Regulatory Assistance FAQs

SPRAT

Regulatory Assistance FAQs

Regulatory Assistance FAQs

No.

OSHA’s General Duty Clause of the OSH Act (29 U.S.C. § 654, 5 (a) (1)), which is further supported by 29 CFR § 1910.9 among other regulations, requires an employer to furnish a safe work environment for their employees.

While OSHA’s 29 CFR § 1910.27 does not apply to industrial rope access systems, topics covered under that regulation, such as stabilization at a work location significantly lower than the anchorages of a two-rope system as well as the availability and usage of certified anchorages, should be considered as part of providing a safe work environment. 

Rope access systems are only one component of ensuring a safe work environment. Additional components can be found within SPRAT’s Safe Practices for Rope Access Work, which include, but are not limited to training, certification (skills verification), and an access work plan including risk assessment and rescue preparedness.

Yes.

Section 3.1.3 of SPRAT’s Safe Practices for Rope Access Work states: “Policies and procedures shall be consistent with requirements of the presiding regulatory authority related to the work environment to ensure that such requirements are followed by all rope access technicians when conducting work.”

Section 3.1.4 further clarifies the previous clause, stating: “Where a presiding regulatory authority has requirements that are stricter than this standard, those requirements shall be followed.”

As stated in the Federal Register Vol. 81, No. 223 on page 82569, “In the final rule, OSHA added language to the definition of RDS expressly specifying that RDS do not include industrial rope access systems (IRAS) (§ 1910.21(b)). As such, final§ 1910.27 does not cover or apply to IRAS. However, other sections of the final rule, including § 1910.28, do cover IRAS.”

29 CFR § 1910.28(a)(1) states that: “…the employer must ensure …fall protection systems required by this section meet the criteria of § 1910.140.

29 CFR § 1910.140 provides requirements for personal fall protection systems, including requirements for gate strength of connectors and carabiners (29 CFR § 1910.140(c)(8)) and anchorages 29 CFR § 1910.140(c)(13).

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