevant harmonised standards are the "appropriate tests". In general, the following tests can be used:

  • Guided type fall arrester on a rigid anchorage line drop test according to EN 353-1:1992
  • Guided type fall arrester on a flexible anchorage line dynamic drop test (100 kg) according to EN 353-2:1992; if necessary, an additional drop test with 150 kg
  • Lanyard: Static test according to EN 354:1992, and when is standard will be amended for adjustable lanyards: dynamic fall test (100 kg) according to EN 354:1992, if necessary
  • Energy absorber: Drop test (100 kg) according to EN 355:1992
  • Work positioning belt: As harness
  • Retractable type fall arrester: drop test (100 kg) according to EN 360:1992
  • Harness: A complete visual examination is fundamental to compare the sample with the EC Type examination sample. At least one test (static or dynamic) is necessary
  • Connector: Static strength test (15 kN) according to EN 362:1992

It is not possible to certify a product in compliance with a standard where one or more requirements of the standard are not satisfied. The product may nevertheless be certified in compliance with the essential health and safety requirements of the Directive.

Practical experiences in testing and certification

The complexity of PPE against falls from height raises a lot of questions in the interpretation of the PPE Directive and the corresponding testing and certification procedures. Some actual examples are given here:

  1. Examples for minor changes in PPE products:

    • Change in trade mark
    • Change in reference
    • Change in marking

    Documents to be supplied by the manufacturer are:
    • Formal letter from the manufacturer describing the change(s) in the equipment and confirming that there is no further modification
    • Manufacturers technical specification relative to the change
    • Sample or specimen

    Conditions of validity are:
    • Delivery of an EC type examination extension
    • The extension file is to be kept in the file of the original equipment
  2. Examples of changes to be verified by re-examination:

    • Change in the colour of a strap or a sewing thread
    • On a harness, an addition, removal or modification in an accessory support device
    • An addition, reduction or modification in a size (harness size or lanyard length)
    • Change in length of a lanyard on a retractable type fall arrester

    Documents to be supplied by the manufacturer are:
    • Formal letter from the manufacturer describing the change(s) in the equipment and confirming that there is no further modification
    • Manufacturers technical specification relative to the change (drawing, parts list, letter from subcontractor, etc)
    • One example of the modified equipment for verification and storage
    • And one example of the original equipment for comparison with the modified equipment

    Conditions of validity are:
    • Examination of the modified equipment
    • Delivery of an EC-type examination extension
    • The extension file is to be kept in the file of the original equipment
  3. Examples of essential changes requiring specific or partial tests:

    • On a belt, a change in the type of carriage gaurd
    • On a harness, a change in the metal buckle (material, dimension, treatment, etc)
    • On a harness, a change in the dorsal plate
    • On a connector, a change in the anti-corrosion treatment
    • On a retractable type fall arrester, a change in the termination

    Documents to be supplied by the manufacturer are:
    • Formal letter from the manufacturer describing the change(s) in the equipment and confirming that there is no further modification
    • Manufacturers technical specifications relative to the change (drawings, parts list, letter of subcontractor, etc)
    • One or several specimens of the modified equipment, or one or several samples of the modified component for performing the test
    • One specimen of the original equipment for comparison with the modified equipment

    Conditions of validity are:
    • Performance of specific tests on the modified equipment
    • Delivery of an EC-type examination extension
    • The extension file is to be kept in the file of the original equipment

    When equipment is modified several times it becomes necessary to query the continuation of the original certificate! Major changes (in materials, arrangements of straps/seams or attachment points on a harness, of components or anchorage lines on fall arresters, etc) require a new EC-type examination in any case.
  4. Examples of major changes requiring an EC-type examination:

    • On all PPE types, simultaneous or successive changes in components requiring processing as in sheet no. 11.008
    • On a harness, a change in the arrangement of straps and/or seams
    • On a harness, a fundamental change in strap (width, material, etc)
    • On a harness, an addition, removal or shifting of an attachment point
    • On a lanyard, a change in the termination (slice, ferrule, etc)
    • On a retractable type fall arrester, a fundamental change in components
    • On a guided type fall arrester on anchorage line, a change in the fall arrester (principle, configuration, material, etc) or in the anchorage line (diameter, material, etc)

    Documents to be supplied by the manufacturer are:
    • According to the EC-type examination

    Conditions of calidity are:
    • According to the EC-type examination procedure
    • The equipment is subjected to specific storage and identification

Tests of anchor devices (EN 795)

As mentioned before, only anchor devices class B and E are considered to be PPE. The CE marking and instructions for use have to include the complete PPE.

The tests carried out for the certification are restricted to the components and anchor points in the testing procedure. Any auxiliary constructions applied when used on site are not usually covered by the certificate

Experience has shown that decisions about the use on site needs assessment by an expert, mostly in connection with additional static calculation and practical tests

Minimum ground clearance for the use of:

  • energy absorbers
  • guided type fall arresters on a flexible anchorage line

The coordination group VG 11 agreed on a requirement of an extra distance of 1 metre when tested according to the standards, taking into consideration the arrest distance and elongation of the equipment. This is to allow a clearance below the feet of the user to avoid a collision with the ground in a fall from height.

Type examination certificate - different applicants

Often for PPE the product name or the applicant is changed for market reasons. This has to be brought to the attention of the Notified Body who carried out the EC-type examination and, if it's another one, to the Notified Body who is responsible for the quality assurance system.

There can only be one type examination that several declarations of conformity can be issued on the basis of one type examination certificate.

Files for several product identifications

For files concerning PPE likely to have several product identifications there are two acceptable solutions:

  1. The original manufacturer or his authorised representative remains responsible for placing the equipment on the marketThe manufacturer is the certificate holder and establishes the declarations of conformityThe technical construction file indicates the different forms of product identification and markings as well as the trade name of the distributors. The various versions of the instruction handbook are subject to EC-type examination (with the exception of direct translations into foreign languages)
  2. The distributor or importer, acting as a manufacturer, is responsible for placing the equipment on the marketBeing responsible for placing the equipment on the market the distributor / importer must request an EC-type examinationThe certificate, or the extension to the certificate, is established in the trade name of whoever is responsible for placing the equipment on the market. He in turn establishes the declarations of conformity in his name

There is a variety of problems under discussion by the Coordination of Notified Bodies with the intention of gaining safe solutions in compliance with the Directive and to reach a common level in Europe. For users and manufacturers out there - we are trying very hard!

Author

TÜV Austria is a private independent Notified Body and is accredited as a third party Testing, Inspection and Certification Body.

Our activities cover a wide range of New Approach Directives (machinery, lifts, PPE, low voltage, emc, telecommunications, pressure equipment, medical devices, vehicles, cableway installations, etc), but also Sports, Playground and other Recreational equipment, environmental assessments, facility management and measurements of emissions/immissions are additional tasks. Hazard analysis and Certification of Products, Personnel and Management Systems complete our services.

We are ISO 9000 and EN 45000 (EN IO/IC 17025) and SCC certified and involved with the following international organisations: CEN and ISO standardisation, European Coordination of Notified Bodies, CEOC - Confederation of testing/inspection bodies, EUROLAB - Testing and ECOSA - Consumer Protection.

TÜV Austria Group - a multidivisional partner for technical safety!

Head Office:

Krugerstraße 16A - 1015 Vienna

Austria

Phone: +43 1 51407 - 0

e-mail: office@tuev.or.athttp://www.tuev.or.at

Affiliate companies:

  • TÜV Austria Hellas Ltd., Athens (GR)
  • UMSITEC GmbH, Gauting (D)
  • TÜV Ausztria Magyarország Kft., Budapest (HU)
  • TÜV Austria Iran repr., Tehran (IR)
  • TÜV Austria Malta repr., Valetta (MT)
  • TÜV Austria Cyprus, Nikosia (CY)
  • I.T.I. Integrovaná technická inspekce spol. s r. o., Prag (CZ)

Published: 10th Jul 2004 in Health and Safety International

Author


Adolf Russold



Adolf Russold

Website:
http://www.tuev.or.at

Email:
office@tuev.or.at

Phone:
+43 1 51407 - 0

office@tuev.or.at
http://www.tuev.or.at
+43 1 51407 - 0

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