At the 2012 SPRAT Annual Meeting, the membership asked the Board of Directors to address what was at that time a recent notice from Petzl, recalling their previous guidance regarding the use of the Shunt as a rope access backup device. To that end, earlier this year the SPRAT Board of Directors passed the following motion:
SPRAT recommends that rope access technicians ALWAYS follow manufacturer’s instructions when using products. Evaluators shall consider any use of equipment in a manner contradictory to the manufacturer’s instructions to be a discrepancy each time the action occurs. In the case of the Shunt, the manufacturer specifies that the device may not be ‘towed’ by a string during use, and that it may not be used with a lanyard. Petzl recently issued clarification that although this use has become colloquially acceptable among users, it is explicitly outside manufacturer’s instructions.
With this in mind, the SPRAT BOD hereby directs Evaluators that they shall issue a discrepancy for any use of this (or any other product) in a manner that is contradictory to the manufacturer’s instructions during an evaluation, with a separate discrepancy issued each time the misuse occurs.
In order to give sufficient time to clarify this matter to Evaluators, Trainers, and candidates, until October, 2012, Evaluators may choose to issue a warning rather than a discrepancy during evaluations where the Shunt is used with a lanyard, so long as the potential fall factor on the Shunt does not exceed FF1, and so long as the Shunt is moved only when the candidate is in a secure, stopped condition on the main line. After this date, Evaluators are expected to enforce the manufacturer’s instructions explicitly.
While the intent of this motion was to clarify the issue raised at the Annual Meeting, it inadvertently created potential concerns with other pieces of rope access gear, particularly as relates to using equipment in a manner not addressed by manufacturer’s instructions.
In addition, concerns were raised about how to evaluate candidates during testing when fall clearances are not sufficient for rope access backup equipment to perform normally.
The Standards Operating Committee will be asked to ensure that these questions are addressed in future revisions of SPRAT’s Safe Practices and Certification Requirements documents. In the meantime, the SPRAT Board of Directors passed the following two motions in an effort to provide interim guidance to evaluators and technicians:
Motion 1: When it is necessary to use rope access equipment during training or operations in a manner that is not covered in the equipment manufacturer’s instructions, such use shall be the responsibility of the organization training or/and employing the end user. In such cases, the organization must ensure that adequate procedures are established and that the end user has received relevant training based on documented in-depth risk management. The complete risk mitigation concept must bring the likelihood and the consequence of all potential hazards down as low as reasonably practical. For the purposes of evaluations, this information shall be made available to the Evaluator upon request.
Motion 2: In the case of evaluations, when it becomes necessary for candidates to demonstrate the proper use of equipment at low heights where clearance requirements are not met for proper function of that equipment, the candidate should be protected from the hazards of a fall as is reasonably practical. In such cases, the lack of clearance shall not be considered a discrepancy as long as the equipment is otherwise being used properly.
Clearly the intent of the organization is that technicians are adequately protected from foreseeable hazards. For the purposes of evaluations, it is incumbent upon the candidate (or the host) to prove to the evaluator that methods being used are adequate and appropriate. The evaluator will make a determination to the best of his/her ability based on the information available, and any controversial judgments may be appealed according to established SPRAT practices.
If you have any questions on this, please contact Pete Lance at SPRAT headquarters at 610-971-4850.