A Field Guide to Fall Protection Harness D-Rings

Modern fall protection harnesses often come with many attachment points for lanyards of different varieties. Understanding their proper use is critical. Photos: Malta Dynamics

Modern full-body harnesses for fall protection often come with many attachment points for lanyards of different varieties, and it can be tempting to think that any available D-ring is as good as the next for fall-arrest tie-off. Unfortunately, this is not the case, and using the wrong D-ring can have life-threatening consequences in the event of a fall.

Getting to know the various D-rings on your harness can help you avoid putting yourself and others in danger when working at heights.

Dorsal D-Ring

D-rings get their name because they are shaped like a capital “D.” The dorsal D-ring — the attachment point on the back of the harness — is the main connection point for fall protection and fall arrest lanyards. Its position high on the back ensures that, in the event of a fall, the worker is oriented in an upright position and the force of arresting the fall is safely distributed evenly throughout the body. Once a fall is arrested, the dorsal D-ring allows the suspended worker to remain upright with their weight centered while awaiting rescue.

When a worker wears the harness, the dorsal D-ring should sit between the shoulder blades in the center of the back. An improperly fitting harness can present a serious hazard because the position of the dorsal D-ring when the harness is in use is key to its effectiveness. If it’s too high, it could strike the back of the worker’s head during a fall; if it sits too low, a fallen worker can end up suspended face-down rather than falling in an upright position, increasing the risk of suspension trauma and secondary injury.

Always ensure your harness fits properly, with the dorsal D-ring falling in the center of your back between your shoulder blades and the harness fitting snugly enough to allow you to put your fingers — but not a fist — between your body and the straps.

Side D-Rings

Many harnesses have D-rings on the sides, located at the hips. Side D-rings are mainly used for work positioning. Work positioning systems allow a worker to be held in suspension, enabling them to work with both hands free. This has common applications in tower work and rebar construction, for example. Positioning devices such as a belly chain or a rebar chain assembly can connect to the harness’s side D-rings for hands-free work positioning.

Note that these positioning systems do not replace the need for fall protection, which should be attached from a suitable anchor point to the harness’s dorsal D-ring at the same time.

Side D-rings are not suitable for fall-arrest attachments; attaching a fall arrest system to a side D-ring is extremely dangerous. With a fall protection system attached to a side D-ring, in the event of a fall, the worker won’t descend in an upright position, and the force of the sudden stop when the fall arrest system engages would not be distributed evenly throughout the body, likely causing serious injury.

Side D-rings are, however, ideal options for attaching tool lanyards. Elastic tool lanyards, sometimes called tool tethers or bungees, prevent dropped tools from falling onto workers below. Simply attach one end of a tool lanyard to the tool and the other onto a side D-ring on your harness. This configuration keeps the tool tethered to your harness in case you lose your grip on it, while keeping the length of the lanyard conveniently off to the side when you’re working with the tool.

Sternal D-Ring

The sternal D-ring, located in the center of the chest, is primarily used for fixed-ladder climbing fall protection systems.

Probably the most noticeable D-ring to the harness wearer is the one on the center of the chest. Called the sternal D-ring, this attachment point is primarily used for fixed-ladder climbing fall protection systems. New OSHA regulations that began to phase into effect in November 2018 require a ladder safety or personal fall protection system on all new fixed ladders of 24 feet or taller. Starting in 2020, all new fixed ladders and replacement ladder/ladder sections must have a ladder safety or personal fall protection system and all existing ladders must be equipped with a cage, well, ladder safety system, or personal fall arrest system on fixed ladders that do not have any fall protection, according to OSHA.

Headlining the changes in OSHA’s latest update is a purposeful shift away from ladder cages in favor of ladder safety or personal fall protection systems. These ladder-based fall protection systems typically attach to the sternal D-ring, allowing the workers to comfortably scale the ladder while remaining protected from a fall.

Like the dorsal D-ring, the sternal D-ring should fall squarely in the center of the chest, at the sternum or breastbone. This positioning ensures the harness is able to distribute the worker’s weight evenly and safely in the event of a fall. Wearing an ill-fitting harness that sits too high or too low can lead to secondary injuries if the fall-arrest system is engaged.

Shoulder D-Rings

Many harnesses have shoulder D-rings at the top of the harness. These may be webbed or metal D-rings and can be used as attachment points for confined-space rescue, entry, and retrieval or for work positioning when used as a pair.

The dorsal D-ring is the main connection point for fall protection and fall arrest lanyards.

Because of their location off-center to the worker’s body, shoulder D-rings are not suitable as fall arrest connection points. Furthermore, these D-rings are not rated for fall arrest and are not designed to withstand the tremendous, sudden force at play when a fall arrest system is engaged. Instead, these D-rings are meant to allow workers to descend or ascend a confined space in a steady, controlled motion.

Although each type of D-ring may look superficially alike, their intended uses should not be confused. Most importantly, it is critical not to rely on the wrong D-rings as attachment points for your fall protection system. As a rule of thumb, fall protection attachment points should be high up in the center of your body. Always check with the manufacturer of your fall protection equipment for their recommendations if you’re unsure which D-rings can be used as fall protection attachment points.

About the author: David Ivey oversees the product development of fall protection and safety equipment at Malta Dynamics. He also sits on the ANSI Z359 board and participates in many subcommittee meetings for safety products. For more information or with questions about how to properly use your safety harness D-rings, contact divey@maltadynamics.com.

Updating Your Employee Manual for 2021

Most everyone can agree that 2020 has been challenging. However, the year has also been an opportunity, a time for roofing contractors and other businesses to take a step back, study what works and what does not, and implement necessary revisions to standard operating procedures.

As you get ready for the new year, take a moment to evaluate your company. See what has changed and consider what new demands you expect for 2021. Then update your employee handbook to reflect those changes.

I-9 Requirements

Your human resources office is likely well-versed in having workers complete I-9 forms when they onboard. During the COVID-19 pandemic, the U.S. Immigration and Customs Enforcement (ICE) and the Department of Homeland Security (DHS) relaxed the I-9 requirements for remote workers, but that flexibility expired on December 31. Also, as President-elect Biden takes office, immigration regulations may change. Ensure your employee handbook adequately explains the current requirements, and be ready to make changes throughout 2021 as needed. Additionally, as states continue to pass new laws regarding e-verification of employees, make sure that your employee handbook is properly updated to address any e-verify changes that affect your company.

Minimum Wage and Overtime

In November, Florida voted to raise the state minimum wage to $15 per hour, to incrementally take effect by 2026. Seven other states had already agreed to the increase, and with the new administration, increased minimum wage rates may become a national trend. Take a look at your hourly employees and determine if you need to start raising their pay to meet your state’s standards. Also, be sure that your handbook clearly explains rules around working overtime and receiving overtime pay.

Discrimination and Harassment Prevention

In recent years, courts and lawmakers have issued rulings and legislation to prohibit discrimination and harassment in the workplace. For instance, in 2020, the United States Supreme Court ruled that federal law prohibiting discrimination on the basis of an employee or job applicant’s sex also extended to sexual orientation and gender identification, so that it is illegal for covered employers to discriminate on the basis of an employee or job applicant’s sexual orientation or gender identity. It is important to update your manual to reflect those directives and to ensure your human resources and management team understand the newly-clarified scope of federal anti-discrimination laws.

Safety Guidance

Over the last several months, everyone has become accustomed to wearing masks, social distancing, and regular handwashing. The promise of a COVID-19 vaccine looms. However, it may be several months before the vaccine is available to the entire population, and then it will still be sometime before the country sees the collective effects of the vaccine. Everyone may be growing tired of the pandemic precautions, but it is important to keep the necessary safety guidelines in place and clearly explain them in the employee manual. Further, as COVID-19 safety guidance continues to evolve on a weekly basis, it is important to remain vigilant and up-to-date on the evolving safety standards.

Drug Use and Testing

In the recent election, many states voted on laws related to personal drug use. In Arizona, Montana, New Jersey, and South Dakota, voters cast their ballots to decriminalize recreational marijuana, making it legal in 15 states. Oregon made it legal to possess small amounts of cocaine, heroin, and methamphetamines (but selling the drugs is still illegal) and also voted to create a program for distributors of psilocybin, the active ingredient in psychedelic mushrooms. Washington, D.C., also decriminalized psilocybin. Meanwhile, Mississippi and South Dakota voted to legalize medical marijuana, joining 33 other states that had already done so.

Review the laws in your region and make sure your handbook explains (or related drug policy adequately addresses) the possession and use of controlled substances in light of these changing laws. Bear in mind that while you cannot dictate what employees do on their own time, you are generally still able to implement certain drug-free policies as it relates to your workplace. If drug testing is among your company’s policies, review your policies to ensure they comply with your state laws regarding medical marijuana use and other controlled substances.

Employee Training

In addition to updating your manual, consider updating your employee training. As the new year approaches, everyone could likely benefit from a refresher on discrimination and harassment prevention, safety, and compliance.

Also, your company may want to offer additional training for managers so they can identify signs of impairment. If workers have any drugs in their system, they can be a danger to themselves, their coworkers, and/or your customers and the community, and this is especially true in the roofing and construction environment. Any lack of focus can result in accidents, injuries, and lost time, which puts your people and your projects in jeopardy.

As you prepare for 2021, do not shy away from challenging issues. Instead, determine how they will affect your company and create the proper policies. It is up to you to set expectations for your workers and keep communications current and accurate.

About the author: Benjamin Briggs is a Partner at Cotney Construction Law who practices Labor & Employment Law. Cotney Construction Law is an advocate for the roofing industry and serves as General Counsel for NRCA and several other roofing associations. For more information, visit www.cotneycl.com.

Authors’ note: The information contained in this article is for general educational information only. This information does not constitute legal advice, is not intended to constitute legal advice, nor should it be relied upon as legal advice for your specific factual pattern or situation.

Roofing Alliance Funds Mississippi State Virtual Reality Safety Research

The Roofing Alliance, the foundation of the National Roofing Contractors Association (NRCA) celebrating its 25th year, is funding a research program through Mississippi State University (MSU) for virtual reality and safety research. A team from MSU is working with a Roofing Alliance task force to develop a virtual reality training module that will help the roofing industry focus on ladder safety and overall assessment of rooftop safety.

Roofing Alliance task force members have been holding virtual meetings with the Mississippi State University team as the project progresses. The first steps were to identify topics for the virtual reality module(s) being developed. Two main areas were selected: ladder safety and an overall assessment of rooftop safety. The programs are aimed at new hires and entry-level workers with no prior experience. Participants using VR will experience what it feels like to climb a relatively tall ladder and understand some of the key concepts of ladder safety. The task team has also worked with MSU to develop a BIM model strategy for the research and deliverables.

“It’s intended to be part of a new hire’s onboard training before they actually go up on the roof,” stated Josh Kelly, task force chair. “We provided faculty with some elements that are to be included such as assessing the jobsite for best ladder location, selecting which ladder to use based on building height and weight rating, inspecting the ladder, setting it up and securing it.”

The funding request was submitted by Dr. Saeed Rokooei, an assistant professor at Mississippi State University. The proposal named “Evaluating the Efficacy of Virtual Reality Technology for Improving the Roofing Construction Workers’ Safety” was approved for funding in April of 2020.

For more information on how to submit funding requests, current funding projects or the Roofing Alliance 25th Anniversary contact Bennett Judson, the Roofing Alliance’s executive director, at bjudson@roofingalliance.net or visit www.roofingalliance.net.

New Safety Helmets Designed for Comfort and Protection

Malta Dynamics announces the release of its new safety helmets, which feature an innovative design that aims to maximize both safety and comfort on the jobsite. The new Malta Dynamics Safety Helmets meet ANSI Z89.1-2014 Type 1 Class C standards and can optionally come equipped with an attached clear or tinted visor.

The Malta Dynamics Safety Helmet features sliding adjustable vents to help with air circulation. The helmet’s six-point suspension system and adjustable chin strap improve comfort and provide greater protection in the event of an impact or fall. The low-profile design allows a more secure fit that sits lower on the crown of your head, which provides better coverage and makes wearing the helmet more comfortable than a higher-profile sitting hard hat.

“We’re excited to introduce our new safety helmet that offers a fantastic mix of protection and comfort,” says Damian Lang, owner and CEO of Malta Dynamics. “Because we use these products ourselves, we know how important it is for PPE to fit comfortably when you wear it around a jobsite all day. Workers have to be comfortable wearing it so that they keep it on at all times and are protected when they need it.”

For more information, visit maltadynamics.com.

Reusable Parapet Anchors

Malta Dynamics introduces its reusable parapet anchor, designed specifically for flat roofs surrounded by parapet walls. These parapet anchors are fully adjustable and can be installed on wall thicknesses from 2.36 inches all the way up to 14.1 inches. Parapet walls must be at least 9 inches high to install this anchor, which supports workers up to 310 pounds.

This anchorage device is non-penetrating and requires no tools to install. The dual tightening handles allow for even force distribution, and rubber protective pads eliminate damage to the parapet wall.

“Our parapet anchors are so easy to install, you can be up and running in just a few minutes,” said Damian Lang, owner and CEO of Malta Dynamics. “They provide a great cost savings because these reusable anchor points can be transferred from one jobsite to another.”

For more information, visit www.maltadynamics.com

Swivel Metal Roof Anchor

Dynamic Fastener offers a swivel metal roof anchor for use with lifelines, rope/cable grabs or retractors. It offers continuous protection and freedom of movement with the 360 degree swivel and 180-plus degree flip movement of the D-ring, keeping the connection point in line with your work. According to the company, the unique design keeps the anchor point above the high point of the panels. The swivel metal roof anchor is designed for temporary or permanent application. It is designed to fit in the valleys of lighter R panels and capture the purlin below. The product is supplied with 14-14 x 11/2 inch T4 fasteners.

For more information, visit www.dynamicfastener.com.

National Safety Stand-Down to Prevent Falls Rescheduled for September 14-18

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced that the 7th annual National Stand-Down to Prevent Falls in Construction has been rescheduled for September 14-18, 2020. While OSHA postponed the event earlier this year due to the coronavirus pandemic, the agency continues to encourage employers to promote fall safety virtually or while employing social distancing practices among small groups.

OSHA is partnering with other safety organizations in 2020 to encourage employers to provide safety demonstrations on fall protection equipment, conduct talks regarding fall-related hazards, safety policies, goals and expectations, and promote the event by using the #StandDown4Safety on social media.

“This national initiative brings much needed attention to falls, which continue to be the leading cause of fatalities in construction,” said Principal Deputy Assistant Secretary of Labor for Occupational Safety and Health Loren Sweatt. “Since OSHA began doing fall prevention stand-down events six years ago, nearly 10 million workers have been reached by our message that falls are preventable. These efforts have been successful in raising awareness of the recognition, evaluation, and control of fall hazards.”

Extensive resources are available on OSHA’s Fall Prevention Stand-Down webpage at http://www.osha.gov/StopFallsStandDown and are presented in various languages, including English, Spanish, Russian, and Portuguese. Resources include a brief video entitled “5 Ways to Prevent Workplace Falls,” which encourages employers to educate and train workers on fall protection equipment; a series of fall prevention publications, with an emphasis on construction, and fall prevention videos; OSHA’s Fall Prevention Training Guide, which provides a lesson plan for employers, including several Toolbox Talks; and guidance on ladder and scaffolding safety.

Employers are also encouraged to provide feedback after their events, and obtain a personalized certificate of participation.

The national safety stand-down is part of OSHA’s fall prevention campaign, and was developed in partnership with the National Institute for Occupational Safety and Health, National Occupational Research Agenda, and The Center for Construction Research and Training.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance.

For more information, visit www.osha.gov.

Safety Obligations Under the OSH Act Can Extend to Non-Employees and Other Trades

The nature of roofing (particularly re-roofing) frequently involves the presence of non-employees on or around active construction sites. This is true in both the residential and commercial contexts. However, the risk increases significantly on commercial projects, such as retail and mixed-use projects, where many parties can be present, including the property owners’ customers and employees, as well as other trades working at the project simultaneously.

As such, it is essential that roofing contractors understand the scope of their obligations to non-employees under the Occupational Safety and Health Act of 1970 (OSH Act). While accidents and injuries can certainly trigger an investigation by OSHA, employers are frequently charged with violations of the OSH Act for merely failing to implement appropriate procedures. Not to be taken lightly, OSHA citations carry significant consequences, including penalties of up to $134,937 per violation, as well as creating a stigma against the company and loss of future opportunities. Moreover, company owners may not always be free to “walk away” from these consequences by closing the business (a common misbelief in the industry).

In the OSH Act, Congress authorized the Secretary of Labor to develop safety and health standards (OSHA regulations). One of the most important of these standards to contractors, arguably, is 29 CFR 1910.12, which provides: “Each employer shall protect the employment and places of employment of each of his employees engaged in construction work.” [Emphasis added.] This provision, like OSHA’s general duty clause, seems to imply that OSHA-imposed obligations extend only to an employer’s own employees. However, this is frequently not the case.

For many decades, the phrase “his employees” has been a major point of contention because OSHA has frequently penalized employers for hazards which did not affect the employers’ own employees. While early court decisions initially rejected OSHA’s imposition of liability in these circumstances, the tide eventually shifted, and now the opposite is true. Today, most courts will impose liability under OSHA’s “Multi-Employer Citation Policy” where the contractor “could reasonably be expected to prevent or detect and abate the violations due to its supervisory authority and control over the worksite.” This is true even where the contractor’s own employees were completely unaffected, or even absent when the hazard occurred.

While the borders of OSHA’s policy are unclear and still developing, contractors should at least suspect they may be held responsible for the safety violations at a jobsite if they either: (1) created the hazard; or (2) exercised some degree of control over the subject worksite. With that in mind, roofing contractors can address this risk preemptively by starting with a plan to mitigate hazards and potential liability on their jobsites.

Identifying Risk

One method of doing so is by creating a Jobsite Hazard Analysis (JHA). According to OSHA, a JHA “is a technique that focuses on job tasks as a way to identify hazards before they occur.” By identifying risks, such as exposure of the public and other trades to an active construction site, roofing contractors can implement effective measures to mitigate known hazards.

While planning requirements will vary by jobsite, most roofing contractors’ JHA should address the following questions on this topic:

  • Will non-employees be present at the worksite during active construction? Could they gain access without the company’s knowledge or consent?
  • Can measures be taken to reduce or eliminate access to the worksite by non-employees?
  • What types of hazards could non-employees be exposed to? (e.g.,falling debris)
  • What steps will the company take to reduce or eliminate risks to non-employees?

In addition to addressing these risks in company policies, such as JHAs and a safety manual, it is also prudent to include provisions in the company’s contract which seek to limit exposure of non-employees to hazards. For example, the roofing contractor could include a provision in the contract which forbids the property owner’s employees from using certain entrances to the building during specific phases of construction. Roofing contractors may also seek indemnification from owners for claims of third parties based upon third parties’ failure to comply with contractual requirements. 

Under any circumstances, roofing contractors should take a preemptive approach to hazards, understanding the adage, “an ounce of prevention is worth a pound of cure,” is especially true in their industry. The first step in this process is assessing and appreciating the risks that safety hazards present. The second is implementing proactive safety policies which seek to eliminate or reduce those risks.

About the author: Travis S. McConnell is a construction law attorney with Cotney Construction Law, LLP. McConnell’s legal practice focuses on all aspects of construction law. He works extensively on matters relating to OSHA defense, which includes the management and development of safety and health strategies for construction contractors across the United States. McConnell’s OSHA practice concentrates on litigation and the appeals of citations involving catastrophic construction related accidents. He can be contacted by email at tmcconnell@CotneyCL.com.

New Line of ANSI-Rated Safety Helmets

Protecting workers on the job from potential head injuries is vital to most workforce safety plans. Whether you’re restoring power at great heights or working daily on the construction site, you rely on your safety helmet to keep you safe while on the job. The new line of Ridgeline XR7 Safety Helmets from Pyramex Safety is the company’s latest addition to its trusted Ridgeline series, incorporating expertly designed features like a comfortable breakaway chin strap which secures the hat and offers protection from strangulation should a major fall occur, as well as the ability to attach earmuff and face shield accessories to adapt to the needs of any work environment.

The new Ridgeline XR7 Safety Helmet is constructed of ABS/PC material that’s not only ultra-lightweight, it offers superior strength and increased heat resistance. It’s easy to adjust with a 6-point ratchet suspension system ensuring a personalized fit. A soft four-point PU breakaway chin strap ensures all-day wearing comfort while keeping the helmet securely fastened. Removal is simple with a quick release of the breakaway clip. Easily adjust height and angle options for the suspension, as well as adjust it from 6-1/2 to 8 head size via an easy to grasp knob to help you find the most comfortable position on your head.

The Ridgeline XR7 meets ANSI Z89.1-2014 Type I, Class E and CE EN 397:2012 +A1:2012 safety standards, so wearers can be confident they are well protected while on the job. Safety helmet adapter, earmuff and face shield accessories are also available (sold separately) to customize the Ridgeline XR7 and adapt to individual working conditions. The Ridgeline XR7 is available in a wide variety of colors including: White, Slate Gray, Black Graphite, Yellow, Hi-vis Lime and Blue. Custom imprinting is also available.

For more information, visit www.pyramexsafety.com.

Skylight Fall Protection System

Dynamic Fastener offers fall protection systems for flat and domed skylights. Ideal for R-panel, standing seam, or curb mount skylights, the system utilizes an OSHA-compliant galvanized steel safety screen with a maximum 4-inch-by-4-inch opening. The screen is secured with zinc-coated carbon steel clips and long-life, self-drilling fasteners. All of the required mounting hardware and supports are included in the kit for a complete installation. 

According to the manufacturer, all systems are factory-sized to install quickly. Roof-mounted models maintain a low profile to create a clean and finished look. Curb-mount applications are hidden beneath the domed skylight. The system can be custom painted to match the building’s exterior.

 For more information, visit www.dynamicfastener.com.