After careful deliberation, the Society of Professional Rope Access Technicians (SPRAT), in an effort to support certified rope access technicians and their employers within the United States and internationally, respectfully expresses our opposition to the voluntary standard, ASSP/ANSI Z459.1 Safety Requirements for Rope Access Systems (Z459.1).

Though falls from height remain a leading cause of workplace fatalities in the United States (Source: BLS), rope access workplace fatalities have remained practically non-existent. This difference is partly attributable to a number of established rope access organizations that provide certification schemes and accessible standards to facilitate a comprehensive rope access program meeting regulatory requirements. Z459.1 needlessly departs from these existing rope access standards, as well as the Z359 Fall Protection Code (Z359), placing unnecessary restrictions on rope access training, systems, and equipment. Adopting and implementing Z459.1 would needlessly disrupt and complicate the adoption of rope access as a viable, lower-risk alternative to other forms of fall protection in the United States and abroad.

Training Requirements
Ensuring that personnel are provided appropriate training to address worksite hazards is fundamental to any employer’s safety program. To ensure the appropriate use of applicable fall protection systems and procedures, Z359 requires a needs-based approach to training in accordance with ANSI/ASSP Z490.1. Unfortunately, Z459.1 fails to adopt this successful approach. Fundamental rope access skills, such as change-overs, rope-to-rope transfers, and passing knots, are notably absent from the training requirements of Z459.1. In many situations, Z459.1 requires training of all personnel, irrespective of their roles or responsibilities, in advanced rope access techniques that may be unrelated to a worksite. As a result, rope access technicians, certified to Level 1 by an established rope access organization (e.g., ANETVA, DPMC, FISAT, IRATA, SOFT, SPRAT, SRAA), trained in all techniques suitable for a worksite, and working under appropriate supervision would still be unable to work in compliance with the standard.

Rope Access Systems and Equipment
Z459.1 places unfounded restrictions on the construction and configuration of rope access systems. There are no regulatory requirements, worksite hazards, or foreseeable misuses of equipment to justify these limitations. For example, dual main systems, a proven approach to reduce clearance requirements in applications with significant amounts of rope in service, would not be in compliance with this standard. In addition, Z459.1’s equipment requirements do not provide metrics to assist with regulatory compliance or the standard’s own system requirements, and will unnecessarily limit the availability of appropriate rope access equipment.

SPRAT would support a prudent standard that represented modern rope access, protected rope access technicians, and ensured regulatory compliance. Unfortunately, Z459.1 falls woefully short of these goals and fails to provide an achievable, sensible pathway for incorporating rope access within a comprehensive fall protection program. Based on this determination, we cannot currently provide support for the implementation of this standard.

Approved by the SPRAT Board of Directors, August 2021