MSC HRA 2013-3 Physical Requirements for use of Fall Protection Arrest System (PFAS)

http://civmar.sealiftcommand.com/wp-content/uploads/2013/10/HRA-2013-3-PHYSICAL-REQUIREMENTS-FOR-MSC-PERSONNEL-IN-CONNECTION-WITH-US…pdf

  1. MSC and Seafarer’s International Union came to agreement on
    the appropriate arrangements for this new requirement which are
    listed below:
    a. MSC will provide a “grace period”, 12-months from the
    date of implementation, for any CIVMAR who exceeds the 295 lbs.
    Subj: PHYSICAL REQUIREMENTS FOR MSC PERSONNEL IN CONNECTION
    WITH USE OF FALL PROTECTION ARREST SYSTEM (PFAS) SAFETY
    EQUIPMENT
    weight limit. The purpose of this “grace period” is to allow a
    CIVMAR sufficient time to lose weight in order to get at or
    below 295 lbs. All “grace periods” will expire one year after
    the implementation date.
    b. MSC agrees no administrative action, specific to the
    Fall Protection Arrest Safety System (FPAS) equipment, will be
    taken until after the 12-month “grace period” has passed and the
    CIVMAR remains above the limit. During this “grace period”, any
    affected CIVMAR will retain his/her current rating but will not
    be assigned to work aloft.

Is MSC planning on firing all ratings that fall under this advisory and weigh over 295lbs starting Sept 2014 (after the 12 month grace period)? Is this a factor that MSC HR considers when hiring new employees?

I would have to assume that the 295lbs limit was born out of the swl of the harnesses or arrestors used to go aloft. Why did this issue come to a head in 2013? Were there any accidents involving folks who were 295lbs+ and working aloft?

I thought it was just assumed that the big boys didn’t go aloft in the same way they weren’t expected to be able to fit into a firefighter’s turnout gear. What about cold weather immersion suits? Are suits available that will fit a 295lbs+ man or woman?

Have the weight discrimination lawsuits start rolling in yet?

You cannot be fired at MSC. Yes, we special order the largest turn out gear and immersion suits available. 295 lbs is nothing at MSC, we have many folks 350+.

[QUOTE=UnRepKing;132027]You cannot be fired at MSC. Yes, we special order the largest turn out gear and immersion suits available. 295 lbs is nothing at MSC, we have many folks 350+.[/QUOTE]

If that’s really the case, then what’s the purpose of the advisory? Is MSC trying to scare obese mariners into losing weight or else face administrative action (whatever this means)? If they make turn out gear and immersion suits for these folks, I’m sure harnesses and fall arrestors can be sourced for them as well.

Sounds like blatant discrimination. Is body weight really going to be a deciding factor on whether or not MSC will hire someone?

Is MSC making an effort to help “big guys” lose weight? For example having a eating & fitness program for them to join. Are they making the stewards cook more healthy or have more healthy options to pick from. I’m sure the ships have weight/exercise rooms?

In order for guys to get below 295lbs they need to get their mind right and focus on eating right/exercise, but they also need a little help from company to get started and pointed in the right direction.

They make Jumbo Immersion suits that can fit guys up 375lbs.

What is not addressed in the MSC message is that workers under 130lbs are also outside of the safe weight operating envelope of the PFAS harnesses.

Here is a very good discussion on this issue. http://www.asse.org/practicespecialties/interviews/rwingfield2.php

What are the lard-asses doing at sea in the first place? If you can’t fit through a manhole your days at sea is over.

[QUOTE=Jeffrox;132132]What is not addressed in the MSC message is that workers under 130lbs are also outside of the safe weight operating envelope of the PFAS harnesses.

Here is a very good discussion on this issue. http://www.asse.org/practicespecialties/interviews/rwingfield2.php[/QUOTE]

Thanks for the link- good read.

From the discussion:

Typically, we use the term “capacity” when referring to workers’ weights in standards writing for fall protection equipment. The current capacity weight range given in the Z359 Fall Protection Code is 130-310 lbs. If we look at the upper range, 310 lbs. is the maximum capacity for a fully equipped (tools and clothes) worker. Most people in the industry define workers over 310 lbs. as “heavier workers.”
The criteria for defining capacity have not changed since 1992, and the Z359.1 standard has remained constant. We have discussed going beyond the 310-lb. range, but since we are governed by science and available data, the committee is holding to that capacity range as is.

If the “defining capacity” (310lbs) hasn’t changed since 1992, why is MSC making this an issue over 20 years later in 2013/4? Why 295lbs vs 310lbs? In some of the literature out there, they give an allowance of +/- 5lbs for clothing and gear. Where did the 295lbs number come from?

I can’t find any information that the PFAS is unsafe for individuals who weigh over 310lbs, just that the standard for testing the PFAS within these organizations is under 310lbs. From the same discussion:

Fall protection equipment manufacturers are producing harnesses, personal energy absorbers and other associated equipment with an increased capacity range, in some instances, as high as 440 lbs. Each manufacturer addresses this issue individually in its product line. For example, we see ranges of 375, 400, 420 and 440 lbs. among different manufacturers. Manufacturers have taken it upon themselves to decide the appropriateness of their equipment for use beyond 310 lbs.

Manufacturers are producing the equipment to safely handle folks who weigh up to 440lbs[/U], but the “non-profit” (ANSI) and federal testing (OSHA) organizations aren’t testing for capacities over 310lbs, yet.

Does anyone know whether MSC follows ANSI, OSHA, or another safety/testing organization’s guidelines when it comes to PFAS?

MSC has been talking about this for years. No, there’s been no accidents, just the standard stuff about how overweight people don’t do the jobs they are supposed to do (can’t drive forklifts, struggle to climb ladders, etc). They were all over the place with BMI, body diameters, and all the rest and standards and settled on the fall protection standards. Yes, the makers of the gear provide stuff up to 440 pounds and more (think about the guys wearing the metal suits working on high tension wires…think they weigh less than 310 pounds all fitted out?). But the Navy goes with ANSI and OSHA standards. So it doesn’t matter whether there’s things out there that a manufacturer says can handle things…if it doesn’t have an ANSI sticker, it doesn’t count. It’s purely a liability thing.
As to the plus/minus weight allowances, the MSC 295 pound weight limit allows for that. It allows for the 5 pounds of clothes and 10 pounds of tools and similar things being hauled up or used while aloft (if the stuff is tied off to you, then that’s part of the weight pulling on the harness).
As to the underweight topic, here’s the scuttlebutt on how that will be handled: “Those guys will just have extra weight added to them, like with a weight belt scuba divers use, to get them above the 130 pound limit”…how someone that small can function nimbly while being loaded down with extra 10-15 pounds they are not accustomed to while aloft to is beyond me.
And yes, in September, 2014…if you are more than 295 and in one of the billets where going aloft is required as part of your job in your job description…you will most likely be deemed to have not been ready to do your job as assigned. Just like if you don’t have a passport, your MMD, or things like that. “May or May Not” be fired, could be demoted to a job that doesn’t have the fall protection requirement. But if those jobs are already full and there’s no room for you…well, then you can’t be assigned to a ship which means you can’t be a mariner for MSC. And this does mean that at some point promotion packages and application packages will have some sort of body weight certification or statement or something to indicate you are within the standard (new hire that was overweight should be identified in NEO just like with any other medically disqualifying situation, like the guy that showed up that couldn’t hear…it’s anybody’s guess how they’ll do it for promotion boards.
Why now? Well, first time I heard the conversation, specifically on fall protection weights, was like nine years ago when SMS first started. The fact it took this long shows the level of priority it had…it wasn’t urgent, but it wasn’t something that they forgot either.
A couple things that stymied them were the really tall, skinny guys that are “overweight” by this definition, who now will have “admin procedures” and the shorter people who are within the weight standards but who physically have too big of a body diameter to properly close the the climbing harness that would be missed. But I guess they chose to start before solving those issues. Have heard stuff about “obstacle courses” and other things to go beyond fall protection weight limits and address the guys that can’t climb a set of ladders or get from the bow to the stern without stopping for a cigarette or who are on meds for claustrophobia or anxiety or anything else…but that’s probably another 9 years in the future.

"A couple things that stymied them were the really tall, skinny guys that are “overweight” by this definition, who now will have “admin procedures” and the shorter people who are within the weight standards but who physically have too big of a body diameter to properly close the the climbing harness that would be missed. But I guess they chose to start before solving those issues. Have heard stuff about “obstacle courses” and other things to go beyond fall protection weight limits and address the guys that can’t climb a set of ladders or get from the bow to the stern without stopping for a cigarette or who are on meds for claustrophobia or anxiety or anything else…but that’s probably another 9 years in the future.[/QUOTE]

Really? Stymied? There is no such thing as a tall skinny guy who weighs 295. Nor do we have a super short fat guy under 130 lbs. This ruling is just MSC exercising some little used common sense and I’m glad they’re doing so.

What common sense are you referring too? If suppliers are manufacturing pfas gear for folks above 295lbs or below 130lbs, why shouldn’t these mariners be able to do a job where the equipment is available for them to do so safely. Assuming a mariner’s abilities solely on his or her weight is blatant discrimination. So firing or demoting +295lbs mariners because MSC decides to create a new policy that says it’s ok to do so is troubling to say the least. Am I surprised the SIU hasn’t chimed in yet? Not really; just reinforces the union’s inability to positively impact federally employed mariners. Maintain the status quo or at a level just slightly below.

[QUOTE=Abronson;134095]Am I surprised the SIU hasn’t chimed in yet? Not really; just reinforces the union’s inability to positively impact federally employed mariners. Maintain the status quo or at a level just slightly below.[/QUOTE]

The MSC directive states that this policy was crafted after consultation with and in agreement with SIU.

[QUOTE=Slacker;134068]"A couple things that stymied them were the really tall, skinny guys that are “overweight” by this definition, who now will have “admin procedures” and the shorter people who are within the weight standards but who physically have too big of a body diameter to properly close the the climbing harness that would be missed. But I guess they chose to start before solving those issues. Have heard stuff about “obstacle courses” and other things to go beyond fall protection weight limits and address the guys that can’t climb a set of ladders or get from the bow to the stern without stopping for a cigarette or who are on meds for claustrophobia or anxiety or anything else…but that’s probably another 9 years in the future.[/QUOTE]

Really? Stymied? There is no such thing as a tall skinny guy who weighs 295. Nor do we have a super short fat guy under 130 lbs. This ruling is just MSC exercising some little used common sense and I’m glad they’re doing so.[/QUOTE]

West coast has a 6’8 guy that weighs 325. Skinny; not anorexic skinny, but fit skinny. There’s a couple of 6’4 and 6’5 guys that work out that are pushing 300 as well (don’t think there’s not a list of who is over 300 and who isn’t). And no, there are no super short fat guys less than 130. But we have a lot of short fat guys who can’t close the harness. Or lifejackets. But they are within the weight standard. The “stymied” came from the fact that they didn’t want to eliminate the skinny/fit people, but did want to “encourage” the shorter, rotund folks to move on. Point is, whether the solution is right or wrong, that’s what took so long.

Shouldn’t it be about whether you can do your job or not? And not whether you are tall, short, fat, skinny, are missing the tip of a finger, smoke, dip, drink, or have a beard? If any of your abilities get in the way of doing your job (too fat to get behind the wheel of a forktruck, can’t work with your arms above your head, can’t handle the heat/sun, are unable to bend at the waist to needlegun, smoke so much you can’t make it up a ladderwell, have a beard so your respirator/SCBA doesn’t seal, drink so much you don’t get to work on time), then that’s the issue…not a measure of scale, ruler, or how pretty you look in the uniform of the day? I know lots of guys that have difficulty with the physical ability to their job that are not overweight. And that’s without going into the guys on daily doses of mood-controlling medicine.

A person 6 foot 8 inches and 325 lbs would have a body mass index of over 35. I don’t regard the use of BMI as a foolproof standard but this still falls well in to the obese zone. As for equipment for larger workers, that stuff is all special order equipment that might also require additional modifications.