ACTIVE FALL PROTECTION IN GENERAL INDUSTRY Seminar/2019Jan.pdf · 2019-01-13 · 1/7/2019 1 ACTIVE FALL PROTECTION IN GENERAL INDUSTRY Presented to: Delaware Valley Association of

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ACTIVE FALL PROTECTION IN

GENERAL INDUSTRY

Presented to: Delaware Valley Association of Structural Engineers (DVASE)

January 9, 2019

Presented By: Ryan M. Firkser, PE, SE, CSP

PRESENTATION TO DELAWARE VALLEY ASSOCIATION OF STRUCTURAL ENGINEERS (DVASE) | 01.09.2019 1

Learning Objectives

� I want you to leave this presentation:

� Able to identify a potentially hazardous condition or deficient fall

protection system

� Able to ask the right questions of the design team and/or end

user/owner during design development

� Confident in “owning” the engineered design and documentation

of an anchorage in your structural package

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What?

� Single Point Active Systems in General Industry:

� Regulations, Codes & Standards

� The Lingo

� Loads

� Design Considerations


Why?

� Professional

� Engineering Ethics

� Safety is Paramount

� Niche that needs a home

� Liability

� Ultimate Fail Safe = Our Structure

� Where are the construction details?

� Get with the times

� For your family & employees

� For your practice

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Where?

� General Industry – OSHA 29

� Maintenance (1910) vs Construction (1926)

� “OSHA SPACES”

� Industrial and Manufacturing

� Mechanical Spaces

� Secure Rooftops

� Workplace/Occupational Safety vs Public Safety

� Authorized Users Only

� In the future – International Building Code? Is the future already here with Pennsylvania adopting IBC 2015?


When?

� Hazard Elimination or Separation is not feasible, reasonable or might create a greater hazard.

� Low Frequency Task

� Some Fortune 100 Companies: < 6x Annually

� Greater Frequency = Greater Likelihood of Abuse

� The owner/employer is committed:

� User Training Maintained

� Strong Safety Management Program with Executive Commitment

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Hierarchy of Safety Controls


Anything That Will Be Missing?

� Yes. Today, we are NOT talking in depth about

� Construction Activity & Sites (OSHA 1926)

� Suspended Maintenance & Window Cleaning Anchorages or Equipment (Façade Access)

� Horizontal Lifeline Systems

� Confined Space & Rescue Systems

� Fixed Ladder Vertical Safety Systems (24’-0”)

� Rope Descent Systems

� “Passive” Fall Protection

� Administrative Controls

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Regulations, Codes & Standards


Occupational Safety & Health Administration (OSHA)� 29 CFR Part 1910 “Occupational Safety and Health Standards”

� Subpart D “Walking-Working Surfaces”

� Revisions effective January 17, 2017 are the first revisions since inception in 1971

� 29 CFR Part 1926 “Safety and Health Regulations for Construction”

� Subpart M “Fall Protection”

� There are distinct differences between the general industry (1910) and construction (1926) regulations

� Active fall protection was not even addressed in Part 1910 until January 2017

� One key difference: fall protection trigger height

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OSHA: General Industry vs. Construction

� General Industry: “….making or keeping a structure, fixture or foundation in proper condition in a routine, scheduled or anticipated fashion….”

� Preventative Maintenance

� Predictable & Routine, Repetitive Scheduling

� Scale & Complexity of Task

� Physical Size of the Object Being Worked On

� How can the precedent for OSHA regulation be established?

� Restrict access or use to authorized persons only

� Permit Systems

� Locks and Alarms


ANSI Z359 “The Fall Protection Code”

� National consensus best practice specification

� Ten (10) Standards in the specification

� Most of which address fall protection program management

and component/device performance and testing

� One of which is specifically intended for engineers:

Z359.6 “Specifications and Design Requirements for Active

Fall Protection Systems”

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OSHA 1910 vs. ANSI Z359

� OSHA: Regulation. Compliance is a legal obligation of the employer. Enforceable.

� ANSI Z359: Voluntary. Not enforceable unless adopted by code

� Does the end user’s safety management program mandate ANSI Z359 compliance?

� Does the building code mandate ANSI Z359 compliance for a specific application?

� Some key differences:

� Total Fall Distances

� Definition of Competent and Qualified Persons

� ANSI Z359 provides more robust technical guidance, whereas OSHA is more requirement driven


OSHA vs. ANSI – Competent Person

� OSHA 1910: A person who is capable of identifying existing and predictable hazards in any personal fall protection system or any component of it, as well as in their application and uses with related equipment, and who has authorization to take prompt corrective action to eliminate the identified hazards

� A competent person can designate a 5,000 pound anchorage

� A competent person can perform workplace assessments and equipment inspections, and be responsible for oversight of system installation and use

� ANSI Z359: An individual designated by the employer to be responsible for the immediate supervision, implementation and monitoring of the employer’s managed fall protection program who, through training and knowledge, is capable of identifying, evaluating and addressing existing and potential fall hazards, and who has the employer’s authority to take prompt corrective action with regard to such hazards

� Similar responsibilities to OSHA, except that a competent person cannot specify and/or design systems and anchorages

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OSHA vs. ANSI – Qualified Person

� OSHA 1910: A person who, by possession of a recognized degree, certificate or professional standing, or who by extensive knowledge, training and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work or the project

� A qualified person can perform similar duties to a competent person. In addition, they can supervise the design, installation and use of horizontal lifeline systems and certified anchorages

� ANSI Z359: A person with a recognized degree or professional certificate and with extensive knowledge, training and experience in the fall protection and rescue field who is capable of designing, analyzing, evaluating and specifying fall protection and rescue systems to the extent required by these standards

� ANSI Z359.6 states that any fall protection system shall have drawings and/or specifications prepared under the direction of a registered Professional Engineer


IBC/ASCE & Active Fall Protection

� Active Fall Protection – IBC 2015:

� Section 1015.6 Mechanical equipment, systems and devices

� Exception to guardrails for ANSI Z359 active protection

� Specific Reference to ANSI Z359:

� Precedent for any future incorporations of active fall protection

� Could upset the industry

� Current implications for some rooftop anchorages

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IBC/ASCE & Active Fall Protection

� Suspended Maintenance - ASCE 7-16 & IBC 2015:

� Live load requirements for elements supporting hoists for façade access equipment

� Live load requirements for lifeline anchorages for façade access equipment

� Distinction remains between suspended maintenance and general industry fall protection

� Outside of IBC 2015 Section 1015.6 and for façade access systems, there are no additional references to active fall protection systems

� Still a ground breaking precedent


Additional References

� OSHA’s preamble to the final rule for walking-working surfaces [Federal Register Volume 81, No. 223]

� 486 Pages of Commentary to 25 Pages of Regulation

� OSHA’s Standard Interpretations: https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear

� ASCE Task Committee on Façade Access’ Design Guideline “Façade Access Equipment Structural Design, Evaluation and Testing” 2015

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Learn the Lingo:Definitions


Active Fall Protection

� ANSI Z359: A fall protection system that requires authorized persons to wear or use fall protection equipment…..

� Two (2) Primary Types of Active Fall Protection

� Fall Restraint: the user connects to an anchorage using a lifeline or lanyard that is short enough such that their center of gravity cannot reach the hazard

� Fall Arrest: does not prevent a fall from occurring, but is designed such that the fall is “arrested” prior to the user striking a lower level or obstruction

� Significant Owner Responsibilities & Associated Risks

� Heavily reliant upon the User

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Fall Restraint

� Fall Restraint is preferable but is often difficult to configure and manage, and is exceptionally prone to abuse and misuse

� Secure, stable walking-working surfaces

� Dedicated lifeline length

� Doesn’t have to be a fall edge

� Dangerous or Moving Machinery

� Open Vessels

� Design anchorages for FALL ARREST loads

� Mark them!


Fall Arrest vs. Fall Restraint

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Personal Fall Arrest System (PFAS)

� A-B-C, It’s Easy as 1-2-3!!!

� A: Anchorage + Anchorage Connector

� B: Body Wear

� C: Connecting Subsystem


A: Anchorage

� ANSI Z359: A secure connecting point or termination point of an active fall protection system

� OSHA: A secure point of attachment for equipment such as lifelines, lanyards, or deceleration devices

� Anchorage Connector: A component of a subsystem that links the fall protection system with the anchorage

� To Your Client: Tie Off, Anchor Point, Pick Point, Eyehook, U-Bar, Yo-Yo Hook, etc, etc, etc

� In Practice: “Anchorage” + “Anchorage Connector”

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Examples of Anchorage Connectors


A: Anchorage

� Single Point Anchorage:

� One (1) anchorage connector for attachment of one (1) fall protection subsystem

� Single User

� Overhead Anchorage:

� Installed overhead and above the user

� Overhead Superstructure or Dedicated Framing System

� Rooftop (Leading Edge) Anchorage:

� Cantilevered post or wall mount at walking-working surface elevation and near foot level of the user

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B: Body Wear

� 99% of the time: Full Body Harness

� Contains the torso

� Distributes fall arrest forces over at least the upper thighs, pelvis, chest and shoulders

� If the user doesn’t intend to utilize a full body harness as part of the PFAS

� Not necessarily non-compliant, but time to ask questions


C: Connecting Subsystem

� ANSI Z359: Assembly of components between the anchorage connector and the body wear

� Self-Retracting Lifeline (SRL) <<< GREAT TOOL

� Shock Absorbing Lanyard <<< MOSTLY ANTIQUATED IN GENERAL INDUSTRY

� Can be more than a single component

� Free Falls Greater than 6’-0”

� To Your Client: Cable, Equipment, Device, Yo-Yo, Fall Arrester, Round thing with a carabiner

� In Practice: “Lanyard” or “Lifeline” [“SRL” or “Retractable”]

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Personal Fall Arrest System (PFAS)

� A-B-C, It’s Easy as 1-2-3!!!

� A: Anchorage + Anchorage Connector

� B: Body Wear


� It’s really A-C-B

� “Always Check Before” providing engineering consultation


Always Check Before

� “Always Check Before” providing engineering consultation

� Materials Handling vs Fall Protection (never both)

� Can it be managed, inspected and maintained over time?

� Does the layout pass the sniff test?

� Who is the qualified person? Who is the competent person?

� Does the owner expect:

� Controlled Descent & Rescue?

� To anchor a horizontal lifeline (HLL)?

� To utilize the anchorage(s) for suspended maintenance or façade access in the future?

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Anatomy of an Overhead PFAS

� A: Anchorage

� Anchorage Superstructure

� Anchorage Connector


� Self-Retracting Lifeline (SRL)

� B: Body Wear

� Full Body Harness


Anatomy of a Rooftop or Leading Edge PFAS

� A: Anchorage

� Anchorage Structure

� Rooftop Posts

� Anchorage Connector

� Most often at foot level


� Self-Retracting Lifeline (SRL)

� Abrasion Resistance

� Cable Lifeline

� SRL-LE

� In-line Energy Absorber

� B: Body Wear

� Full Body Harness

� Suspension Straps

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Loads: The Legend of the 5,000 Pound Rule...Kind Of


Toyota Tacoma: 4,480 LB Curb Weight

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Female Orca: 5,000 LB Average Mature Weight


2018 Phillies Active Roster: 4,785 LB Combined Player Weight

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ANSI Z359 Performance Requirements

� Anchorage Connector Component:

Capable of withstanding 5,000 pounds without breaking (static)

� Self-Retracting Lifeline – Line Constituent:

Synthetic Rope & Webbing: Minimum breaking strength of 4,500 pounds (static)

Wire Rope: Minimum breaking strength of 3,400 pounds (static)

� Self-Retracting Lifeline – Overall Performance:

Capable of withstanding 3,000 pounds without breaking (static)

Maximum Arresting Force of 1,800 pounds (dynamic) with residual

strength of 1,000 pounds in the line constituent


ANSI Z359 Analytical Methods

� Acceptable Analytical Methods:

� Dynamic Analysis – all active fall protection systems

� Energy Analysis - all active fall protection systems

� Static Analysis – limitations apply

� Testing and Interpolation Analysis – prototype testing

� Let’s try to stick with STATIC ANALYSIS. You can do so for single point anchorages if the following conditions are met:

� Personal Energy Absorber or Self-Retracting Lifeline is used to control the maximum arresting force

� Worker weight is less than 310 pounds (combined person & tools)

� Free fall is less than 6’-0”

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Static Design Load

� IBC 2015 & ASCE 7-16: Lifeline anchorages for Façade Access Equipment

� Live Load = 3100 POUNDS

� ASCE Façade Access Equipment Design Guideline

� “While OSHA defines the loading that structural elements need to be able to support, OSHA specifications are not consistent with commonly used structural engineering literature and standards. In addition, OSHA does not specify how element strengths are to be established.”

� To facilitate use by structural engineers and with common structural engineering design standards, the unfactored LIVE LOAD for fall arrest anchorages should be 3100 POUNDS in every direction that a fall arrest load might be applied


IBC 2015 – Façade Access

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What Does it Mean?

� It establishes in accepted engineering literature and with engineering principles the precedent that the OSHA 5,000 Pound load is a factored load

� Latest revisions to IBC and ASCE support this

� You will satisfy OSHA requirements by…

� Considering a fall arrest anchorage service live load of 3,100 Pounds (unfactored)

� Considering that load as a Static Force when MAF is controlled

� Utilizing the same conventional analysis methods, codes and specifications that you use everyday

� Forget the “5,000 Pound Rule” and embrace the “3,100 Pound Rule”

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Factor of Safety Case Study

� “3,100 Pound Rule” with Conventional Methods

� Allowable Strength Design Provisions (ASD)

� Structural Steel in Flexure, Ω = 1.67

� Single User Anchorage, 1800 Pound MAF Device

� Factor of Safety Against Yield = (3100 LB ÷ 1800 LB)*(Ω = 1.67) = 2.872

� “5,000 Pound Rule” to Yield (Common Practice)

� Factor of Safety Against Yield = (5000 LB ÷ 1800 LB) = 2.778


Still More to Know…

� The “3,100 Pound Rule” is for non-certified anchorages

� OSHA does allow for certified anchorages that are designed, installed, and usedunder the supervision of a qualified person, as part of a complete personal fall arrest system that maintains a factor of safety equal to 2.0 (Ultimate Load)

� 1,800 LB Maximum Arresting Force = 3600 LB Ultimate Load (2,250 LB Live Load)

� 900 LB Maximum Arresting Force = 1800 LB Ultimate Load (1,125 LB Live Load)

� The easy part for structural engineers: Anchorage Design & Supervision of Installation

� The difficult part for structural engineers: PFAS Specification & Ensuring Proper Use (especially over time)

� OSHA does allow for these responsibilities to be split amongst parties

� Owner Commitment/Clear Delineation & Communication of Responsibility

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Summary - Loads…

Forget “The 5,000 Pound Rule” and embrace “The 3,100 Pound Rule” for single point fall protection

anchorages in general industry

The “3,100 Pound Rule” DOES NOT apply to davit bases, outriggers, rooftop carriages or equipment tieback anchorages for suspended maintenance or

façade access.

The “3,100 Pound Rule” DOES NOT apply if the maximum arresting force is not controlled.

The “3,100 Pound Rule” DOES NOT apply to horizontal lifeline systems.


Personal Fall Arrest System

Design Considerations

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Common Abuse and Misuse…

� Checklist Oversight: “Where’s your harness?”

� Not verifying available fall clearances or considering device selection

� Shock absorbing lanyards

� Ignoring obstructions

� Working outside of the protected zone

� Active systems with impossible rescue, inspection or maintenance

� Repeating prior approved methods without proper assessment of each unique space and/or task

� Engineer designing an anchorage without knowing the intended function


Fall Clearances – Rigid Anchorage

� Fall Clearance:

The distance from a specified reference point, such as the walking-working surface or anchorage of a fall arrest system, to the lower level or obstruction that a user might encounter during a fall

� The Available Fall Clearance must greater than or equal to the Total Fall Distance plus a Safety Margin

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Fall Clearance Calculation

Components:

1. Free Fall Distance

2. Deceleration Distance

3. Stretch Out

4. Swing Fall Distance

5. Safety Margin

� Total Fall Distance = 1 + 2 + 3 + 4

� Required Fall Clearance = Total Fall Distance + Safety Margin

= (1 + 2 + 3 + 4) + 5


1. Free Fall Distance

The vertical distance travelled during a fall incident and before the fall protection system begins to arrest the fall.

� 6’-0” maximum free fall unless special considerations are made in development of the PFAS

� SRL: 2’-0” maximum “activation distance” – or amount of line paid out before braking or stopping forces are applied

� Don’t forget lanyard or lifeline slack

� Anchorage below D-Ring = increased free fall distance

� Interstitial spaces, vaults/cold boxes, walkable ceilings

� Foot level anchorages: Rooftops

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Free Fall Distance


2. Deceleration Distance

The vertical distance travelled from activation of the fall protection system to arresting of the fall.

� Highly variable based upon selection of the connecting subsystem

� Self-retracting lifelines perform better than lanyards

� 3’-6” maximum allowable

� Use lesser values only if supported by manufacturer testing performed in accordance with ANSI Z359 and if device selection can be managed over time

� Shorter Deceleration Distances = Higher Arresting Forces

� Longer Deceleration Distances = Lower Arresting Forces

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3. Stretch Out

The additional fall distance resulting from body elongation and flipping of the D-Ring during a fall arrest. Plus additional considerations for elasticity

and improper fit of the body wear.

� ANSI Z359 separates these components

� Body Elongation & D-Ring Flip: 1’-0”

� Harness Contribution: 0’-6” to 2’-6” (*)

� Total: 1’-6” to 3’-6”

� OSHA: 1’-0”

� Manufacturer Literature & User Instruction Manuals: ???


Stretch Out

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4. Swing Fall Distance

The vertical drop in height of a user’s D-Ring during a swing fall incident, as measured at the lowest point during the fall.

� Travelling horizontally from your anchorage = Swing Fall Potential

� ANSI Z359: 4’-0” Maximum “Swing Drop Distance”

� Manufacturer Literature & User Instruction Manuals: Considered in Fall Clearances Tables & Figures


Swing Fall Distance

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5. Safety Margin

A clearance factor of safety between the lowest extremity of the user’s body and the level and/or obstruction below after arresting of the fall and stretch

out.

� ANSI Z359: 2’-0”

� OSHA: 2’-0” (*)

� Manufacturer Literature & User Instruction Manuals: ???


Self-Retracting Lifelines (SRL)

� Activation Distance: The amount of line paid out by an SRL from the onset of a fall to the point where the device begins to apply a braking force.

� 2’-0” maximum

� Maximum Arrest Distance: The total distance traveled from the onset of a fall to arresting of the fall.

� Manufacturer specifications

� (1. Free Fall Distance) + (2. Deceleration Distance)

� Can be misleading if there is slack in the lifeline

� ANSI Z259: Class A SRL = 2’-0” Max (RARE)

� ANSI Z259: Class B SRL = 4’-6” Max (Common)

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OSHA vs. ANSI Z359 vs. Manufacturer Literature

� ANSI Z359 calculations result in the largest required fall clearances

� ANSI Z359 suggests that OSHA stretch out values might be undervalued

� Manufacturer Literature:

� Great fall clearance tools in graph and table format

� Considerations to stretch out and safety margins are largely uncommunicated

� Result in the smallest required fall clearances


Manufacturer Literature

� A minimum available fall clearance of 6’-0” is specified for most devices

� A minimum available fall clearance of 4’-0” is specified for some devices

� But……….

� Class A MAD = 2’-0”

� ANSI Harness Contribution to Stretch Out = 3’-6”

� Safety Margin = 2’-0”

� 7’-6” > 4’-0”

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Fall Clearances Study

� Overhead Anchorage with 4’-6” Maximum Arresting Distance Self-Retracting Lifeline (SRL)

� Minimum Required Fall Clearances

� OSHA = 7’-6”

� ANSI = 10’-0”

� Remember IBC 2015 reference to ANSI Z359

� What assumptions are the manufacturers making for their published charts and tables?


Swing Fall Hazards…

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Swing Fall Hazards…


Fall Clearances – Surprises

� Trucks at a Loading Dock

� Parking Lots

� Forklift Traffic

� Equipment at Ground Level

� Entry Canopies

� Trees & Shrubs

� Piping & Utilities

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Considerations – Overhead Anchorage

� BEST: Directly above the hazard in relation to the user’s D-Ring

� IDEAL RANGE: Lifeline angle 0 to 15 Degrees from vertical

� Connecting Subsystem: SRL with tagline

� Triple check fall distances against available clearance:

� Horizontal movement from directly beneath anchorage

� Less than 10’-0” of available clearance

� Unknown complete personal fall arrest system (PFAS)

� Unknown end user safety management program

� Additional Considerations:

� Lifeline Interference with Performance of the Task or Mobility

� Future Inspection & Device Maintenance


Considerations – Rooftop Anchorage

� BEST: Work area directly perpendicular to anchorage

� IDEAL RANGE: Lifeline angle 0 to 15 Degrees from horizontal

� Triple check fall distances against available clearance:

� Horizontal movement along the leading edge

� Less than 20’-0” of available clearance

� Unknown complete personal fall arrest system (PFAS)

� Unknown end user safety management program

� Additional Considerations:

� Safe access to the anchorage

� Abuse

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Brief Summary:

� A-C-B: “Always Check Before” providing engineering consultation

� “The 3,100 Pound Rule”

� Make sure it works……

� Overhead Anchorage, Fall Clearance < 10’-0”

� Rooftop Anchorages, Fall Clearance < 20’-0”

� Horizontal Movement

� Anchorages not elevated above the user or slack in the system


Something Smell Fishy?

Don’t Guess, Don’t Punt

CALL OR EMAIL ME!!

Ryan Firkser, PE, SE, CSP

610-209-2895

[email protected]

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QUESTIONS?

Documents

ACTIVE FALL PROTECTION IN GENERAL INDUSTRY Seminar/2019Jan.pdf · 2019-01-13 · 1/7/2019 1 ACTIVE FALL PROTECTION IN GENERAL INDUSTRY Presented to: Delaware Valley Association of