OSHA, ANSI, and Work at Height

Founded in 1918, the American National Standards Institute is a not-for-profit organization dedicated to promoting “voluntary consensus standards.”  Those three words, “voluntary”, “consensus” and “standards” succinctly describe the documents that ANSI produces.  ANSI’s primary mission is to facilitate standards that, when adhered to, set a level of quality and safety across an entire industry.  These standards address everything from mold remediation, to transportation of nuclear materials, to bakery equipment and digital encryption.   The standards are consensus based because they are written and agreed upon by many members across the entire applicable industry: manufacturers, end users, testing laboratories, etc.  Lastly, the standards are voluntary in that ANSI has no enforcement power.

Technically speaking, ANSI itself does not develop standards.  Instead, ANSI develops and administers the procedures by which other organizations can create the actual standards.  ANSI will then accredit committees formed by other organizations and ultimately approve their documents as American National Standards.  These independent organizations are referred to as the secretariats to the ANSI accredited committees.  For example, the American Society of Safety Engineers (ASSE) acts as the secretariat to the ANSI Z359 Committee, the committee that Vertical Access serves on to create fall protection standards.

The Occupational Safety and Health Administration  (OSHA) is a governmental agency that was created by Congress in 1971 as a subset of the Department of Labor.  Contrary to ANSI, OSHA’s mission is to assure safe working conditions for employees by “setting and enforcing standards”.  This enforcement aspect of OSHA is its primary distinction from ANSI.  Many OSHA regulations address similar topics as ANSI standards (e.g. fall protection), but where ANSI standards are voluntary, OSHA regulations are law.

ANSI standards, however, can be adopted by OSHA and become law in two primary ways.  Explicitly, OSHA can reference specific ANSI (or any other organization’s) standards in OSHA regulations*.  This is referred to as “incorporation by reference”.  Implicitly, OSHA can require adherence to ANSI standards through the General Duty Clause, which states, “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards…”  This clause allows OSHA to cite employers for hazardous conditions that are not directly addressed by OSHA, but are addressed by other industry standards.

To recap, ANSI is a private organization that creates voluntary standards, while OSHA is a regulatory government body that has the power to write ANSI standards into occupational law. (content source: CMC Pro)

 

Although OSHA fall protection standards are mandatory and carry the weight of law, they are often misunderstood or ignored (willingly or unknowingly) by challenge course and zipline professionals. In 2016, OSHA (Occupational Safety and Health Administration) came out with a bulletin to address and clarify what is required by law to protect the safety of workers in the zipline industry. It is attached below.

 

*Note that in this bulletin, OSHA references the “ANSI/ACCT 03-2016 Challenge Course/Zip Line Tours Standards”

OSHA Bulletin p1 OSHA Bulletin p2 OSHA Bulletin p3 OSHA Bulletin p4 OSHA Bulletin p5 OSHA Bulletin p6


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