Fall Protection Discussion with Loui McCurley


Episode 185: In this episode host Phil Brown chats Loui McCurley, an expert in fall protection and rope access. She is CEO of PMI (Pigeon Mountain Industries) and original founder of SPRAT (Society of Professional Rope Access Technicians). 

Topics and Questions Presented in This Episode

One of the key aspects of fall protection is understanding the distinction between fall positioning, fall arrest, and fall prevention. Loui guides us through these different approaches, illuminating how each method serves a unique purpose in safeguarding individuals working at heights. Loui also delves into the contrasting approaches of active fall protection and passive fall protection.

Clear communication is vital in the realm of fall protection, and Loui emphasizes the importance of using the correct terminology when describing fall protection systems and equipment. She discusses how accurate terminology eliminates confusion and ensures effective communication between professionals, workers, and regulatory bodies, ultimately promoting a safer work environment.

Standards play a pivotal role in fall protection, and Loui highlights their significance in maintaining consistent safety practices. She delves into the process of creating fall protection standards, discussing the key principles that inform their development and implementation. Furthermore, she enlightens us on how these standards principles can be effectively taught to professionals, empowering them to uphold the highest safety standards within their respective industries.

In the world of fall protection, being authorized, competent, and qualified are distinct designations defined by OSHA. Loui explains the nuanced differences between these terms, shedding light on the specific requirements and expectations associated with each. Listeners gain a comprehensive understanding of the qualifications and competencies necessary to ensure optimal worker safety and compliance with regulatory guidelines.

Join us for an incredibly informative conversation with Loui McCurley, as we explore the realm of fall protection, its intricacies, and its profound impact on worker safety. Whether you’re an industry professional or someone interested in height safety, this episode promises to deepen your understanding of fall protection, leaving you equipped with valuable insights to promote a safer working environment.

Be sure to check out the next episode where we continue the conversation with Loui, this time discussing rescue principles and techniques.

Additional Resources

Learn more about PMI at: https://pmirope.com/

Learn more about SPRAT at:  https://sprat.org/

Connect with Loui  – lmccurley@pmirope.com

Full Show Transcript


A little backstory for listeners. I attended a couple of workshops that Louis led at the most recent ACCT conference at the actual PVM professional vendor member symposium. Let us start with this first topic. If we can, we’ll go straight into it. Louis, explain to the audience. I know that’s a big topic, but rope access.



Oh my goodness, thanks for making a small topic. You know, that really helps to narrow it down, Phil. I appreciate that. Rope access, it’s funny because historically, people will think of rope access as like literally anything to do with ropes, right? So if you’re hanging on a rope, it’s rope access. That’s not necessarily true. So rope access is the term that has been chosen to describe a certain type of fall protection that also involves access.



And so rope access in its definition, according to standard E’s, like according to ANSI and ISO and then the standards organizations. Rope access is any two rope system in which one rope provides the means of access and egress and the other rope provides safety backup and in which the primary and secondary ropes are interchangeable.



So I can put my primary system on my secondary rope and vice versa at any point throughout, while always maintaining at least two points of context. That’s the simple boiled down definition of rope access. Now rope access is used in a bunch of different kinds of environments, right? It can be used for any number of people. Oh, rope access, that’s what window cleaners use, or that’s what rock scalers use, or that’s what bridge engineers use. And all of those are true, but that’s not all they use. It’s just one of many.



types of fall protection. So you can compare it, for example, to fall arrest is another type of fall protection. Positioning, restraint are all other types of fall protection. Can I get you to elaborate a little bit on, because I’ve got this written down, the differences, the nuances between full protection, full arrest, full prevention, full restraint. All of these words have the fall in them. And I know that that can overwhelm people when they hear, especially with



new standards in our industry, OSHA standards around work at height, that some of these can be very overwhelming for people. And we’ve got lots of people, our clients who are, what’s the difference between these full protection, full arrest, full, it just feels a lot of language. That’s a really good question because so often I hear these terms being used interchangeably. People just make an assumption that, you know, fall protection equals fall arrest, for example.



If I’ve got fall protection, it must mean that I’m working in a harness and if I fall, I’m attached to a dorsal attachment and I might perhaps be caught if I fall. That’s not necessarily true. Fall protection is generically in the big picture, fall protection is anything that protects you from a fall. So it might include a safety rail. So if you can’t fall because there’s a safety rail in the way, that’s fall protection. It might involve restraint.



Restraint is a type of active fall protection. So let’s look at those two different things first. We have active fall protection and passive fall protection. Active fall protection is something that requires you to do something like put on a harness attached to something. Active fall protection is different from passive fall protection because passive fall protection thinks for me. It’s the handrail, the safety rail that’s already there.



that prevents me from falling unless I’m doing something ridiculous like crawling over it. So active fall protection is further divided into certain types of fall protection. So restraint is a type of active fall protection that prevents me from reaching an edge where I might fall. So it’s essentially a leash. You put a leash on so the person can’t reach the edge.



that allows me to maintain a position on a slope, like a roofer working on a steep roof. He’s gonna lean into that fall protection. He’s gonna lean into the positioning system so that he maintains his footing. But if he falls, if there’s a chance of him falling, he should also maintain another true fall arrest system so that in the event of the failure of that positioning system, he is caught. So what’s this fall arrest of which we speak? Well,



Fall arrest is anything that arrests or catches your fall in the event of a release of the main system. So if the main system is your feet, a fall arrest system will catch you if your feet fall off of the ladder, for example. A fall arrest system can also be a passive system, which is a little bit confusing to some people, but there is such a thing as a passive fall arrest system, and it might include netting.



So under a bridge, for example, if people are working on the edge of a bridge, there might be a net system that prevents them from falling 20 feet, but they get caught by this net. Active fall protection, passive fall protection are kind of the key terms, and fall protection in general is anything that protects you from a fall. So essentially there’s this umbrella of like fall protection and then underneath this umbrella is the different methods by which we protect.



people from a fall. Mills-Powell That’s a fabulous way of looking at it, Phil. Mason-Dyer You mentioned that those words get used interchangeably. Where do you see that being an issue? I think that even people listening to this might be like, oh, is this just legalese? What’s the importance of understanding these definitions? Mills-Powell As an employer, it’s very important to understand that OSHA requires that we provide fall protection to anybody who’s working at height. So OSHA, the Occupational Safety and Health Administration…



says of any employer, if you have employees who are working at height in a hazard, you have to protect them from that hazard. So as an employer, there’s a number of things that I might be able to choose as methods to protect them. And so that, as we talked about the methods of fall protection, each one of those methods has different rules. So fall arrest, for example, in a typical fall arrest system.



OSHA says that I’m not supposed to let someone fall more than six feet. So I have to catch them within that six foot range. Now that’s a pretty simple definition and there’s definitely more to it than that. But that differs from a positioning system in that in a positioning system, I’m supposed to be leaning into the system and not falling at all. So knowing how to build the systems, how to rig the systems and how to keep those systems compliant and safe for the employee.



is critical to understand the terms. Mason- You were involved, I know that you were involved in some of the standards that you were speaking of. What was that process like? And I’m sure the answer is not the positive, but how maybe was that process? And what do you see from going through that process? Is the importance of why this needed to have occurred? Where do you see the benefits on some of these standards that have come into place in the recent years?



Let me start by saying that I am the original anti-standards person. I am that person that says, hey, train your people really well and give them the tools and resources they need to do their job and leave them alone. Let them go do what they need to do. And so from that perspective, the concept of standards rears its head. Right. And the reality is, is that OSHA



right, has standards. OSHA has regulations. And whether we like them or not, we have to meet those standards. We have to meet those requirements. And so the way that most people meet OSHA requirements is by using ANSI standards, which are a little bit fuller. They’re a little bit more detailed. They have the how-to, whereas the OSHA regulations basically say, here’s the limit, here’s where the line is, don’t cross it. And ANSI standards kind of define that and say,



Well, here’s what they mean by that line and here’s how to not cross it. And here’s the kind of equipment that you need to use. And here’s the limitations that you need to place on a system and that sort of thing. When I was first asked by my employer to get involved in standards development, I laughed. I was like, uh-uh. And his response to me was, well, Louie, you know, if you’re not sitting in that room, somebody’s going to be.



And so which would you rather do? Have somebody who doesn’t like standards and doesn’t want over-standardization to be sitting in that room. Or to have somebody who’s excited about being able to write rules for other people sitting in that room. And I thought about it and said, great, when do I start? In reality, there’s all of us sitting in that room. Now a lot of people believe that people, you know, safety through engineering, right? People shouldn’t have to make decisions. People shouldn’t be allowed to make decisions.



Everything should be standardized to the point that there’s no variation, there’s no deviation. And if we can do that, everybody will be safe. I don’t know about you, Phil, but that’s not the world that I work in. My world is not a standard world. Everything’s different. The places I work every day, the kinds of structures I’m working on, the kinds of environments where the ropes that I manufacture are used, all of that, it’s different all the time. So how can you use a standardized system?



to build a safety program for a non-standard environment. So for me, the important thing about developing standards is that the standards need to be measurable. They need to have some criteria by which you know whether you’re in or out, but not so specific, not so design restrictive that you have to do it, you have to connect, you know, carabiner A to anchor B the same way every time.



So that’s where, this is a really roundabout answer to your question, I know, but what happens in the real standards environment is that there are people sitting at the table who believe on opposite ends of that spectrum. And so there’s this kind of constant push and pull. And that in reality is what standards are. Standards are where everybody gets their perspective and everybody inserts their perspective and you pull on it a little bit like a tug of war.



as my friend Steve Hudson used to say, a good standard is one in which everybody is a little upset. So it’s true consensus when everybody’s just a little bit upset. And if we can have those people who are so specific and they want everything to be defined down to the nth and we can balance their needs with the people like me who just want to provide information and let people go do their work, I think we end up with a decent standard.



I’m going to thank you for being a part of that because I’m also of the mindset we’ve had discussions internally before around our involvement in different committees or joining different things. And I’ve had that same thought around, well, if we’re not there, then somebody else will be and then we don’t get to complain after the fact because we had this opportunity to maybe be there. And so I thank you for being there because I know that the stepping into those processes aren’t easiest.



I’m almost guaranteed just in this brief conversation and the small conversations we had at ACCT, you brought in a lens that was very valuable. And even just being somewhat a little bit anti-standard, I think is probably the best person to be in the room. Oh, thank you. Thank you. I’m going to give you an example, Phil. This is an interesting one that comes up a lot because rope strengths are measured in different ways. So if in different industries…



commodity ropes, for example, the strength of a commodity rope is not measured in the same way as a life safety rope is today. That wasn’t the case when I first started in rescue, I won’t say how long ago, but all these ropes were coming in. It was like, well, this rope, look how much stronger this rope is than that rope is. It’s like, wow, this one’s rated at 5,000 pounds and this one’s rated at 7,000 pounds. They’re the same size rope. Why is that? What’s the difference? Well, come to find out at that time.



There was no consistent way to measure the strength of a rope with any kind of statistical significance. So breaking strength might be the manufacturer pull tested a rope and the number that he came up with is the number that he put on the package. Or a manufacturer might test 10 ropes.



the best number he came up with is what he put on the package. Or maybe he was really conservative, and it was the lowest number that he put on the package. Or maybe it was somewhere in between. There wasn’t any way to know it. There was just no consistency in that. And so the Cordage Institute wrote a life safety rope standard to help differentiate this, because in the Cordage Institute in those days, rope strength was measured by mass per unit length. So if a rope weighed so much per meter, the assumption was that it was



so many pounds strong. And so they wrote a standard for life safety rope that really kind of brought all of that together. And they said, okay, well, you have to do at least five tests on this given rope. It needs to measure or calculate five standard deviations below the mean breaking strength of the tests that you performed. And then you need to report something at that strength or lower.



as you’re, you know, that’s the highest breaking strength that you’re allowed to report as the minimum breaking strength. So now, all of a sudden, there’s some consistency. Now we have some sort of constant with all the manufacturers who subscribe to that standard, who all of those manufacturers who say, yes, I make rope according to the Cordage Institute standard. Now you know how they’re measuring their strengths and it’s not just an arbitrary number. I know that for you as well.



training is a big part of this, right? The education of this is such a big part of it. There’s no clear defined, you’re going to go to the same place and see the same thing, right? How do you teach that? Because we get in this mindset of like, how do we teach thinking practitioners? I don’t want the answer to be because Phil told me or Louis told me, right? That’s right. That’s right. How do you teach that? This is one, Phil, where, and I’ve wrestled with this over the years because from the beginning, like,



I’ve always believed that in order to be safe at height on rope with rigging systems, I mean, if you’re doing fall arrest or just a non-thinking system, then okay, you know, whatever, you know the rules and you know how to use them. But if you’re doing any kind of rescue rope access, anything where you actually have to think about your systems, you dang well better understand exactly how those systems work, what happens when they don’t work, what are the consequences of failure.



You need to understand where your weak points are in the system. You need to be able to analyze your systems. And so I’ve always been of the belief that people should understand concepts. So if I have a descender, it’s not that it breaks. It’s not that it, as in B-E-R-A-K-E, it’s not that it breaks me down the rope. It’s not that it provides friction. It’s open that sucker up and see how it works. And why does it make friction?



And if it’s not making the right amount of friction, why could that be? And how would you analyze that? How would you even think about it if you were in that predicament? And so understanding why your year works and what happens when you attach that descender to an anchor or to your harness and what are the physics at play and what’s going to cause it to malfunction and what are the things that you don’t want to do and why, and all of that’s so, so, so very important.



And then I started to run across people who they’re doing well just to understand where to attach it. Right? And, and, and you can’t teach everybody the concepts. Everybody is not, you know, there’s, there’s an aptitude that people are naturally ingrained to do something or another. And some people are really good at maths and some people are really good at, at English and some people are, are really good at rigging and they’re not always the same people. And so.



So I’ve had to come to learn that and I’ve had to come to the point where in an organization, it’s probably a good thing to have a standardized system. It’s probably a good thing to have, this is how we do it. You attach curbing or A to anchor B and you put your lanyard here and this is what it looks like when it’s wrong or when it’s right and anything other than that is wrong. So within an organization, I think it’s super important to have that level of



I don’t know, is that training even the word? You know, that level of understanding. But for a true technician, for somebody who’s going to be making systems, somebody who’s going to be designing systems, somebody who’s going to be deciding whether that system that somebody else just made is safe or not, I think understanding the physics behind things is super, super important. And I know that word physics scares people and it’s really not, I’m not a scientist, but.



I love physics, right? Because I love ropes and I love gravity and I love height and all those things when you put them together, guess what they create? You’re right in the middle of some principles of physics and you’ll understand physics really, really fast whether you know the words or not. And that’s where I think experience is absolutely essential. Doing a couple of things wrong over the course of your life and hopefully you survive it, right? You have all your systems backed up and you have your principles in place so that when you make mistakes, A, you catch them and



be, your system catches you. Understanding is experience. Without going through that, I don’t think people can really grasp. I don’t think that just learning from a book or learning in a class, here’s where you attach and that’s how you attach, I don’t think you can get it. I think that has to be some tactile, some time on rope, some time with your feet in the air. Mason I think this lines up as well with the two words that jump into my mind when I think



I’ve racked my brain around, I was having a discussion with another trainer about how much information do we want to give and how much do I bring to the table just because I’m a nerd about something, right? Even at a very basic level, I used to teach the history of belaying because I loved the mechanics of the technology change and I think that that informs why we do things a certain way. But for a new person who just is being sent to a belay training, all of that is over their head, right? They don’t want it.



And in fact, that could be negative to their learning and now they’re overwhelmed. And so I think about these two words and I know they apply also to standardization in OSHA, but competency and qualified. Someone who’s a competent person and is a qualified person. I wonder if you could speak to those, like what those words actually truly mean and maybe how that even applies to some of the training. You know, it’s, it’s interesting. OSHA actually likes those words and OSHA has come up with some definitions that are used pretty much throughout.



the working world, regardless of what industry you’re in, these generic definitions pretty much apply. And actually they have three words. They have authorized, competent, and qualified. And in OSHA speak, authorized simply means that you’re allowed to do a job. So I, as your employer, have given you enough training that I believe that you can go out there and do a job. Not think, not make any decisions, but just do what you’ve been taught to do.



competent, Osha defines, as someone who has enough experience in training to be able to recognize a hazard when they see it and to take prompt, corrective action. So in practical speak, we would often think of that as maybe a supervisor, right, on the job site. But that’s that person who he may not know how to design a new system or how to fully even rig the big picture, but he understands it well enough to be able to recognize it when it’s wrong.



and to take prompt corrective action. Even if that action is only to say everybody out of the field, you know, everybody out of the pool, that’s competency. And then qualified is defined again in regulatory speak as having enough experience and education relevant to the topic at hand. So you can be any of these things in rigging, but you can also be any of these things in driving a boat or whatever, any driving a forklift or, or whatever.



Qualified would be that person who has enough knowledge and experience and training specific to the field that we’re talking about to be able to design systems and create systems and to decide how those systems should and shouldn’t go together, what kinds of equipment is appropriate for use in those systems and what is not. Some people in work at height safety consider that only a professional engineer can be a qualified person.



Now that’s not necessarily true in OSHA language. OSHA doesn’t necessarily say that, but some of the standards do in ANSI, and there’s kind of an underground belief among, I guess I should say among engineers that feel strongly about that. But my belief is that anybody who is going to be designing and building challenge courses, anybody who’s going to be, has enough knowledge and training.



to design and specify the type of fall protection that’s going to happen in that challenge. Of course, those are all qualified people. They’re qualified by virtue of their experience and training specific to that industry that many a professional engineer wouldn’t comprehend if they walked on site. So that just by virtue of the world that you live in, the world that you work in, it qualifies you to that level.



Practitioners on a challenge course and we kind of encourage people to seek outside of just their niche so even as I’m talking about this I am internally very desperate to take a training with yourself at PMI because Just on rope access because there’s a whole there’s a whole overlap, but there’s stuff that will not be applicable but I just think the overlap is the part that I’m more intrigued about and even the process of



training. I think that there’s philosophy in training that I’m kind of intrigued to watch other trainers do stuff and just say, wow, I’m going to take this or whatever. But, and I encourage other people as you’re listening, not just saying I want to go there, but I would encourage yourself to reach out and take some training with PMI just because even if you’re an educational, traditional dynamic belayed course, like what we might be, I think the overlap between even the, even the discussion on some of these things around full protection are so important because the greater your understanding, the more broad you can be.



in this qualified mindset of being able to make choices and decisions. It is. I think that one of the most exciting things that I get to do because of my unique role in PMI, we serve so many different markets, right? I mean, we serve the rope access market. We serve bridge engineers. We serve rescue people, fire departments, SWAT teams, rope access teams, cavers, climbers. I mean, it’s and to be able to connect with all those different people in their respective environments.



to be able to go on jobs with people in different environments. It’s like, wow, I can take this and apply this there. Oh my goodness. Why did we never think of that? You know, it’s, it’s so to me, that crossover in knowledge and understanding is huge. And there’s a annual event called the international technical rescue symposium. And it’s held every year in a different location. It’s, it’s underwritten by PMI and CMC, but it’s not, um, it’s not, it’s not commercial in any way.



Basically, all of these people come together. It’s limited to under 200 people. So only a maximum of 200 people are allowed to come every year, just to keep the dialogue intimate, if you will. And people present on everything from, I had this incident happen, and here’s what happened, and hey, what do you all think? Or, hey, this really cool new device came out, and I know it’s not designed for this, but guess what I did? I tried it in this manner, and it worked. Isn’t this cool? And I mean, just all these different presentations.



And they’re all from different industries. Like there’s rope access people there, there’s cavers there, there’s climbers there, there’s mountain rescue people there, there’s fire departments there, there’s industrial rescue teams there. And they’re all sitting there in the same room and presenting during the day and asking each other questions. And then at night everybody hangs out together and they go to dinner together and they come to the hospitality suite and discuss things. And to me, it’s just, it’s information over mode for three days, but it’s the most exciting three days of the year for me.



because there’s such knowledge and such depth and breadth of experience in all these people that to have it all come into the, I mean it’s giving me goosebumps even now, to have it all come into the same room at the same time, it’s just, it’s cool, it’s really exciting. Well save me a seat, Louie.