New anchor point standard - seeing the forest from the trees ...
By Michael Biddle, Managing Director, Capital Safety and Current Chair, Working at Height Association
Wednesday, 08 October, 2014
In October 2013, Standards Australia released AS/NZS5532 - a new Australian and New Zealand standard defining the manufacturing and testing requirements for anchor points used in fall protection. Since its release, there has been a lot of commentary and concern from industry about the impact of the standard and its implication for equipment users. This article explores the reasons behind the creation of the standard and its implications for industry.
What is a fall protection system?
Every fall protection system should have five key elements. They are easily identified as the A,B,C,D,E of fall protection:
A is for Anchor point - a high-strength device from which to to anchor yourself;
B is for Body harness - ideally a fall-arrest-rated product that will secure you in the event of an unplanned fall;
C is for Connector - a device to connect between your anchorage point and body harness, with an energy dissipation mechanism to remove the full impact of fall forces;
D is for Descent and rescue - a plan and/or equipment to ensure you can be safely retrieved after a fall event; and
E is for Education - ensuring you have to right training to perform safe work while at height.
Fall protection systems are required when a risk assessment of a job identifies no practical alternative to perform a job safely exists, other than climbing to a location to work at height.
How did the new standard come about?
For quite some time, Australian consumers, manufacturers and distributors have relied on the various codes of practice issued by state regulators and Safe Work Australia, as well as the AS/NZS1891 standards to determine best practices for working at heights. These codes and standards have generally served industry well. While AS/NZS1891.1 defines the manufacturing and testing requirements for B (Body Harnesses) and C (Connectors), it does not prescribe testing methods for A (Anchorages). It simply defines the ‘performance criteria’ for anchors. For example, it prescribes that an anchor point for fall arrest for a single person is defined as being able to sustain a force of 15 kN, but does not say how a product must be tested to confirm that performance.
The Working at Height Association (WAHA) has been interested in addressing this discrepancy. Its members noted the shortcoming in the AS/NZS1891 standard represented an issue for consumers. A manufacturer may well claim their product can deliver to the performance criteria, but how would a consumer know something is safe for use without some type of testing to back it up? This might not be an issue if you are making a product less critical than a device that a person trusts their life on; however, anchor points are for that very purpose.
Under the funding model required for the creation of new standards, WAHA then decided to sponsor the creation of a new standard to mitigate this real risk - that a product being sold on the market without any validation testing would be removed from consideration by consumers.
Was there any scrutiny undertaken by independent experts on the new standard?
Standards Australia adopts a very public process in its development process. The committee that has previously undertaken the drafting and amendments to the AS/NZS1891 standard is the same committee of experts that were engaged to oversee the issue of AS/NZS5532. Known as the SF015 committee, the group comprises representatives of a wide range of industry associations, end users, workplace regulators and other interested parties. Once amendments are made, these comments are circulated to the public for feedback and potential changes, in an attempt to remove ambiguity. Given the lengthy time to draft and review the process, in the end AS/NZS5532 was subjected to two separate rounds of public comment, prior to its formal release.
What are the immediate implications of the standard?
In many cases, manufacturers may previously have had their products tested to the ‘performance criteria’ as noted in the AS/NZS1891 standard. For example, an anchor point manufacturer may have performed either a dynamic or static test (or both) on an anchor they make in their own test lab, or that of third party. If they were satisfied the product could sustain the performance, the product may well then be marked as complying with the requirements of AS/NZS1891.
The difference with AS/NZS5532 is that now the testing requirements for all anchor points are the same. The standard details the test weight, the drop heights, the configuration of testing equipment and other methods that will allow all anchors to be defined as passing. This consistent test methodology therefore provides a higher degree of certainty that manufacturers can not only claim conformance with a standard, but more importantly can provide a product certification.
There is no legal requirement to test and sell a product to the new AS/NZS5532 standard. If a product does, however, get subjected to this test regime and is then certified by a third party such as SAI Global or BSI Benchmark, then this provides the consumer with a greater level of assurance that a product not only conforms to the standard but that it has been rigorously tested to the same criteria as all other complying products on the market.
What if my anchors don’t carry a certification mark to AS/NZS5532?
There is nothing illegal about continuing to use a product that does not carry a certification mark to AS/NZS5532. It is essential, however, that you conduct a risk assessment to determine whether a product used for fall arrest will provide the level of protection required. It is best to contact the manufacturer of the products to gain that assurance, or to utilise an inspection service that has the expertise and training from the manufacturer to ensure that the products continue to be safe for use.
Are my existing anchor points unsafe?
Just because a new product standard is released, it does not immediately mean that an existing product is unsafe for use. The release of the new standard simply sets out a new testing regime for anchors to be tested to. It is quite possible that the existing products that you have installed already pass the testing requirements of the new standard. It is best to contact the manufacturer or your installer directly about whether their product will comply with the new standard, or at least advise a time when they might be verified as compliant. A risk assessment is therefore the first step in determining the continued use of product in the absence of any certification information being available.
Is there a phase-in period for implementation of the standard?
In many cases in industry, a phase-in period is deemed appropriate to allow consumers and manufacturers the time to make adjustments to their products, retest them and certify or recertify them in line with a new standard. A 12-month time frame is frequently cited as a suitable phase-in period; however, there are no guidelines available from Standards Australia for this standard.
Given that the manufacture of fall protection equipment to Australian and New Zealand standards is not mandatory under legislation, it could be argued that back-certification may not be required. An argument frequently given is that old model cars without seat belts are not required to have them installed as they were made before new legislation was brought into being. As a matter of due diligence and risk mitigation, however, we would recommend action be undertaken to have products upgraded to the new standard as soon as practical.
Can I continue to use my existing products?
There is no legal reason why you cannot continue to use your existing installed permanent anchor products. It is, however, recommended that you perform a risk assessment as to the safety of the product prior to continued use. If the manufacturer can supply certification information or other testing data to validate the performance of the products in use to the new standard, then existing products should be suitable for ongoing use, provided they are installed according to the manufacturer’s instructions and that they pass ongoing inspection requirements.
I have contacted the manufacturer, but they will not respond. What can I do next?
There is no doubt that a number of manufacturers have been caught a little short in getting their products tested and certified to the new AS/NZS5532 standard. This testing delay is not easily solved. The transition to the new standard is very expensive for manufacturers. They are required to potentially procure a new testing rig and perform back-testing on all their products on different roofing profiles and structural materials. Alternatively, third-party testing labs are not yet well equipped to get the testing done in a short time frame. In short, this process is not easy to get done quickly.
Therefore, it is recommended that you request information from the manufacturer as to when the testing information is likely to be available, if at all. If the manufacturer has no plans to test the existing products to the new standard, then you need to make an assessment about continued use of your existing product. Replacement of a newly certified alternative might be considered the best alternative in that instance.
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