Safety harness damaged past the point of repair. Image credit: Hazmasters Canada
How long does a harness last? The industry standard of the “5 year expiration date” is deeply flawed; continue reading to find out why, and learn the considerations to help you make the right call.
It is paramount that safety professionals NOT fall into the trap which suggests that the manufacturer or OSHA be the deciding factor on when to retire a used harness or lanyard. There are way too many variables for anyone, including OSHA, ANSI, the manufacturer, or a distributor of these goods, to tell you when to discard your safety equipment–but here are some things to consider.
OSHA has at times, used (and abused) the ‘manufacturer’ as a rule maker. They cannot abrogate their duty to make rules to a private industry with selfish interests, and you should not allow them to imply they can. They cannot. They do use manufacturer’s guidelines as a tool to help determine whether there is a violation. For instance, if a ‘Competent Person’ does NOT take into consideration the manufacturer’s guidelines, they could say that he did not comply with the rules to properly inspect the equipment, which would imply that he SHOULD take into account the manufacturer’s guidelines. But saying that doesn’t make it so.
The Competent Person could have taken into consideration a more comprehensive set of guidelines put out by the webbing and fabric industry, or a more rigid instruction for another manufacturer that makes almost the same item. He could have conducted testing or gotten specific information from a source that is better than the manufacturer’s. This is readily seen, (sort of in reverse) if you look at all manufacturer’s guidelines and notice they all tell you to avoid knots… or, more strictly, NOT to use the device with any knots. In appendix C of the “Inspection and Design criteria for Safety Systems,” OSHA themselves tell you to take into consideration the manufacturer’s advisories. But they also tell you to account for and deduct for the use of knots in any safety system. Clearly, they allow that YOU, the Competent and Qualified Person can decide how and when to determine right from wrong, and a distant CSHO (Compliance Safety and Health Officer) or a manufacturer cannot. Similarly, the Competent and Qualified person should not operate under the assumption that the manufacturer will tell you when it’s time to throw out a given piece of equipment.
Regarding the 5-year “expiration” date that is common in the industry, this life expectancy is a general guideline. From the moment you open the bag the harness starts to deteriorate.
Specific instructions for use, inspection, and cleaning generally accompany the equipment, and it is important that these instructions are read and understood. However, regarding the 5-year “expiration” date that is common in the industry, this life expectancy is just a suggestion, and a loose one. From the moment you open the bag the harness starts to deteriorate. The manufacturer cannot usually tell you how many tiny little spatters of slag it takes to discard the harness, nor how many whiffs of chlorine at how much concentration in PPM it would take to degrade the material to a certain degree. The manufacturer cannot tell you, except generally, how many rays of sunshine–and at what elevation (that matters!) — it takes to degrade the item to a point it is too worn out or weakened to use. The manufacturer cannot tell you the effects of your sweat components (acid, alkalinity, salts), or of the amount of grit in your air, or the pollution in your work locations. Without question, the best person to tell an employer when to retire equipment is the Competent and Qualified Person on site, the one who has a sense of the degradation that accompanies slag, sun, sweat, etc.
So the manufacturer can’t tell me. OSHA can’t tell me. How do I, as the Competent and Qualified Person, make the decision to retire equipment?
Rest assured, the equipment has tremendous excess capacity, and the degradation that is common (not normal…) in a 3-5-year period does not render the device worthless on the 1st day of the 6th year. The manufacturer knows that a harness worn every day will likely not make the 5-year mark, not by a long shot. A heavy form carpenter or an iron worker can easily wear out a harness in less than a year. On the other hand, a harness that is properly stored and worn only for inspections and riding in boom lifts and on roofs, that is used once a week or once a month, may last a lifetime. The Competent Person is the deciding factor. Lanyards have a recommended 3-year use limit, but a similar degree of scrutiny and evaluation should be used in their evaluation.
Manufacturers can’t tell you about strength or loss of strength. What they can do is take your lanyard or harness back and test it, but that destroys it–and it’s a moot point whether it should be retired after that. Therefore, they could only provide more recommendations (still requiring the Competent Person to make the final decisions).
Let’s say you have 25 lanyards, all around the 3-yar mark, and really can’t decide what to do. So you decide to ask for a test. The manufacturer can test the material of three lanyards that YOU decide are the worst, because YOU agree that getting some data will help YOU make up YOUR mind. The webbing of all three lanyards are tested and it tells you that the break test shows that the webbing is about 25% diminished from when it was new. So the 10,000 break strength is now 7,500 lbs. Well, that is substantially more than the 5,000 lb minimum described by OSHA. YOU decide to keep using the remaining 22 lanyards, using the testing data as ONE of your many considerations for that decision.
The manufacturer can’t tell you to use the three that were tested, but it cannot tell you to use the other 22 either. It’s not their decision to make, and they bear little to no responsibility for the decisions your company makes. Most importantly, the other 22 are probably only safe to use if you can safely assume that all 25 lanyards have endured similar exposures–amounts of sun time, chemical time, sweat components, acid rain, storage locations, duration of use, wear on parts, etc. If one is used every day on the same exact grommet in the leg straps by one user, and the others are used on different settings since different users have them each day, the two will not degrade identically. So, this original manufacturer’s test is probably useful if the controlled experiment is applicable to the other 22 pieces of equipment–but the only person capable of making that decision is the Competent and Qualified Person. This is just one piece of data the Competent Person can use, but their goal is true occupational safety, not showing they did their ‘due diligence’. A manufacturer’s test can be helpful, but should be considered insufficient on its own. Similarly, keep in mind that is is good practice to mark Date of First Use on the harness tag. You should not necessarily use the date of manufacture as the beginning of the harness lifespan, but this date of first use.
Ultimately, it’s your decision. Gather data, gather resources, and account for all the factors–then make the right call.
Safety people: don’t turn your responsibility to train and make decisions and help others make rightful decisions over to a salesman or technician at some manufacturer. They will always default to ‘read the warnings and instructions, and advice and take our recommendations’, as if their attorney was speaking directly to you. It is THEIR responsibility to indemnify their organization; it is YOUR responsibility to keep YOUR people safe.
A Competent Person, as defined by OSHA, uses manufacturer’s recommendations and OSHA and ANSI rules as guidelines. Appendix C has a lot of helpful indicators and reminders to check for, too, and even this article might be one of your deciding factors.
At the end of the day, though, you make the decision. It would be prudent to all concerned to default on the side of the old adage: if there’s doubt, take it out. But by the same token, if there is no doubt it’s fine, then the safety professionals and Competent and/or Qualified Persons should be confident enough of their knowledge and observations and all things taken into consideration, and allow it to stay in service. And–this is imperative– document your choices and decisions on a separate record tied to the unit number of each piece.
Don’t turn your responsibility to train and make decisions and help others make rightful decisions over to a salesman or technician at some manufacturer.
OSHA realizes that manufacturers have three overall interests: making good products, getting paid, and protecting themselves from injurious lawsuits. Some will submit claims that imply and allege that the manufacturer has some duty they do not. They do not have a duty to inspect and approve equipment for use by your clients or employers.
That is your domain. That is the domain of a safety professional and a Competent or Qualified Person.
Make your decision, make it right, and keep your people safe for another day.
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