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The Guardian Fall Team Blog

Throughout the ages there have been eternal questions that have eluded answering, rather, the search for an answer itself becomes the answer. What is the sound of one hand clapping? How many licks does it take to get to the center of a Tootsie Roll Pop? How much wood could a woodchuck chuck if a woodchuck could chuck wood? The world has waited and waited for answers to these questions, but alas, like the number of grains of sand on a beach, they too, as yet, are unknown.

How It All Began

Fall protection also has its share of chimeric questions, one of them is: What is a Leading Edge application? The answer, of course, will determine when it is necessary to utilize a Leading Edge compatible SRL, one which must be tested to enhanced ANSI requirements (see below). Without pointing too many fingers, I think part of the confusion of Leading Edge stems from the definitions given by both ANSI and OSHA. Before we begin to interpret them, let’s see exactly what they say:

ANSI A10.32-2012
A leading edge means the unprotected side or edge during periods when it is actively or continuously under construction.

OSHA 1926.751    
Leading edge means the unprotected side and edge of a floor, roof, or formwork for a floor or other walking/working surface (such as deck) which changes location as additional floor, roof, decking or formwork sections are placed, formed or constructed.

Late To The Party

As you consider these definitions, bear in mind they were made before ANSI applied the term Leading Edge to an SRL. That happened in 2012 with the release of the Z359.14 Safety Requirements for Self-Retracting Devices. In light of this fact, it’s not surprising that there might be some confusion as to just what Leading Edge means. So tell me, do these definitions match your own definition of what a Leading Edge is, or to be more precise, do they define the only circumstances in which you might want to utilize a Leading Edge compatible SRL? Based solely on these definitions, it’s arguable that once construction ceases, there is no such thing as a Leading Edge on a structure. Notice how both definitions tie a Leading Edge to work in progress. While I can understand the genesis of this definition - that a structure in the process of being built continually creates new, unfinished (and therefore potentially sharp) edges - the definitions fall short of warning against all of the potential situations where a lifeline or lanyard might impact a sharp, rough, or unprotected edge. The definitions seem overly narrow.

 

Leading Edge Small.jpg

 

Different Purpose, Different Test

To complicate this, let’s also briefly talk about the required dynamic performance test designed by ANSI that all Leading Edge compatible SRLs must comply with in order to be labelled (and used) as such. The test is designed to mimic a worker falling over an unprotected edge with their SRL tied off at foot level. A test weight of 282 lbs. is dropped a distance of 5’ so that the lifeline component of the SRL contacts an edge of 1018 steel with a radii of no greater than .005”. This should sound very familiar to those of you who work on or around structural steel. The test demands that the weight fall, the lifeline component remain intact after impact, and arrest forces stay within a predetermined range. In addition, an offset test, whereby the test weight is dropped in a manner to cause a “sawing” action of the lifeline across the edge, must also be conducted.

The test sounds, reasonable, right? Sure it does. But this is where we start to equivocate. Does ANSI mean to say (through the example of their test) that Leading Edge means only when the lifeline might contact structural steel? What about concrete? Galvanized roof panels? The edge of a tiled or slate roof? The edge of a shingled roof? The edge of a parapet? At what point (based on the given definitions and test) does an application cease to be Leading Edge and become something else? Is it when work is complete? Or when there is no longer a danger of the lifeline contacting steel? Is it acceptable for a lifeline to contact wood? Of course the point of avoiding lifeline/edge interaction in the first place is to prevent the forces of a fall from travelling up the lifeline and damaging it (through sheer force or abrasion) at the point of contact with the edge. If this happens, the potential exists for the lifeline (regardless of whether it is steel or webbing) to fail.

 

In The Midst of The Mist, Some Clarity

Given the rule-driven world we live in, these are real questions that can be (and have been) asked to try to nail down exactly what is meant by Leading Edge. After all, if employers and workers are going to be asked to comply with the rules, they had better be able to discern what the rule means in the first place, right? It seems part of the discrepancy between the letter of the rule and spirit of the rule is the speed at which reality moves compared to the speed at which the rules attempting to govern that reality move. And because reality moves faster than the rules, it is up to all of us in the fall protection world to carefully consider the evolving nature of the workplace and make cogent decisions with the goal of always raising the bar of safety as high as possible.

The bad news regarding what constitutes Leading Edge is that there is no definitive answer – yet, well at least not from ANSI or OSHA. When it comes to a Leading Edge application, Guardian’s policy is that any time there is the potential for a lifeline to come into contact with an edge of any material during a fall, it is considered a Leading Edge application, and a Leading Edge compatible SRL, such as our Halo, should be used.  We believe that employers and workers should proceed with an abundance of caution whenever there is the risk of lifeline/edge contact, period, whether it’s a roof, a floor, a beam, or the edge of a water tower. This is nothing to fool with. A lifeline is literally just that – treat it like one.