Cal/OSHA §1670 Compliance Checklist: Mastering Fall Arrest and Restraint Systems in Waste Management

In waste management, heights lurk everywhere—from tipping trailers and compactor roofs to conveyor towers and landfill berms. One misstep on a greasy catwalk, and you're looking at serious injury. Cal/OSHA Title 8 §1670 sets the bar for personal fall arrest and restraint systems (PFAS), demanding systems that arrest falls within safe limits and restrain workers from edges. We've audited dozens of facilities where skipping this compliance led to citations; here's your no-nonsense checklist to lock it down.

Step 1: Conduct a Thorough Fall Hazard Assessment

Start here. §1670(a) requires identifying all walking/working surfaces 6 feet or higher in waste ops—think truck hoist areas, shredder platforms, or wastewater tanks.

• Map every elevated work zone using site plans and worker input.
• Measure fall distances precisely; account for waste pile variability in landfills.
• Classify hazards: leading edges (dumpster lips), holes (conveyor gaps), or slippery surfaces from leachate.
• Document swing fall risks—unique in tight waste processing bays.
• Prioritize based on frequency: daily truck maintenance tops the list.

This isn't paperwork; it's the foundation. In one SoCal yard we consulted, reassessing after a near-miss cut violations by 40%.

Step 2: Select Compliant Fall Arrest and Restraint Systems

§1670(b)-(d) details criteria. Fall arrest decelerates to ≤1,800 lbs max arrest force; restraint prevents reaching the edge.

1. Choose full-body harnesses meeting §1670(c): inspect for "A" rating, no fraying.
2. Pair with shock-absorbing lanyards or self-retracting lifelines (SRLs) rated for your max fall distance (MFD ≤6 ft per §1670(e)).
3. For restraint: shorter lanyards (<6 ft) without shock absorbers, ensuring no edge contact.
4. Select anchorages per §1670(f): 5,000 lbs static strength for non-certified, or 2:1 safety factor for engineered.
5. In waste: opt for chemical-resistant gear against corrosives; horizontal lifelines for truck roofs.

Pro tip: We've seen cheap imports fail spectacularly in salty coastal dumps—stick to ANSI/ASSE Z359 certified.

Step 3: Install and Use Systems Correctly

Installation per §1670(g) isn't optional. Wrong setup turns gear into liabilities.

• Position anchors overhead to minimize free fall (<6 ft).
• For horizontal systems, engineer deflection under dynamic loads—critical over soft waste piles.
• Train on donning: dorsal D-ring up, leg straps snug but not tourniquet-tight.
• Restraint zones: mark 6-ft boundaries from edges with tape or lines.
• Rescue plan mandatory (§1670(h)): prompt retrieval, no suspension trauma—stock descent devices.

Step 4: Implement Rigorous Inspection and Maintenance

§1670(i) mandates pre-use checks and annual pro inspections. Waste environments accelerate wear.

• Daily: visual for cuts, burns from hot waste, UV degradation.
• Monthly: load-test SRLs; log serial numbers.
• Post-incident or drop: retire immediately—no second chances.
• Maintain records 1 year; tag out defective gear.
• Audit storage: away from chemicals, hung vertically.

Real talk: A Fresno client dodged a $50k fine by catching a frayed lanyard in routine checks.

Step 5: Train and Document for the Long Haul

§1670(j) requires competent person oversight and worker training.

1. Hands-on sessions: fit-testing, emergency procedures (2-min rescue goal).
2. Annual refreshers, plus post-change (new equipment).
3. Certify trainers; use Cal/OSHA-approved curricula.
4. IIPP integration: tie to your Injury and Illness Prevention Program.
5. Records: training logs, assessments, inspections—retain 3 years.

Compliance isn't static. Revisit quarterly in dynamic waste ops. Reference full regs at dir.ca.gov/title8/1670.html and ANSI Z359 for depth. Nail this checklist, and your team works safer, inspectors walk away happy.