18 Aug Can a Connector Be Unbreakable?
Changes to the OSHA Regulation 1910.140 Personal Protective Equipment (PPE) have arrived. The largest change is the inclusion of the 3600 lbs. or 16 KN gate strength for carabiners and snap hooks.
Many people are familiar with this because it is a copy and paste from ANSI Z.359. Before the release of 1910.140 the industry best practice was to use ANSI rated gates, however it was not an OSHA requirement.
This requirement sets a new precedent in the realm of equipment misuse.
With the new requirements, carabiners are now strong enough to withstand a severe loading, even when cross-loaded.
In a fall arrest situation (per OSHA 1910.140(d)(1)(iii)) the free fall must be no more than 6 ft. resulting in a force transferred to the body of 1800 lbs. or less (1910.140(d)(1)(i)). The system strength criteria (1915.159(a)(9)(i)) has long set the stage for all fall arrest systems to have a SSSF (Static System Safety Factor) of at least two. This has been followed by the updated 1910.140(c)(11)(ii).
By following this logic, any carabiner that has the 3600 lbs. (16KN) gate would qualify for misuse in any situation.
The issue I take with designing products this way is that it opens a Pandora’s Box situation. We are designing products strong enough to be used in the wrong configuration rather than teaching people to be cautious and intelligent when dealing with situations that could kill them.
The irony of the situation is that the larger gate causes cross-loads.
The mass and girth must be increased to be able to withstand the force. This enlargement causes the gate to protrude into the space inside the carabiner resulting in a shelf on top of the gate where the gate meets the nose. This shelf catches on many things commonly connected to carabiners, making the cross-load strength a self-fulfilling requirement.
I am always excited to see progress in the world of safety.
It is my opinion that a 3600 lbs. gate is a great addition to the requirements. It will save lives, and has already made a huge impact since the first products were released in 2007 (ANSI).
By no means can we ever engineer out the potential for users to misuse equipment, by intent or accident. It is up to the end users to make smart choices and use the equipment in a responsible manner.
The biggest challenge the fall protection industry faces is not the breaking open of carabiner gates, it is implementing a culture of 100% tie off.
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