Regular inspection of fall protection PPE: who is authorised to inspect your equipment?

When working at height, PPE is not just an accessory. It’s the difference between getting home safely at the end of the day and not making it home at all. And yet, the issue of inspecting this equipment remains unclear to many, particularly when it comes to who is authorised to inspect a harness, a lanyard or an energy absorber. All the answers to these questions can be found in the EN 365:2004 standard. Here is a summary of everything you need to know.

The European standard EN 365:2004 applies to all Category 3 PPE, i.e. equipment designed to protect against a life-threatening risk, which includes fall arrest equipment. It is unequivocal on one point: every manufacturer must provide, in the language of the country of destination, three separate documents:

•    instructions for use (§ 4.2)

•    maintenance instructions (§ 4.3)

•    instructions for periodic inspections (§ 4.4)

These instructions are not optional. They form the basis for any statutory inspection of fall protection PPE.

Section 4.4 also specifies two key points: the periodic inspection must take place at least once every twelve months, and it may only be carried out by a competent person, in strict accordance with the manufacturer’s operating procedures.

Who is a ‘competent person’?

This is where many companies cut corners, which can prove costly. The EN 365:2004 standard defines a competent person in Section 3.3:

‘A person who is familiar with the applicable requirements concerning periodic inspections and with the manufacturer’s recommendations and instructions applicable to the component, subsystem or system to be inspected. ”

Two elements are inseparable in this definition. Knowledge of the regulations, yes — but also knowledge of the specific instructions provided by the manufacturer of the equipment being inspected. One without the other is not sufficient.

The standard goes further in its notes. It specifies that a competent person must be able to identify and assess faults, and to take the necessary corrective action (Note 1). It also acknowledges that, for complex or innovative equipment, training provided by the manufacturer may prove essential (Note 2). Such training may, moreover, be updated in the event of product developments.

What this means in practice

Clause 4.7 of standard EN 365:2004 places the responsibility on the manufacturer: it is the manufacturer’s responsibility to provide everything necessary to enable a competent person to carry out the inspection, including instructions, checklists or spare parts, if required.

Consequently, the competent person must be someone who has received training, or whose knowledge has been verified by a person holding a personalised training certificate. This certificate must be valid and must specify the scope of product-related competencies covered. It should be noted that without this certificate, the periodic inspection has no regulatory validity.

The three categories recognised by KRATOS SAFETY

On the basis of these regulations, KRATOS SAFETY recognises the following as competent persons for the periodic inspection of its fall protection PPE:

- Any person trained by KRATOS SAFETY. The training, delivered directly by us, guarantees mastery of the operating procedures and inspection criteria specific to each product range.

- Any person trained by an authorised KRATOS SAFETY representative, subject to strict compliance with KRATOS SAFETY’s periodic inspection procedures. The network of authorised representatives is authorised to confer this competence under the same conditions as the manufacturer.

If you find yourself in this situation, you can contact us immediately to request a certificate of equivalence from our team.

Any person trained by another European manufacturer, provided that this training explicitly covers PPE regulations and the applicable European standards, and that the person is able to produce a valid training certificate. In this case, the inspection must be carried out in accordance with KRATOS SAFETY’s operating procedures for equipment in our range, as general knowledge is no substitute for the instructions provided by the manufacturer of the equipment being inspected. Similarly, you may request a certificate of equivalence from our team if this situation applies to you.

In summary

An uninspected or poorly inspected harness is a harness that could cost a worker their life. The EN 365:2004 standard was not drawn up to make life difficult for businesses; it exists because the consequences of faulty PPE are irreversible. Entrusting the inspection to someone who has not been properly trained is to take a legal and human risk that nothing can justify.

KRATOS SAFETY offers training courses on the periodic inspection of fall protection PPE, open to individuals designated by their companies. Upon completion of the training, a personalised certificate is issued, clearly setting out the scope of the trainee’s product-specific competencies.

For any training or information enquiries, please contact our team.