CSA Standards – Meeting the requirements of Legislative Interpretations

Topic: CSA Standards – Meeting the requirements of Issued by: VP, WorkSafe Services
Statute: General Regulation 91-191 Date Issued: October 8, 1997
Section: 49.1(1)(c) and 49.1(2) Date Revised: March 1, 2023

49.1(1) An owner of a place of employment, an employer and a contractor shall each ensure that the components of a fall-protection system

(c) meet the requirements of the applicable standards.

49.1(2) For the purposes of paragraph (1)(c), the following CSA standards apply:

(a) Z259.1-05, “Body Belts and Saddles for Work Positioning and Travel Restraint” or Z259.1-95, “Safety Belts and Lanyards”;
(b) Z259.2.4:15 (R2020), “Fall arresters and vertical rigid rails”, or a standard offering equivalent or better protection;
(c) Z259.2.5-17, “Fall arresters and vertical lifelines”, or a standard offering equivalent or better protection;
(d) Z259.2.2-17 (R2022), “Self-retracting devices”, or a standard offering equivalent or better protection;
(e) Z259.2.3-99, “Descent Control Devices”, or a standard offering equivalent or better protection;
(f) Z259.10-18 – Full body harnesses or a standard offering equivalent or better protection;  
(g) Z259.11-17 – Personal energy absorbers and lanyards or a standard offering equivalent or better protection; 
(h) Z259.12-16 (R2021), “Connecting components for personal fall-arrest systems (PFAS)”, or a standard offering equivalent or better protection;
(i) Z259.14-01, “Fall Restricting Equipment for Wood Pole Climbing”, or a standard offering equivalent or better protection;
(j) Z259.13-04, “Flexible Horizontal Life Line Systems”; and
(k) Z259.16-04, “Design of Active Fall-Protection Systems”.
(l) Z259.15-12 (R2016), Anchorage connectors or a standard offering equivalent or better protection.

NOTE: THIS EXPLANATION APPLIES TO ALL OTHER SIMILAR WORDINGS IN REFERENCES TO STANDARDS.

Question
Does the item of protective equipment have to have a CSA approval sticker on it?

Response:
No. The CSA (or ANSI or ASHRAE) sticker is a very easy way of establishing that the equipment meets the standard, but it is not the only way.

“Meet the requirements of” means it has to be fabricated in accordance with the provisions of the standard but it does not necessarily require certification by CSA. For example: If the CSA standard says the only requirement for a rope is that it must be capable of withstanding 5,000 lb, and a rope will withstand 5,000 lb, then that rope “meets the requirements of the standard” even though there is no CSA label on it.

It is harder to judge if equipment "meets the requirements of" when there is no label. A certificate from an independent laboratory, an engineer’s certificate or some form of non-destructive testing would be alternatives. The equipment would have to be clearly substandard or deficient before an officer would require any of these.

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