How to Verify Fall Protection Products are Truly ANSI Compliant

Today, hundreds of fall protection products on the market claim to be compliant with safety standards when they haven’t been adequately tested. Your fall protection equipment might be labeled ANSI-compliant, but that doesn’t mean it meets any or all of the standard’s safety requirements. Even if you have a Declaration of Conformity (DOC), which is supposed to guarantee compliance, the document may be missing information required in the DOC, which voids the document, and therefore, strips away the product’s ANSI compliance. Even worse, there aren’t any laws against mislabeling products or creating an unreliable DOC.

Verifying ANSI Compliance

You can verify ANSI compliance through a document called the Declaration of Conformity (DOC). As of 2019, every manufacturer has to provide a readily-available DOC for each piece of equipment. This document confirms that the product has passed all applicable tests, meets every requirement, and has been tested by an accredited lab. Without this document, manufacturers can’t prove their products meet the required ANSI standards, which include requirements for the DOCs themselves. If the document doesn’t meet these requirements, the DOC is void and the product is not ANSI compliant.

Here’s what ANSI says about DOC compliance:

“The manufacturer shall prepare and make available a Declaration of Conformity for each model of product for which a claim of conformity is made, or use a third-party certification organization to prepare and make available a Certificate of Compliance for each model of product. The manufacturer or certification organization shall not claim compliance to portions of a standard, exclude tests or sections of a standard, or provide exceptions. The Declaration of Conformity or Certificate of Compliance shall only be provided when a product passes all applicable tests and includes all markings, labels and instructions required by the product standard.”

If the manufacturer doesn’t have this document or won’t provide it, the equipment is not ANSI-compliant. Any manufacturer whose products actually meet ANSI requirements will be happy to make the DOC available for you.

Once you have the DOC, your work isn’t done. You must carefully vet the document to make sure it includes all of the information ANSI requires. Some companies use incomplete DOCs to misdirect customers who might think any document titled “Declaration of Conformity” means the product meets compliance standards. They may also create the documents without making sure their products meet all of the standard’s requirements, claiming compliance without fully testing or verifying the equipment.

Use the guidelines in the next section to inspect the Declarations of Conformity for your equipment.

How to use a Declaration of Conformity

ANSI requires DOCs to provide specific pieces of information. Though this might be the simplest part of the process, it’s an important indicator of a manufacturer’s reliability and commitment to standards. After all, if they can’t create a simple document correctly, can you trust that they’ve done everything else right? Whether you’re looking to buy new equipment or want to vet your current gear, this document is the best place to start.

1. Unique document number. Each DOC should have its own document number. Review a few of the manufacturer’s DOCs to make sure they’re not reusing the same number.

2. Date of the report. By ANSI standards, manufacturers must test and requalify each product every two to five years. If the date on the DOC is more than five years old, it isn’t compliant. That said, reach out to the manufacturer if you see this issue. New standards are continually released and testing takes time, so they may be in the process of requalifying the equipment to the latest standard.

3. Manufacturer’s name, address, and contact information. Make sure this information is included and that it matches the company you’re buying the product from.

4. Product models listed for the item you’re reviewing. Multiple models of a product can use the same DOC, as long as they’re all included in the document. For example, you may have a full body harness that comes in multiple sizes. Since it’s the same product model, every size will generally be qualified under the same DOC, even though they’re sold as separate products. Make sure the product/model number is listed and that it matches the manufacturer’s product number.

Some companies resell products that were manufactured and tested overseas. Though they use their own product numbers to sell the equipment, the testing information may use the original manufacturer’s product number. If the product number doesn’t match what you see on the DOC, this might be why. Reach out to the manufacturer to ask about the discrepancy.

5. Applicable ANSI Z359 product standard number and date. The DOC should reference the Z359 standard that applies to that type of product. Make sure the full standard code is listed. It should also reflect the most recent version of the standard available at the time of the declaration date.

6. Statement attesting to the product’s compliance. Additionally, there should be a statement from the manufacturer that the product(s) listed conforms with the standard’s requirements.

7. Name/identification of the accredited test lab and accrediting agency. This is the single piece of information that you can use to confirm ANSI compliance. Without this element, the DOC is worthless. Every piece of ANSI-certified fall protection gear must be tested by a laboratory accredited to the ISO/IEC Standard 17025. The DOC should include the name of the lab, as well as an accreditation mark from the organization that accredited the lab. This mark is the best way to confidently verify that the product has been properly tested. Unlike ANSI, these ISO accreditation companies will legally pursue manufacturers that forge their certification mark or improperly execute testing to the requirements of a standard. If a manufacturer doesn’t provide proper DOC documentation, the accrediting organization may also stop certifying the lab and therefore invaliding all affected test reports until they are in compliance.

For full confidence, or if a DOC lists an accredited laboratory without including an accreditation mark, search for the lab in the accreditation agency’s directory. Here, you can verify the accreditation certificate, as well as the type of testing the laboratory is approved for. 8. References to applicable test reports. This section should include the document numbers for the product’s test reports. You should be able to request this information from the manufacturer to review the results yourself.

Unfortunately, some companies may not offer this information. They may claim that testing information is “proprietary.” FallTech thinks differently. We believe customers deserve transparency. There’s no good reason to hide information about the products you’re trusting your life to. We include these reports with our DOCs so you can easily see how the product performed and have full confidence in the equipment you use.

9. Authorized signature with printed name and title. After checking the DOC to make sure the product is compliant, an authorized person within the company will sign the document. This person’s name and title, as well as the date of signing, should also be included.

Finally, it is important to understand the difference between a Declaration of Conformity versus a Certificate of Compliance. If the manufacturer tests and certifies the product itself in its own lab or a third-party lab, it will produce a Declaration of Conformity for the equipment. ANSI also allows companies to hire third-party accredited labs to certify products rather than doing it themselves. In this case, the third-party organization will issue a Certificate of Compliance (COC). Though the documents are different, they both certify ANSI compliance. COCs are not common in the market today but can be verified using the same steps above.

Is “ANSI-compliant” the same as Meeting all Safety Requirements?

No. And here’s why. The Occupational Safety and Health Administration (OSHA) regulates and monitors safety on behalf of the federal government. Businesses that fail to comply with its standards, or say that they do when they don’t, can face maximum fines ranging between $14,502 to $145,027, depending on the violation. OSHA actively enforces its regulations, encouraging businesses to maintain safe workplaces to avoid these fines.

The American National Standards Institute (ANSI), however, isn’t part of the federal government and doesn’t enforce its guidelines. Instead, it offers voluntary consensus standards. Manufacturers can choose to follow these standards, but they don’t have to. There aren’t any fines or penalties for non-compliance or for falsely labeling products as compliant.

Unfortunately, most buyers don’t realize that ANSI works on the honor system. They think that if ANSI has certified the product as compliant, as the label says, it must perform as predicted. For too many fall protection products, however, that’s simply not true.

For example, think about the seatbelts and airbags in a car. You wouldn’t even think to question what the manufacturer says about their performance. They’re offered as a certified safety feature, so you assume they’ll protect you in an accident. But what if they don’t? What if the seat belt isn’t made with the right webbing material or the airbag fails to meet minimum deployment thresholds? What if the National Highway Traffic Safety Administration (NHTSA), which sets these safety standards, didn’t enforce its regulations? You would only find out after the safety device fails, when it’s too late for the person relying on the equipment.

Misleading compliance claims in fall protection are more common than you would think. You can find products that may have failed ANSI-required testing, been improperly tested, been certified without meeting all the requirements in the standard, have only been tested for some of the requirements in the standard, or been tested by overseas manufacturers but not to U.S. safety standards.

The most common, and most dangerous, problem you’ll see is mislabeled products. Fall protection SRLs are the most expensive to test. To avoid the cost, some companies will use insufficient testing or manipulate testing results.

For example, you can buy leading edge lifelines that will immediately fail during a fall because the material can’t withstand contact with the edge. There may be products available that have never been tested against fall arrest forces and may subject your workers to unsafe forces during a fall.

Given the depth of this issue on the market, you should never buy an ANSI-compliant fall protection product without first verifying the information given in its DOC.

Why ANSI Z359 Compliance Matters

The ANSI Z359 standard, which covers fall protection equipment, is comprehensive and detailed. Compliance with this standard is the only way to know that a lifeline with a leading-edge rating can withstand contact with a sharp edge or that a horizontal lifeline will safely arrest a fall. Additionally, it isn’t just compliance that matters, but the standard itself.

In the U.S., OSHA and ANSI are the only two organizations that offer guidelines for fall protection workplace safety. Though both organizations promote safety, OSHA’s requirements set the regulatory minimums. ANSI’s standards are far more comprehensive, stricter, and thus, safer.

For example, consider the difference in the standards for self-retracting lifelines (SRLs). OSHA offers a single-sentence standard, written in 1998, that requires SRLs to limit free fall distance to two feet and sustain a minimum tensile load of 3,000 pounds. As long as a manufacturer meets these requirements, OSHA considers the product safe and won’t cite the company for violations.

An ANSI-compliant SRL, on the other hand, has to meet a full 60-page standard that covers design, testing, product labeling, and user instruction requirements. It also has to be requalified every five years, or when the standards are updated, to remain compliant.

The ANSI-compliant label should mean that a product has been tested properly and performs as predicted. Unfortunately, many of the products that boast ANSI compliance don’t actually meet the organization’s high standards. If you don’t verify these claims for yourself, you may be risking your workers’ safety every time they use that product.

Vetting fall protection products and manufacturers can be confusing. It also requires a lot of work. With your insurance, EMR rating, and more depending on your gear’s ANSI compliance, FallTech offers DOCs and testing reports for all of our ANSI-compliant products on our website. With a single click, you can see that the equipment performs as it's supposed to during a fall. In addition to the Class 1 and Class 2 standard labels, all Class 2 SRLs must include a full fall clearance table or diagram as part of the physical product and the user instruction manual. This provides critical clearance information directly on the product, where it is most easily accessible by the end-user or Competent Person at the place and time of use. •

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