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Query to SSPG: Clarification of additional controls for restrained-fall PFAS
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Query to SSPG: Clarification of additional controls for restrained-fall PFAS
Background
In 2015, the EEA adopted an objective to implement an ‘attachment at all times’ practice for employees working at height, except while climbing a ladder. The practice was to be introduced progressively and become standard electricity industry practice by March 2016. In the distribution sector, this requirement is commonly met by using a fall-arrest harness with two pole straps: one supports the worker at the working position, while the other provides support when the worker changes position.
In 2026, the SSPG introduced SM-EI requirements that, when a pole strap supports a worker’s weight, additional controls must protect the worker if the pole strap fails (see SM-EI rules PH 1.3012, PH 3.2012, PH 3.2021, PH 4.4102, and PH 4.4141). A common distribution-sector response is to use both pole straps at the working position. Some electricity industry companies also require fall-arrest harnesses to have two sets of D-rings.
Comments
The requirements to remain attached at all times and to maintain an additional control against pole-strap failure create a practical conflict when a worker changes position. If a fall-arrest harness has only two pole straps, disconnecting one strap to move removes the additional protection against failure of the remaining strap. SM-EI does not expressly address this situation, which may be an oversight.
Two options could address this issue. First, the SSPG could introduce a specific SM-EI exception to the additional-control requirement while a worker changes position. Alternatively, the SSPG could provide practical guidance on how to maintain an additional control throughout the movement. Whichever approach is adopted, SM-EI should clearly state the requirement that applies when a worker changes position.
Query to SSPG
Please review the background and comments above and clarify how the SM-EI requirements apply when a worker changes position, including which of the options identified, or what alternative approach, the SSPG considers appropriate.
<b style=”font-family: inherit; font-size: inherit;”>Here are the SM-EI Rules for Reference
<b style=”font-family: inherit; font-size: inherit;”>PH 1.3 Provide instruction for Work at height
PH 1.3011 For work on poles and pole structures, procedures shall be developed and implemented that enable workers to be attached at all times.
PH 1.3012 When a work positioning system is intended to support the user’s weight, additional control measures shall also be implemented to provide protection in the event of a system failure.
PH 3.2 Select equipment for Work at height
PH 3.2011 When working at height (excluding when climbing a ladder), workers shall be attached at all times, including when transferring working positions.
PH 3.2012 When a work positioning system is intended to support the user’s weight, additional control measures shall also be implemented to provide protection in the event of a system failure.
PH 3.2021 When preparing for work at height, workers shall select equipment that enables them to:
· be attached at all times (except for when climbing a ladder)
· either prevent a fall occurring or, where this is not possible, eliminate risk of harm from a fall (for example, by using a personal fall-arrest system).
· have additional controls in place when a fall arrest system supports the users weight in the event of a system failure
PH 4.401 When using any fall-arrest harness with a pole strap connected to both side D-rings, no free fall shall be possible. This system may be used where a restrained fall only may occur (e.g. working with the pole strap around a pole where tension exists on the pole strap at all times when in use and would be expected to remain during any fall).
PH 4.4102 When using a pole strap that supports the users weight, additional control measures shall be in place to prevent a fall in the event of a pole strap failure.
PH 4.4141 When setting up a personal fall arrest system (PFAS) harness with integral body belt and before any weight is place on the harness and pole strap:
· both snap hooks of the pole strap shall be engaged in separate D-rings
· the fastenings shall be properly engaged and checked for engagement, with the snap hooks hooked into the D-rings
· the pole trap shall be attached to a secure part of the structure from which it cannot slip.
· have in place additional control measures in place to prevent a fall in the event of a pole strap failure
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2 Replies
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Stephen
Thank you for your query.
Your background summary is correct. The SM-EI and associated guides were updated to align with the requirements of AS/NZS 1891.4:2025 relating to additional controls when a work positioning system is supporting a worker’s weight.
The SSPG considered the issue you have raised during development of these requirements. The intent of the SM-EI is that workers remain attached at all times when working at height, including when transferring or changing position around a pole.
The requirement for additional control measures applies when the work positioning system or pole strap is supporting the worker’s weight. Whether a worker is undertaking work at a fixed position or moving between positions does not in itself determine whether additional controls are required.
The SM-EI does not prescribe a specific method for achieving these outcomes. Organisations should ensure their procedures, equipment selection and work practices enable workers to remain attached at all times and provide appropriate additional protection whenever a work positioning system is supporting the worker’s weight.
Regards
SSPG
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Hi Graeme,
Thank you for the SSPG response.
Supplementary question seeking clarification of SM-EI:
When a worker is transferring or changing position around a pole or pole structure, at the stages when only one pole strap is attached, must that pole strap be under tension to comply with SM-EI?
Regards
Stephen
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