Joseph Feldstein has served as Chair of the U.S. Technical Advisory Group (USTAG) to ISOTC94/SC4 for Fall Protection since 1999. In this interview, Feldstein explains how the USTAG operates, its achievements thus far and its goals for the following year.
Please provide a brief description of your professional occupation and of your position within the USTAG to ISOTC94/SC4 for Fall Protection.
I work for Mine Safety Appliances Company (MSA), a manufacturer of personal safety equipment. My title is Manager of Technical Services, and I have 17 years of product design and standards development experience in fall protection.
My role as Chair of the USTAG is to bring U.S. interests into the ISO international standards-making process. I also carry the information gathered while working with international representatives back to the U.S. to advise U.S. interests of activities and trends in fall protection originating outside our country. Interested U.S. parties include standards development organizations, manufacturers, employers, government researchers, labor groups and trade associations.
The USTAG is one of 23 voting members in ISOTC94/SC4. What procedures must the USTAG follow to effectively participate in this international standards development process? How does this process differ from that of American standards development?
While the U.S. may be a global economic and technological leader, we have only one vote in the International Standards Organization (ISO), just as every other country represented in the Subcommittee on Fall Protection. U.S. interests are therefore in a distinct minority, especially because the European Union (EU) member states tend to vote as a bloc in favor of the European CEN standards. The USTAG has formed various alliances with other national TAGs to serve as a counterbalance to the majority status of the European states. Our USTAG follows the American National Standards Institute’s (ANSI) guidelines for the conduct of all USTAGs that participate in ISO.
The process of developing standards within the ISO framework is similar to that of U.S. national consensus standards bodies under ANSI. This is a process of voluntary consensus-building among the various participants, each representing their national interests. The U.S., like our European counterparts, is signatory to the ISO charter and abides by similar rules in our national standards organizations. The process depends on mutual agreement, with a democratic procedure that ensures majority rule but minority rights. So the process of standards development is familiar to U.S. delegates attending ISO meetings because the rules are similar to those we follow in our U.S. ANSI committee for fall protection.
ISOTC94/SC4 has developed a set of six approved ISO standards that represent a compromise between North American and European standards. However, these standards have not been adopted for use in North America or Europe because they are a hybrid set of requirements. What do these standards encompass, and what is their current status?
The initial suite of ISO fall protection standards was issued as a series from 2000 to 2002. They include the following personal fall arrest systems components:
The compromise involved the attempt to square the circle between U.S. and European fall protection equipment standards. In the U.S., our fall protection protective equipment must meet certain minimum requirements, such as a minimum breaking strength of 5,000 lbs, which are mandated in U.S. Occupational Safety and Health Administration (OSHA) regulations and ANSI voluntary consensus standards.
In Europe, the requirements for the same equipment are different. For example, CEN standards for minimum strength are set at 15 kN (3,372 lbf). The Europeans would not agree to increase their requirements to meet U.S. standards, and the U.S. could not lower our requirements to coincide with those of the Europeans. The resulting set of product standards reflects this impasse, a hybrid between North American and European criteria.
Consequently, the ISO 10333 series of fall protection standards could not be adopted by any of the ISO member states. Europe, Canada and the U.S. continued to promote their own national standards in developing countries where their products were sold.
Since the ISO 10333 series were published, they have not been adopted by any national standards organization. Last year, ISO TC94/SC4 committee members were faced with updating these standards according to the schedule for periodic review under ISO rules. The member delegates were no closer to reaching agreement on key issues in 2006 than they were when the standards were written. We agreed to administratively withdraw the ISO 10333 standards until further progress is made in harmonizing the competing national standards.
Australia has served as Secretariat of ISOTC94/SC4 since 2003. During the last four years, ISOTC94/SC4 has:
What role did the USTAG play in each of these projects, and what are the group’s goals for the following year?
Under the Australia Secretariat, the ISO TC94/SC4 has taken a different track in developing international standards for fall protection. The approach taken since 2003 has been to develop standards, which (a) do not conflict with existing national standards and (b) cover new topics not currently addressed by national standards. The USTAG was instrumental in convincing other members to take this approach, and subsequent events proved the value of this change in direction.
Interested U.S. parties were active in the creation of a Fundamental Principles of Rope Access document led by the Society of Rope Access Technicians (SPRAT). The President of SPRAT was also charged with drafting the next rope access document, Codes of Practice for Rope Access, which covers training, certification, equipment and job planning requirements. The success of these efforts was based on cooperative effort in sharing best practices from all ISO members. Since no national regulations exist for rope access, members were free to agree on the highest and best level of protection. The ISO TC94/SC4 committee avoided the pitfall of setting quantitative values on key requirements and instead left the decision on these values with the national regulatory authority in the states where the standard is adopted.
The USTAG also participated in the ISO Working Group for Descender Devices. U.S. interested parties provided input on the classification scheme, design requirements and test procedures. The published standard incorporates all criteria recommended by interested U.S. parties and serves as a model document for U.S. standards.
Next year, the USTAG will work on Fundamentals of Fall Protection, which is intended to be a guidance document on the proper selection and use of fall protection equipment. The USTAG will play a prominent role in providing example language taken from U.S. national standards. The USTAG has established America as a key partner in the development of international standards for fall protection. We anticipate building on our recent successes in crafting international standards that can truly be used worldwide.
You serve as a primary representative on the ANSI Z359 Accredited Standard Committee (ASC) for Fall Protection. How has this experience helped you in your work with the USTAG?
As a member of the Executive Committee for the ANSI Z359 ASC, I have the opportunity to work with U.S. standards writers for fall protection. The ANSI Z359 subcommittee discussions on standards writing help me understand the reasons behind the requirements. This inside knowledge can be very useful in advocating and defending the rationale of U.S. policies to those outside the U.S.
The USTAG has historically drawn from members of the ANSI Z359 ASC to serve as members and delegates on the USTAG. The USTAG was also instrumental in directing recent changes to the Z359 standards in a manner consistent with the eventual harmonization of U.S. and European fall protection standards.
The USTAG has recommended that the ISO Rope Access document and Descender Devices standard be adopted as U.S. national standards by ANSI. The ANSI Z359 ASC for Fall Protection is currently considering this recommendation.
Does it appear as though these standards will be submitted to ANSI soon?
Yes, the ISO Rope Access document and Descender Devices standard have both been placed on the agenda for possible adoption by the ANSI Z359 ASC. At the last meeting this year, USTAG delegate and SPRAT member, Louie Clem, was appointed as head of the ANSI Z359 Subcommittee for Rope Access. Clem proposes to adopt the ISO standard she helped draft as the U.S. national standard. The Executive Committee will take up the Descender Devices standard later this year, and it is my hope that we will agree to adopt it also as an ANSI/ISO document for the U.S.
The USTAG was recently named ISO TC94/SC4 liaison to the CEN Technical Committee for Fall Protection. What will be the USTAG’s responsibilities as liaison?
The USTAG is honored to serve as liaison to the CEN TC160 Technical Committee for Fall Protection. This is the European equivalent of the ANSI Z359 ASC but with an important difference. The standards CEN TC160 publishes will become the national standards for 22 European member states, with the force in effect of law. The USTAG will lay the groundwork next year for making Europeans comfortable with fall protection practices and technologies of countries outside of Europe, especially the U.S.
To facilitate understanding and cooperation among fall protection experts from Europe, the U.S. and other countries, the USTAG will set up a workshop in 2008 under the auspices of the International Society for Fall Protection. Our USTAG will invite expert speakers from both sides of the Atlantic to present their views on topics of common interest to standards writers in Europe and the U.S. Our goal is to open dialogue with fall protection specialists from the EU nations to better understand their concerns and to offer our views on best solutions in fall protection as currently practiced in the U.S. market. I believe there is general agreement that the time and effort spent by each of the national standards bodies in developing duplicative fall protection standards could be significantly improved by cooperative effort through participation in an ISO international process.
The USTAG is committed to the goal of a unified set of fall protection standards under the ISO framework, with a common set of requirements under ANSI/ISO in the U.S. and ANSI/CEN in Europe. We recognize that this goal may be years away from achievement. I find it encouraging that members of the USTAG also realize that the knowledge gained through exchanging views with our international partners in the process is as valuable as the goal itself.
Joseph Feldstein is Manager of Technical Services for Mine Safety Appliances (MSA) Company in Pittsburgh, PA. In this position, he works in marketing with responsibility for technical support in engineering and sales in North America and internationally.
Feldstein, who has 17 years of experience in fall protection product design and standards development, holds the following affiliations:
He has published articles in Occupational Hazards, ISEA Journal, Roads & Bridges and American Lift & Handler Magazine and has presented at numerous conferences and symposia.
He also holds a patent for a full-body harness for fall arrest and is a 2006 recipient of the National Institute for Occupational Safety and Health’s (NIOSH) Bullard-Sherwood Award.
Feldstein holds a bachelor of science degree in physical sciences from Colorado State University.