This resource does not replace the Occupational Health and Safety Act (OHSA) and its regulations and should not be used as or considered legal advice. Health and safety inspectors apply the law based on the facts they find in the workplace.

Hazard summary

A recent incident occurred when the locking mechanism on a self-retracting lifeline — leading edge (SRL-LE) seized and did not deploy because the wire cable was exposed to moisture and low temperature conditions. This resulted in ice forming on the locking mechanism thereby preventing the SRL-LE from performing as designed.

When used and maintained correctly, SRL equipment offers dependable fall protection and is specifically designed to extend and retract automatically which keeps the lifeline in consistent tension while allowing the wearer to move around within a work area.

A self-retracting lifeline (SRL) consists of a lifeline constructed from webbing or wire cable. The lifeline is wound around a drum in a housing. One end of the SRL connects to the anchor point. The other end of the SRL connects to the dorsal D-ring of the harness system. The lifeline rolls out and automatically retracts into the housing, based on the user’s movement. This retracting function ensures that the lifeline is always kept taut. If functioning properly, when the SRL detects a sudden increase in speed (such as a fall), a locking mechanism in the housing immediately activates and stops the fall. This function is like the sudden tug on a car’s seatbelt.

Under some circumstances, there may be environmental conditions that can cause the locking mechanism to seize resulting in the cable continuing to spool out. If this happens, the worker’s fall will not be arrested.

This situation may occur if:

  • moisture accumulates on the cable and the locking mechanism (this can happen throughout the day if the cable comes into repeated contact with a wet surface and retracts, causing the spool and locking mechanism to become damp or wet)
  • the SRL-LE is exposed to cold temperatures causing the spool and locking mechanism to develop ice (this could happen if the SRL-LE is left or stored in a cold area overnight or if the temperature drops below freezing while it is being used)

Recommended precautions

The hazard exists when the weather changes to freezing, meaning the temperature goes from above zero degrees Celsius to below zero degrees Celsius. During weather extremes (such as, cold and wet conditions), and especially if the cable gets wet, it is important to verify the locking mechanism is working properly.

Take the following action to avoid this situation from happening:

  • During cold and wet conditions ensure the locking mechanism has not seized by rapidly pulling the cable to verify the components of the locking mechanism are functioning properly. This should be done both before the SRL-LE is used for the first time each day and then frequently throughout the day especially during cold and wet conditions.
  • Briskly pull the cable out making sure the locking mechanism inside the housing responds to a sudden jerk on the cable The SRL-LE should lock up like a seat belt does when a car comes to a sudden halt. Do this action three or more times with the cable at different lengths.
  • If the SRL-LE was subject to wet conditions during the shift, store the equipment vertically and avoid having the unit exposed to freezing conditions during storage.
  • Only use the SRL-LE unit if it is fully functional. If the unit fails the locking mechanism testing described above, it has malfunctioned. The malfunctioning SRL-LE unit must be taken out of service until the locking mechanism is no longer frozen and responds properly (like a seat belt).
  • In addition, an SRL-LE unit must be used in accordance with the manufacturer’s operating manual.
  • Construction workers must use adequate fall protection when conducting leading edge work.

Take the following action if the situation does occur:

  • Do not use the SRL-LE if the locking mechanism is not working. If it does not work, equivalent fall protection equipment must be used when working at the leading edge.
  • If you are a worker, notify your supervisor/employer if you encounter situations when the locking mechanism seizes or malfunctions and ensure you have appropriate fall protection in case the SRL-LE unit is taken out-of-service.
  • If you are the supervisor/employer, notify the supplier/manufacturer if you encounter situations when the locking mechanism seizes due to environmental conditions.
  • All components of a fall protection system, including the harness and the SRL-LE, lanyard, or other connecting device, must be immediately removed from service after it has been involved in a fall, regardless of whether any damage is apparent.

What you’re required to do by law

Employers and supervisors have a duty to ensure that workers are aware of workplace hazards. They must, therefore, ensure that workers using an SRL-LE are aware of the hazard described in this Alert and of the preventative actions outlined above.

Under section 25 of the Occupational Health and Safety Act (Act) employers must, among other duties, make sure that:

  • all the equipment, materials and protective devices provided by the employer are maintained in good condition
  • measures and procedures set out in the regulations are followed in the workplace
  • workers are provided with information, instruction, and supervision to protect their health and safety (for example, they are trained to work safely)
  • every precaution reasonable in the circumstances is taken for the protection of a worker

Under section 27 of the Act supervisors must, among other duties, make sure that:

  • measures and procedures set out in the regulations are followed
  • protective devices required by the Act, the regulations and the employer are used or worn
  • workers are advised of the existence of any potential or actual danger of which the supervisor is aware, such as this hazard alert
  • every precaution reasonable in the circumstances is taken for the protection of a worker

Under section 28  of the Act workers must, among other duties, ensure that:

  • equipment is used in a manner that won’t endanger himself, herself, or any other worker

Equipment — general

Under section 93 of Regulation 213/91 — Construction Projects, all tools and equipment must, among other things, be:

  • maintained in a condition that does not endanger a worker
  • used in accordance with any operating manuals issued by the manufacturers

No tools or equipment shall be used:

  • while it is defective or hazardous
  • when the weather or other conditions are such that its use is likely to endanger a worker

Equipment — fall protection

Under section 26.1 of Ontario Regulation 213/91 — Construction Projects a worker must be protected by the highest ranked method of fall protection that is practical when exposed to a hazard described in s. 26, including a fall of more than 3 metres. This also applies when a piece of equipment is not functioning or is taken out of service. If a guardrail cannot be installed, then the ranking of fall protection methods, from highest to lowest, is:

  • a travel restraint system that meets the requirements of section 26.4
  • a fall restricting system that meets the requirements of section 26.5
  • a fall arrest system, other than a fall restricting system designed for use in wood pole climbing, that meets the requirements of section 26.6
  • a safety net that meets the requirements of section 26.8

Working at heights training

Under section 26.2 of Ontario Regulation 213/91 — Construction Projects, an employer must make sure that workers who may use a fall protection system receive:

  • working at Heights training by a Chief Prevention Officer (CPO) approved training provider
  • specific training by a competent person about the fall protection system to be used on site and that a signed written training and instruction record is kept for each worker. The site-specific training can include:
    • the right equipment and procedures to be used
    • how to take care of the equipment
    • what to do in an emergency

Contact us

If you need more information about safety requirements, please contact the Ministry of Labour, Immigration, Training and Skills Development, Health & Safety Contact Centre at 1-877-202-0008, Monday to Friday, from 8:30 a.m. to 5 p.m., or webohs@ontario.ca.

Resources

Infrastructure Health and Safety Association (IHSA) resources: