Session No.

518

Innovative Fall Protection for Limited Clearance Situations

Greg Small, P.Eng., M.Eng., P.E.
High Engineering Corp
Calgary, AB
Kevin Denness
Project Manager
Saxon Energy Services
Calgary, AB

Introduction
The authors of this paper are sharing their solutions for land-based mobile Oil and Gas Drilling
rigs, but believe the philosophies and strategies presented here have application to many other
industrial situations, where working platforms are not very high.

What is a Drilling Rig?

A drilling rig is an assembly of
components such as a derrick, tanks
to hold mud, power generation
systems, offices, accommodation etc.
as illustrated by the photograph in
Figure 1.
The purpose of this complex
assembly is to drill wells into the
ground. The majority of Drilling Rigs
are used for oil and/or gas exploration
and exploitation. Different types of
rigs also exist for water, minerals and
Figure 1
scientific research. Oil and gas is
Typical Land-Based Mobile Drilling Rig
found worldwide so specialist rigs
have been developed to work in all geographical regions, including at sea and in arctic
environments.
A major design consideration is the ability to handle different types of wells, and most
importantly, different drilling depths. Deeper wells require more power to lift the drill bit from
the bottom of the hole, requiring rigs to become larger and heavier.
Generally rigs are mobile, because the investment to build one (typically $5M to >
$500M) is too high to drill only a single well.

In some parts of the world that have open spaces such as at sea, the high arctic, or some
desert areas, the rig can be kept fully or partly assembled for transport from one well location to
the next.
In most land based drilling, there are
significant transportation constraints, to protect
the highways, bridges and other users of the
transportation infrastructure.
Restrictions include limitations of the
maximum weight and size. As a result, most rigs
have to be broken down into several discrete,
transportable parts.

Figure 2
Break Down of Rig for Highway Transport

Some rigs move as frequently as every

few days, so it is critical that they are designed
for rapid assembly and disassembly.
Therefore, it is very important that all safety
systems on the rigs do not adversely increase the
transportable size, and be designed for rapid
deployment and knock down.

The Hierarchy of Fall Protection Abatements

ANSI Z359.2, Minimum requirements for a Comprehensive Managed Fall Protection Program,
directs us to follow a hierarchy of solutions that progress from preferred to marginally acceptable
solutions.
1. Eliminate the Hazard
Those of us who work in fall protection could all go home if it were possible to decree that all fall
hazards be solved by eliminating them. This is often not practical because the world is three
dimensional. Our infrastructure includes many high structures such as buildings, bridges and
towers, that must have height to be functional. Even low structures (including roadways and
walkways) are installed at high locations on the terrain that nature provided. We cannot, in any
practical or cost affordable way, lay down buildings to wash the windows, or re-grade the terrain
to eliminate all fall hazards.
2. Guard the Hazard
Putting up guards to keep workers from reaching the fall hazard is our most common approach to
fall protection.
Unfortunately, it too cannot be a universal solution because of many situations where
complete guarding makes it impossible, difficult or even dangerous to do the work. The cost of
Guardrailing may be prohibitive for low frequency of access.

3. Travel Restraint System

Travel restraint is a great third choice, but is limited to horizontal work platforms that have a
geometry and size that enable the worker to be tethered to an anchorage system in a way that
makes it impossible to fall off. This solution is ideal for circular platforms such as the tops of
large tanks. Irregular perimeters often make it very difficult or impossible to implement. Even a
perfectly rectangular platform requires dual tie-off to prevent the fall of a worker at a corner.
When the platform is too small (i.e., you do not have at least 7 or 8 feet from anchor to edge), or
when the system requires adjustment, but the worker has to carry tools and materials in his/her
hands, Travel Restraint becomes impracticable.

4. Fall Arrest System

Fall Arrest, which is designed to stop the worker from falling to the next level, is also not always
feasible. Although properly designed and implemented Fall Arrest systems work well to protect
falls from great heights, this solution is limited by the distance that a Fall Arrest System requires
to arrest the fall. Fall Arrest Systems are difficult or impossible when the working elevation is too
close to the lower level we dont want to fall to.
5. Fall Protection Plans and Administrative Controls
US OSHA, and some other regulators, allow use of a Fall Protection Plan, including safety
watches and control zones, but ONLY when it has been proven that other measures (1 to 4) in the
above Hierarchy are impracticable.

Understanding the Hierarchy

Solutions 1 & 2 (Elimination and Guarding) are Passive, meaning that the workers do
not have to take any specific actions to be protected. They just do their work without
needing training on how to recognize and deal with the fall hazard.
Solutions 1, 2 & 3 (Elimination, Guarding and Travel Restraint) prevent the fall from
occurring, so there is a negligible risk of injury. Because the fall is prevented, these
three solutions are the first line of defense when available Clearances are limited.
Solutions 1, 2, 3, & 4 ((Elimination, Guarding, Travel Restraint and Fall Arrest) are
deemed Positive Fall Protection in that if they are properly implemented, it is
impossible for a worker to fall all the way to the next lower level.
Solution 4 (Fall Arrest) is difficult to implement in Low Clearance situations. This
solution also doesnt eliminate all risk of injury. A Fall Arrest incident is very similar to a
car accident (where safety systems such as Belts, Air Bags, and Crumple Zones reduce,
but do not completely prevent all injuries and deaths). There is always a risk of injury
in a fall!
Solution 5 (Fall Protection Plans and Administrative Controls) is not deemed Positive
Fall Protection, since mistakes can lead to unimpeded falls all the way to the bottom.

Selection of a Solution
The regulators, including US OSHA, do not decree which solution from the Hierarchy should be
used in particular situations, however, the General Duty Clause in the Regulations basically
compels employers to be aware of and follow industry best practices.
Thus, the use of solutions at or near the bottom of the Hierarchy should be avoided
whenever a practical solution that is higher in the Hierarchy is possible.

CASE STUDY 1: THE RACKING BOARD

Although this papers objective is to discuss low elevation fall
protection solutions, it is useful to begin our discussion by
exploring the Hierarchy for dealing with fall protection on the
Racking Board of a Drill Rig. This will help us understand
why Fall Arrest systems are so frequently implemented in
industrial situations.

Figure 4
Racking Board, storing Pipe

As drill pipe is being

connected and drilled into or
pulled from a well hole, it
needs to be stored in its
vertical orientation. The
Racking Board is essentially a
Figure 3
storage rack that steadies the
Typical Racking Board, Rack
vertically stored pipe. A
Fingers folded up beside
worker needs to be on the
guardrails
Racking Board to guide the
pipe into and out of fingered racks (these fold down when
needed, providing a partial platform at the base of the guardrail).
Figure 3 sows the racking fingers folded up, and figure 4 shows
the racking fingers down with some stored pipe.

Hazard Assessment
There is usually, depending on the specific Drill Rig, potential to fall dozens of feet. The walking
surface is narrow with large openings a worker can fall through. The landing area is typically
lower structures of the drill rig, consisting of steel and machinery.
Possible mitigations, following the Hierarchy of Controls:

Elimination: This job cannot be moved to ground level because the Racking must be above
the middle of each length of pipe to balance it from falling over and is normally close to the
top of the pipe. The workers manually steer pipe into and out of the fingers. Robotics is
already playing a role on some of the very large drilling platforms, but is currently too heavy,
expensive and unreliable for land-based rigs. For now, workers must be near the top of the
pipe to manually assist with the racking.

Guarding: The platform is well guarded laterally around its perimeter, when drilling, but
the guarding must be open on one side during pipe standing operations. Because the pipe
passes through the platform, and must be moved laterally from in line with the well centre, to

the racks where it is stored, the floor cannot be closed off (guarded) at the same time that a
worker is manipulating the pipe into and out of the rack.

Travel Restraint: The Width of the platform the worker stands on is too small to be able to
tether a worker from reaching and falling off the open edges.

Fall Arrest: This is the usual solution on the Racking Board. Barely visible in Figure 3, there
is a diagonal sloping line above the stabbing board that anchors two Self Retracting Lifelines.
Worker(s) wear full body harnesses and connect themselves to the SRLs.

Administrative Controls: Because Fall Arrest is feasible, there is no justification to eliminate

Positive Fall Protection, and therefore, a Fall Protection Plan: is not acceptable as the sole
means to reduce the risk.

Thus, following the Hierarchy of Controls for Fall Protection, we have legitimately
concluded that a Fall Arrest system is the best solution.

CASE STUDY 2: (LOW) ROOFS

Workers must work on the tops of the
various buildings that accompany a
Drilling Rig, primarily during set-up and
breakdown of the rig, but occasionally to
deal with maintenance issues during Rig
operations. Buildings include offices,
dorms, and various power plant, pump &
drilling mud storage tanks.
The elevation of the building
roofs is typically low, around 9 to 11
feet (2.75 3.35m), although some
buildings such as the Doghouse may be
higher. This is at or above the elevation
where most jurisdictions require fall
protection to be provided, but as we will
see, this is also an elevation that is very
difficult to protect.

Figure 6
Building Roofs

Hazard Assessment
There is potential to fall approximately ten feet. The tops of the roofs are typically painted steel,
and very slippery when wet or covered with snow and ice. The landing area is typically a gravel
pad placed at the drilling site prior to mobilizing the Rig.
Possible mitigations, following the Hierarchy of Controls:

Elimination: The work cannot be moved to ground level because low height buildings are
infeasible (they waste the available transportation envelope and wouldnt allow users to stand
up inside them).

Guarding: The guardrails would need to be retracted or removed to transport the building.
The exposure time to manually set up and dismantle Guardrailing generally exceeds the
working time on the roof so setting it up may pose a greater risk than working without it.
Automatic Guardrailing systems (including hydraulically actuated) are possible but would be
expensive and subject to ongoing maintenance and repairs.

Travel Restraint: This is the best solution, because it prevents the fall. Discussions below will
expand on important design considerations to make this work.

Fall Arrest: This is often infeasible due to inadequate Clearance, also as discussed below.

Administrative Controls: Because Travel Restraint (or sometimes Fall Arrest) is feasible,
there is no justification to eliminate Positive Fall Protection, and therefore, a Fall
Protection Plan is not acceptable as the sole means to reduce the risk.

Will Horizontal Lifelines Work?

Horizontal lifelines have been installed on the tops of many of Drilling Rig roofs. The intended
use of these systems (Travel Restraint or Fall Arrest), is often poorly understood. Users and those
who select these systems often do not or recognize when these systems will or wont work.
There are three main issues with using
Horizontal Lifelines to protect the tops of low
roofs:
1. HLLs are force multipliers. The cable
tension, applied to the end anchor, is
generally between 2 and 8 times the fall
arresting or travel restraint force applied
(transverse to the cable) by the falling
worker. Generally, the anchor for an HLL
needs to be much stronger than an anchor
used for direct tie-off. Unfortunately many
systems that have been constructed by
well-meaning people do not consider the
multiplier effect. The photo in figure 7
shows a system where the anchor lug is
welded to 1/8 steel roof sheeting, Also,
the cable is greatly weakened by bending
it over the sharp corners of the hole in
the lug, instead of including a thimble to
protect it from cutting.

Figure 7
Weak HLL Anchorage

Fortunately, these days, more

people have an understanding of the
force multiplier effect, and we are seeing
fewer weak systems, but they still exist.
2. For Fall Arrest use of an HLL, the
system must stop the worker from
impacting the ground. Figure 8 shows
Figure 8
Required Clearance for a
Fall Arrest System

how much Clearance is required for a 60 foot long Horizontal Lifeline made of 3/8 cable on
rigid end anchorages. In a single worker fall, we expect the cable to deflect about three feet. It
is common for workers to use a 6 ft long lanyard that includes a Personal Energy Absorber
(PEA) that can deploy approximately 4 or 5 feet. The ANSI Z359.6 and CSA Z259.16
standards require a two foot Clearance Margin. When we add this up, the Clearance from the
anchorage totals 21 to 22 feet. If the building is about 12 feet wide and the HLL is installed in
the middle (6 feet from the edge), Figure 8 shows that the required Clearance is 15 to 16 feet
below the edge of the roof.
Since most of these buildings are around 10 feet high, the lanyard length would have
to reduce to 1 foot or less for Figure 8 to properly stop the fall in the available Clearance.
This is completely impractical for the worker.
Some people believe that if the worker uses an SRL instead of a lanyard, the fall distance will
be shorter. This is not a valid belief because:

The worker will experience similar Free Fall with an SRL as a lanyard when he steps
off the edge of the roof. He does not start pulling the line out of the SRL (to sense the
speed of the fall and then lock), until his Dorsal D-ring (shoulder height) goes past
the edge of the roof, about a five foot Free Fall.

Most small SRLs are not designed or intended to handle this much free fall, and will
generate large impacts that exceed what regulators would allow. In a worst case, the
impact force can sever the line where it deflects over a sharp edge of the building.

Some SRDs include a built-in energy absorber to deal with large free falls, however,
they usually will deploy more than the personal energy absorber (PEA) in a lanyard
for the same Free Fall distance.

In conclusion, low HLLs just wont work to safely arrest a fall on the Drilling Rig buildings.
3. Generally, the definition of travel restraint is that the torso, from the hips to the shoulders,
cannot leave the roof. Moving up the Hierarchy, can we use a travel restraint system to
prevent the workers torso from leaving the roof? Travel restraint forces are lower than
Fall Arrest forces, but it is still probable for
the HLL to deflect at 1 to 1.5 feet.
Figure 9 shows that the absolute
longest lanyard that could be used (on a 12
ft wide roof, with the HLL in the middle)
would be 2 feet. The problem with a lanyard
this short is that a worker connected to the
HLL will have extremely limited mobility,
and probably could not even crawl beside
the HLL.
If we can bend the conventional
Travel Restraint rules a bit, and allow the
hips to get off the roof, there would not be
any appreciable free fall and a worker can
fairly easily be dragged back on the roof

2.5 ft

2 ft 1.5
ft
Lanyard

Figure 9
The lanyard for travel restraint must be
2 feet or shorter.

(eliminating the need for post-fall rescue of

someone hanging in a harness). Figure 10
illustrates the practical limit of travel of the
workers torso towards the edge that could
arguably prevent the torso from leaving the
roof. Unfortunately, this requires a 3 foot
lanyard still does not allow the worker to
stand up on the roof.

1.5 ft

3 ft
Lanyard

1.5
ft

Can We Make Fall Arrest Work?

Lanyard Systems
Raising the anchorage is a common approach to
improving clearance requirements in a Fall Arrest
System. Figure 11, shows that using a six foot
lanyard, the HLL must be anchored 11 feet above
the top of the roof.

Figure 10
The lanyard for travel restraint must be
3 feet or shorter.
3 ft HLL
deflection

We can reduce the required anchor height

in a few ways:
We can replace the horizontal lifeline with a rigid
anchorage system (a rigid rail spanning between
the posts nominally does not deflect. If there is
only one location the worker needs to work at, we
can erect a single post)

6 ft
lanyard

11 ft
Anchor
Height

4 ft PEA
deployment

We can shorten the lanyard. Figure 11illustrates

that we reduce clearance by one foot with each
foot we shorten the lanyard.
Involve a Qualified Fall Protection Engineer to
accurately determine the gains from setting the
post further back from the edge and from
calculating how much the personal energy
absorber (PEA) will really deploy (based on the
worker weight, free fall and the properties of the
PEA). As we shorten the lanyard, we actually
reduce Clearance by more than the amount we
shorten the lanyard, because we reduce the free
fall and thus the energy that the PEA must deploy
to absorb.

6 ft Worker

2 ft Clearance

Figure 11
Required Anchor Height for a Horizontal
Lifeline Above the worker

We can set the post back from the edge of the roof. This reduces clearance requirements
due to the longer diagonal distance from the anchor point to the edge of the roof.

Thus, by eliminating the Horizontal

Lifeline, shortening the Lanyard, setting the
post back from the edge of the roof, and
working with a Qualified Fall Protection
Engineer, we can optimize the system (and
reduce the required height of the anchorage
to as low as four to six feet).
SRL Systems
Unfortunately, workers often kneel down to
do their work. As can be seen in figure 12,
the required Clearance is 8.5 feet below the
roof edge when the anchorage is above the
worker and rigid.
Setting the anchorage back from the
edge, does not improve Clearances when
using SRLs. This is because free falls
increase dramatically as the line between the
worker and the anchorage becomes more
horizontal.

3 ft arrest
distance

2.5 ft

8.5 ft
Required
Clearance
6 ft Worker
2 ft Clearance

Figure 12
Required Anchor Height for a Horizontal
Lifeline Above the worker

Can We Make Travel Restraint Work?

There are some key objectives that we would like (need) to meet:
Keep the anchorage system low to the roof so that we can transport the buildings without
having to dismantle the systems. This saves time and reduces the fall exposures involved
in setting and knocking down the system with each relocation. This also reduces the cost
of the system because low anchors are much less expensive than raised anchors.
Allow the worker to stand up while walking along the roof. While most workers will
accept that they may need to kneel down to reach the edge of the roof when they are
ready to work, they certainly want to be able to stand when walking along the roof to the
work location.
Try to salvage the existing mid-roof HLL Systems to save the cost of replacing them.

SRL Systems
SRLs can only keep a worker from reaching an edge if the maximum length of line on the SRL is
less than or equal to the length of lanyard that would similarly prevent a worker from reaching the
edge. Usually, an SRL has more line than the worker needs. Even if we set the anchorage system
far enough back that we run out of SRL line before the worker reaches the edge, it is less
expensive to purchase a simple fixed length lanyard or lifeline. SRLs are typically not usable for
travel restraint.

Lanyard Systems
Travel restraint requires having the anchorage far
enough from the edge of the roof that the worker
cannot fall off the edge.
If we push the limits of what might be
considered travel restraint, Figure 13 shows that the
required setback equals 1.5 feet plus the lanyard length
plus the Anchorage System (HLL) deflection at Travel
Restraint forces. This allows a worker facing the edge
to reach the edge with his hands.
When the worker stands up, the slope of his
fixed length Lanyard will force him to stand further
from the edge.
Thus for a standard six foot lanyard, and, say, a one
foot maximum deflection of the HLL, the setback must
be 8.5 feet from the edge.

1.5 ft

Lanyard Length

HLL
Deflection

Required Anchor Setback

1.5 ft

Lanyard Length

HLL
Deflection

Required Anchor Setback

Figure 13
Required Anchor Setback to restrain
worker from falling off the roof

Travel Restraint Solutions

Replace the HLL with some sort of rigid rail or
track. The elimination of the HLL deflection means
that a single track down the centre of a 12 foot wide
roof would work if the lanyard was 4 feet long,
as shown in Figure 14.
A 4 ft lanyard will allow a worker to stand up
and walk down the middle of the roof.

1.5 ft 4.5 ft Lanyard

6 ft Anchor
Setback

6 ft Anchor
Setback

Figure 14
Replace HLL with a Rigid Rail.
Use a 4 ft Lanyard.

1. Elevate the HLL so that a short (say 3 foot) lanyard

will restrain the fall without preventing the worker
from standing up. The photograph in Figure 15
illustrates this concept.
2. Use two Horizontal Lifelines, set back 8 ft from
each edge. The worker will use a six foot YLanyard so that he can connect to both HLLs
simultaneously. The Two HLLs will be 5 feet apart
on a 12 ft wide building. If the worker falls or
moves toward the Left edge, the Right HLL will
anchor him, and if falling toward the right edge, the
Left HLL will anchor him. See Figure 16.
3. Because so many buildings already have a single
Horizontal Lifeline down the middle of the roof, it
is very desirable to salvage as many of the existing
systems possible, particularly those that are
robustly constructed (strong enough and with
minimal deflection).

Figure 15
Elevate the HLL so the lanyard
will restrain reaching the hazard
but the worker can still stand up.

8.5 ft Anchor
Setback

8.5 ft Anchor
Setback

Figure 16
Use Two HLLs and Y-Lanyard
For Double Travel Restraint

As we have been discussing, our problem in travel

restraint is that connecting to the Dorsal D-ring of
the Harness cannot prevent the worker from falling
off the edge, unless the lanyard is shorter than 3 feet
long, which will not allow a worker to stand up.
A solution to this problem is to lower the
connection of the lanyard to the hip D-rings on the
Harness. Since there are two D-rings, this requires
using a Y-lanyard. The Y-Lanyard must be reversed
from its usual orientation so the legs connect to both
hip D-rings and the stem of the Lanyard connects to
the HLL. Figure 17 shows two photographs
illustrating how this works. The upper photograph
shows that the worker can stand up and the lower
photograph shows how close the worker is able to
approach the roof edge. Note that the large
Snaphooks of the Y-lanyard in the photograph are
not deemed compatible with the Harness hip Drings, so purchasing specifications should request a
3 foot Y-Lanyard with regular Snaphooks on all
three ends.

Figure 17
Use a 3 ft Y-Lanyard connected to
the Hip D-rings

Warnings: There are a some of critical considerations when using hip connection to the
harness for travel restraint:

Ensure there is no possibility that a worker can reach and fall off the edge of the roof.
If a worker were to fall, it is dangerous to put fall arrest impact into the workers
hips. This means that the HLL sag must be controlled and compatible with the length
of Y-Lanyard that is being used so that a fall is impossible.

Select a model of harness that can resist a backward pull on the D-rings. The design
of some harnesses does not consider the possibility of a backwards pull. Hip D-rings
are typically tested for a frontward and upward pull only (for a worker facing the
ladder, pole or other structure, using a positioning lanyard or strap connected to both
D-rings, wrapped around the structure. This
allows the worker to lean back and work with
his/her hands. If there is a short fall, the impact on
the hips is upwards, and not across the body.

CASE STUDY 3 Pipe Staging Catwalk

Figure 18 shows a Drill Rig with a 54 foot long lateral
Catwalk that is used to stage horizontal pipe before standing it
vertically. The platform is slightly more than six feet above
the ground, so in some jurisdictions (primarily the United
States), Fall Protection is required any time workers are on the
Catwalk.

Figure 18
Yellow Line Shows proposed
Horizontal Lifeline above the
Catwalk

Figure 19 shows a close-up of the Catwalk which is open in

the middle for the (yellow) hydraulic mechanisms that stand
the pipe. These mechanisms are raised above the platform
during daily inspections and maintenance, so personnel
performing this work, standing on the platform, are exposed
to falls greater just over six feet, either between the platform
and the mechanisms or to the outside.

Hazard Assessment
Figure 19
There is potential of falling six feet or more. The landing area
Pipe Standing Mechanism in the
varies from gravel or soft ground to the outside of the
middle of the platform.
platform to steel bracing and machinery on the inside of the
platform. Workers service the mechanisms once per day, and
must lean over the opening in the Catwalk to reach the points that they are servicing.

Possible mitigations, following the Hierarchy of Controls include:

Elimination: It is theoretically possible to modify the platform height, lowering the platform
slightly below the threshold height of six feet where Fall Protection is legally required. This
however, would not appreciably improve the safety, would require a redesign of the Rig.
Guarding: Since the platform is open in the middle, there are four edges that a worker could
fall from, so there would need to be four runs of Guardrailing. When the Drilling Rig is
operating, pipe is lifted onto and rolled across the catwalk to and from the (yellow) hydraulic
mechanisms. Guardrails will need to be retracted or removed most of the time the Rig is
operating. The exposure time to manually set up and dismantle Guardrailing would be
significant and would exceed the time servicing the pipe standing mechanisms. Installing and
dismantling it for each days maintenance would likely be a greater exposure to falls than
working without fall protection. Hydraulically actuated Guardrailing schemes are possible but
would be very expensive to implement, add significant weight to the drilling rig, and would
also be subject to ongoing maintenance and repairs.
Travel Restraint: As can be seen in figure 19, the twin platforms are too narrow to create a
travel restraint system. Travel restraint is also infeasible because the hydraulic equipment
being maintained is actually outside the edges of the platform.
Fall Arrest: With the platform at an elevation of approximately six feet, we are at the
minimum elevation where any Fall Arrest System can practically work. SRLs anchored to a
rigid system above the worker generally require six feet of Clearance below the platform
(including the mandatory two foot Clearance Margin). If the worker has to kneel, the required
Clearance increases to 8.5 feet, as discussed above. The probability of a kneeling worker
falling off a platform is considered much lower than the probability of a standing worker
falling, so fall arrest protection is primarily needed by a worker who is standing.
Because of the difficulty of stopping falls so close to the ground, the CSA Z259.16
engineering standard for the design of active fall protection systems is exploring an
ammendment that will permit the engineer to reduce or even eliminate the two foot Clearance
Margin in situations where it is not possible to stop the fall within the available Clearances.
If the Qualified Fall Protection Engineer determines there is not enough Clearance to
maintain a two foot Clearance Margin, the new rules would require verification that the
impact speed upon reaching the lower level or obstruction is not greater than if the worker
had fallen from the threshold height where fall protection is legally required. The Engineer
must also warn users by stating on the drawings the circumstances where they may hit the

ground and at what speed or equivalent free fall height.

The reasoning behind this proposed change is:
o The regulators have set a legal threshold, below which fall protection is not required. This
implies that the impact energies (and resulting injuries) from falls just below this legal
limit are acceptable to the regulators.
o In a legal fall from just below the threshold height, there is nothing to control which part
of the body that reaches the ground first. Statistics released by Safe Work Australia in
2013 reveal that 50% of all fall fatalities occur from elevations of 10 feet or less, and that
75% of all fall fatalities inovle fatal head injuries. If the the Fall Arrest System has begun
to arrest the fall at the time of impact, the workers body will be oriented so that the
impact with the ground will always be feet-first. Injuries that may result will be to the
lower extremities of the body, and are much less likely to be life threatening, so it is safer
to use a fall arrest system when there is inadequate Clearance than to work without it.
o The calculations performed by the Engineer are based on conservative assumptions about
the maximum worker weight and other factors. In many cases, workers who are lighter
than the maximum weight the system is designed for will generate less fall energy and
will will not reach the ground.
The ANSI Z359.6 technical committee in the US has not yet considered the change
proposed for CSA Z259.16, but is currently well harmonized with the CSA standard. It is
possible that it too may adopt the proposed CSA rule change in the coming years. In the
meantime, US based Qualified Fall Protection Engineers should clearly state on their
drawings when the system does not maintain the required two foot Clearance Margin, and
should consider defining the limitations (such as maximum worker weight) where the system
will, in-fact, prevent the worker form impacting the ground.

Administrative Controls: It is very difficult to provide fall protection in this scenario,

however, partial fall protection is still safer than no fall protection, and due diligence does not
allow us to use a written fall protection plan instead of some form of positive protection.

Suitability of a Horizontal Lifeline

The client had originally proposed a commercial Horizontal Lifeline (HLL) elevated 3 feet above
the Catwalk deck (See the yellow line in figure 18). One end of the HLL was to be anchored to
the vertical mast of the Drilling Rig, and the other end was to be anchored to a Post that swung up
at the end of the Catwalk. The workers were to use four foot lanyard. Calculations showed that
the selected Horizontal Lifeline, spanning 54 feet, would sag at least 9.5 feet to arrest the fall of a
single 310 lb. worker. When the lanyard length, Personal Energy Absorber deployment, Length
of Worker and Clearance Margin are added to this, the required Clearance below the platform
calculates to be 20.25 feet.
Better Horizontal Lifelines that do not sag as much can be engineered, spans can be
shortened by putting in intermediate supports, and the Horizontal Lifeline can be raised above the
worker so that a Self-Retracting Lifeline can reduce the free fall and deceleration distance.
However, it is still impossible to reduce the sag to zero as would be required to make an SRL
system stop the fall within six feet for a standing worker, and it still would not be adequate for a
kneeling worker.
Another aspect of Horizontal Lifelines is the trade-off between cable sag and its tension.

The only way to reduce sag is to increase the tension. Zero sag mathematically requires infinite
tension and infinitely strong end anchors.
Clearly, a horizontal lifeline to protect work on the Catwalk is completely infeasible.

Other Fall Arrest Solutions:

1. Construct a non-deflecting anchorage system above the workers head so that an SRL can
be used to stop the fall within six feet and still maintain the required two foot Clearance
Margin. As mentioned above, a worker falling form a kneeling position (a very probable
work position) requires 8.5 feet of Clearance below the catwalk platform.
This would require a rigid rail mounted at least eight feet above the catwalk deck. This
would add to the weight of the rig and would have to be carefully engineered to be out of
the way of the pipe handling and standing operations, probably requiring it to be
hydrualically actuated, adding to the expense and maintenance.
2. Engineer a dual SRL system! ,In the
experience of the authors of this
paper, this innovation has not been
tried before. The remainder of this
paper will discuss our investigation of
this approach.

Dual SRL Fall Arrest System

This idea developed while evaluating the
behaviour of a proposed fall arrest system that
connected the worker to a single SRL mounted
to the top of the drilling mast.
The top of the Mast can be considered
a rigid anchorage, so if a STANDING worker
fell from the end of the platform adjacent to
the mast, the fall would be vertical, and would
be arrested within the available six foot
Clearance (including a two foot Clearance
Margin). Figure 20 illustrates that if the
worker fell from the other end of the platform,
once the SRL locked off, gravity would begin
to swing the worker underneath the anchorage
(toward the mast).
Swing falls are extremely dangerous because:

Figure 20
Use of a single SRL mounted at the top of the
Mast will cause severe swing falls if the worker
gets too far from horizontally from the Mast

The horizontal velocites can be high! Sidways impact energies are created by the elevation
drop (Swing Drop Distance) from where the worker begins to swing to where the worker
impacts the structure.
In a swing fall impact, the forces are ALWAYS applied perpendicular to the spine, a
direction where the body has reduced capacity to absorb the energy (by contrast, in a vertical
fall arrest, the harness directs the impact into the workers hips and verticaly up the spine).

There are no energy absorbers to dissipate swing fall energy. In a vertical fall arrest, the PEA
can deploy. In a Swing Fall, the only energy absorber is the workers body, so injuries can be
severe.
The elevation drop experienced by the worker must be added to the required Clearance.

The ANSI Z359.6 and CSA Z259.16 standards for the design of active fall protection
systems limit the Swing Drop Distance (the drop in elevation from where the worker begins to
swing to the elevation where he impacts a structure sideways) to 4 feet or less.

Figure 21 is a chart illustrating the

relationshipbe between the Swing Fall
Distance and the horizontal distance of the
worker from the Rig mast at the start of
the swing, based on the Upper SRL being
anchored 75 feet above the catwalk.
If the worker is within 10 feet of
the mast, the swing fall is negligible.

Vertical Swing Fall Distance

This limitation was not set due to Clearance considerations AND it certainly does not
eliminate all injuries. Four feet was selected as a reasonable level of energy for the human body
to deal with in a swing impact.

Between 10 and 20 feet from the

mast, the swing fall is still within the four
foot maximum Swing Drop distance
discussed above, however, we just dont
have the Clearance to deal with even four
feet of swing drop.

20 ft
15 ft
10 ft
5 ft
0 ft

0 ft

10 ft
20 ft
30 ft
40 ft
Horizontal Distance from the Mast

Figure 21
Swing Drop Distance vs
Horizontal Distance from the Mast

Add a Second SRL to Stop the Swing

It was proposed to investigate the possibility of
installing a second SRL on a post at the end of
the platform farthest from the Rig Mast, to see if
it could control the swinging motion. If this
concept worked, it would reduce both the
potential for swing injuries, and the additonal
Clearance required due to swings.
Figures 22 illustrate the concept of using
one SRL at the top of the Mast to arrest the
vertical fall and one SRL at the far end of the
Catwalk to arrest the swing.
A (commonly available) 1 foot long
harness extension was selected to connect the
worker to the Snaphooks of both SRLs, as
shown in the enlarged view in Figure 22. This
keep the two Snaphooks at a common point
above the workers head and provides a single
attachment point to the workers harness.

Figure 22
Swing Drop Distance vs
Horizontal Distance from the Mast

50 ft

There may be some safety people who would have concerns about two Snaphooks being
connected into the same D-ring at the top end of the harness extension. While it would be
possible to construct a harness extension with two D-rings, a hazard evaluation of this dual
connection concluded:
The risk of interference between the Snaphooks is greatest if one or both Snaphooks are
loose. The tension in both SRL cables will keep the Snaphooks seperated on opposite
sides of the D-ring so there is no risk of interaction;
the modern use of 3600 lb locking gates has greatly reduced the possibility of a forced
rollout.
It was therefore deemed acceptable to use the common harness extension. Those who have
concerns about the dual connection certainly have the option of fabricating a custom harness
extension that provides two separate D-rings.

Computer Modelling
The novelty of having two SRLs connected to one worker certainly needed field testing to prove
whether the system would behave as we hoped. Before purchasing the SRLs and conducting tests,
however, we evaluated the concept using computer models. The calculations were done using
energy analysis wherein the fall energy developed by the worker is distributed into the various
energy absorbing components of the system (in this case, the two SRLs).
Skilled computer modelling can often predict behaviours that may not otherwise be
forseen, and may show why a concept wont work before going to the high expense of doing
testing. Even when the concept is expected to work, computer modelling greatly reduces the
number of tests required to get an accurate understanding of the behaviour of the system.
Computer modelling will predict some problems that can be addressed by re-design before
beginning the testing.
Accurate computer modelling requires a detailed understanding of how the equipment (in
this case, the SRLs) is going to behave. Obtaining detailed information from manufacturer s is
difficult, so we based the intial assumed performance on our experience with several SRLs.
The following properties of the SRLs were assumed by the initial computer model:
Lock-off speed of the SRL: Large SRLs often have lock-off speeds that vary from about
3 to 10 ft/s, depending on the amount of cable that is on the drum of the SRL. The lockoff mechanism generally senses the speed of the drum rotation, so when the SRL is fully
retracted, each rotation of the drum pays out more cable than when the drum is nearly
empty. The computer model included an algorithm that predicted the lock-off speeds
according to the length of line out of the SRL (controlled by the position of the worker
along the catwalk).

 Average Braking Force: The braking force of an SRL critically controls the distance
required to stop the fall. The higher the force, the less deceleration distance and
Clearance is required. A number of models of SRLs were evaluated to see what braking
forces might be available. Most models were labeled as keeping the peak impact force
lower than 900 lbs, however we did find one product that labeled as keeping the impact
force lower than 1350 lbs that was rated for a maximum 420 lb user. This product was
presumed and hoped to have a braking force
80 ft
that would be 50% higher than for the other
70 ft
models we evaluated.
60 ft

The ANSI Z359.6 and CSA Z259.16

standards direct engineers, in the absence of better
information, to assume the SRL deploys at 65% of
the peak impact force. This would suggest that the
average deployment force would be around 880 lb
(3.9 kN).

50 ft
40 ft
30 ft
20 ft
10 ft

Figure 23 shows a plot of the predicted intial

(blue) and final (red) positions of the Dual SRL
cables for a 310 lb (140 kg) worker falling from a
standing postion while attached to the system at 15
feet and 45 feet from the mast. The purple line traces
the path of the fall, initially vertical until the higher
SRL locks, and then swinging towards the mast until
the low SRL at the end of the platform locks.
Figure 24 is a plot of the total vertical and
horizontal distances that the computer model
predicted that a standing worker would fall and
swing, according to the position along the catwalk.
It is interesting to note that:
The total vertical fall calculated to just over one
foot when the worker is next to the mast, and
is just over three feet when the worker is at the
far end of the catwalk. With the harness
stretch (1 foot) and the Clearance Margin (2
ft), the vertical Clearance required for a
standing worker ranges from just over 4 to just
over six feet depending on the workers
location along the catwalk. A kneeling worker
would require 6.5 to 8.5 feet.

0 ft

0 ft

10 ft

20 ft

30 ft

40 ft

50 ft

60 ft

0 ft

10 ft

20 ft

30 ft

40 ft

50 ft

60 ft

80 ft
70 ft
60 ft
50 ft
40 ft
30 ft
20 ft
10 ft
0 ft

Figure 23
Computer Model Showing
Initial (blue) and Final (red) SRL Cables
and Path of the Fall (Purple)

Total Vertical or Horizontal Travel

Usually a torsional clutch is used for the

braking mechanism, so (like the lock-off speed), the
braking force is determined by the amount of cable
on the drum. The clutching force in the computer
model were assumed to linearly vary from 700 lb
with all cable on the drum to 1060 lb with all of the
cable pulled off the drum.

4.0 ft
3.5 ft
3.0 ft
2.5 ft
2.0 ft
1.5 ft
1.0 ft
0.5 ft
0.0 ft
0 ft

10 ft 20 ft 30 ft 40 ft 50 ft
Horizontal Distance from the Mast

Figure 24
Computer Model Showing
Total Horizontal Swing (green)
and Vertical Fall Distance (red)

 horizontal movement calculated to be greatest (more than three feet) when the worker is
next to the mast and when the worker is out at the end of the catwalk.
The computer model predicted that the proposed system could stop the fall and still
maintain a two foot Clearance Margin for a standing worker anywhere on the platform, but that a
kneeling worker may not quite have enough Clearance.
It was decided that the dual SRL option was worth exploring further by doing testing:
1. The performance of this option (in terms of stopping the fall within the available six feet of
Clearance) appeared to actually meet and in most cases exceed the performance of the
overhead rigid rail option, without the expense and difficulty of engineering a rigid rail
system onto the existing drilling rig.
2. As discussed above, the CSA Z259.16 standard was being ammended so that systems where
available Clearance is extremely limited can be used even if the worker may hit the ground.
The caveat is that impact energy must be less than would have occurred if the worker fell
from the threshold height where fall protection is legally required.
In this case, the platform is essentially at the threshold height where fall protection is legally
required, so if the fall arrest system dissipates any fall energy at all (which it does) impact
energies will be reduced below the energy from falling from the threshold height.
3. Only the kneeling worker might not have enough Clearance.
4. The probability of a kneeling worker falling off the catwalk is much lower and less serious
than for a standing worker.
5. It can be argued that less than the two foot Clearance Margin may still be safe.
It was therefore decided that the dual SRL design had a good
chance of success, so the selected SRLs were purchased to test
whether the system behaved in accordance with the computer
model.

Testing
The two selected SRLs were purchased, and the anchors for the
SRLs on Rig Mast and at the end of the Catwalk were designed and
installed. Testing was conducted on the Drill Rig on July 6, 2012.
All tests dropped a 310 lb rigid test mass (as specified by the CSA
Z259.16 standard).
Figure 25 shows test #2 with the test mass located 34 feet
horizontally from the rig mast. There was a total vertical fall
distance of 71 inches and a horizontal swing displacement of 12.5
inches in this test.
Total
Distance Vertical Horizontal
Test from Rig
Swing
Fall
No.
Mast
Distance Distance
1
N/A
>66 in
N/A
2
34.0 ft 71
in 12 1/2 in
3
34.3 ft 64 5/8 in 15 3/4 in
4
22.7 ft 60 1/4 in
6
in
5
23.1 ft 40 1/8 in 10 1/4 in
6
22.5 ft 50 1/2 in
5 5/8 in
7
46.5 ft
> 78 in
40 1/4 in
8
44.0 ft
> 90 in
44 1/2 in

Peak
Force
N/A
450 lb
545 lb
490 lb
N/A
495 lb
610 lb
440 lb

Figure 26
tabulates the test
results.
Comments
Impacted Deck

Load cell not on

Impacted Deck
Impacted Deck

Figure 26
Tabulation of the results of Test 1 to 8

Overall,
the results were
very
disappointing.
The first test

Figure 25
Test #2: 71 inch total
vertical fall and 12.5 inch
horizontal swing

impacted the catwalk deck, greatly exceeding the expected Total Fall Distance. The test weight
was dropped from higher elevations on all subsequent tests, however, Tests 7 & 8 also saw the
test weight impacting the deck, with total vertical fall distances before impact of 6 to 7 feet.
Figure 27 plots the test results against the predictions from the computer model. The Total
Vertical Fall Distances (in red) were more than double the predictions. The Horizontal Swing
Distances were significantly less than the predictions, except when the mass was dropped near the
end of the catwalk where they were slightly greater.
What went wrong?

Total Vertical Fall

Distance (from
Computer Model)

8.0 ft
7.0 ft
6.0 ft

Total Vertical Fall

Distance (from Tests)

5.0 ft
4.0 ft

Horizontal Swing
Distance (from
Computer Model)

3.0 ft
2.0 ft

Horizontal Swing
Distance (from Tests)

1.0 ft
0.0 ft

The peak forces of the impacts were measured on all tests. It was
startling to see that SRLs labeled as having a peak impact of 1350
lbs, gave measured impacts that were between 33% and 45% of
this value. The assumption that the average braking force would
vary from 700 to 1060 lbs was clearly wrong. The fact that the
upper SRL would have had more than 70 ft of its line extracted
meant that the computer model was predicting an average braking
force close to 900 lbs so the peak force measurements should have
been closer to 1200 lbs.

The 130 foot SRL was removed from the Drilling Rig and
was subsequently tested in a static test to determine the braking
forces. Various lengths of cable were pulled out of the device
Figure 27
before locking it off. Then we measured the force as we pulled two
Comparison of test results to computer model
inches of cable from the locked device. The load cell was set to
measure the peak force recorded during the
additional two inches of extraction, after which the
Deployment Force vs. Cable Length
residual force that the device was holding was
600
recorded.
550
10 ft

20 ft

30 ft

40 ft

50 ft

Horizontal Distance from the Mast

Deployment Force (lb)

0 ft

Figure 28 shows a plot of the peak and

residual forces for various lengths of cable pulled
from the 130 ft SRL.

Peak Force Measued over

2 Inches of Deployment

500
450

Residual Force after 2'' of

Deplooyment

400
350
0.0

50.0

150.0

100.0

Cable Length Pulled from the SRL Housing

Least Squares Fit of

Residual Data

Although dynamic braking forces may be

somewhat different than the static test values, it was
Figure 28 Static Testing of Braking Force of the 130 foot SRL
clear that the SRL braking forces were very low.
Because the SRL is rated to arrest the fall of a 420
lb worker, the fact that some of the readings were lower than the weight of the worker implied
that the worker would accelerate instead of
Vertical and Horizontal Movement to
slowing down when the braking force was
Arrest the Fall
this low!
The plot in figure 28 was used to
estimate the braking force that should be used
in the computer model. A least squares fit
(the green line in Figure 28) of the residual
braking forces (the yellow line in figure 28)

Total Vertical or Horizontal Travel

Total Vertical or Horizontal Travel

Vertical and Horizontal Movement to Arrest the Fall

8.0 ft

Total Vertical Fall

Distance (from
Computer Model)

7.0 ft
6.0 ft

Total Vertical Fall

Distance (from Tests)

5.0 ft
4.0 ft
3.0 ft

Horizontal Swing
Distance (from
Computer Model)

2.0 ft
1.0 ft
0.0 ft
0 ft

10 ft

20 ft

30 ft

40 ft

50 ft

Horizontal Swing
Distance (from Tests)

Horizontal Distance from the Mast

Figure 29
Comparison of test results to
revised computer model

was used to estimate average braking forces to vary from 390 lbs to 550 lbs.
We also tested the braking speed of the SRLs, and concluded that the braking speed varied
from approximately 9.5 ft.s with all cable on the drum to 6.0 ft/s when all the cable had been
deployed. This allowed greater free fall than we had predicted in our original computer model.
Figure 29 shows the results of modifying the computer model to use the data from our
static braking force and and our braking speed tests. It can be seen that the curve has shifted
dramatically towards the test data, but that the predicted vertical fall distances are still a a little
less than the test results. The horizontal swings are all well below the swings predicted by the
computer model, however our computer model was based on sequencing a vertical fall and
deceleration on the upper SRL before initiating the swing. In reality, the swing should intiate
during the braking from the upper SRL, so our swing calculations are likely too conservative.
The manufacturer was contacted to discuss the results of our tests. There was agreement
that something might be wrong with the SRLs and the representatie stated that the peak braking
forces we had measured seemed a bit too low.
The SRLs were shipped to the manufacturer, who investigated and reported that the
clutches were not set to the factory specified torque. He adjusted the devices to factory
specifications (which were 30% higher than what we had measured) and shipped them back. Our
request to increase the braking force closer to what we desired was denied.
Unfortunately, by the time the SRLs came back from the manufacturer, the Drill Rig had
been shipped to the purchaser, so there was no opportunity to do followup tests. We did however,
need to complete the engineering on this project. We adjusted the SRLs braking forces in our
computer model to vary from 510 to 730 lbs.
Completion of the design:
Figure 30 shows the final clearnce charts published in the Fall Protection Plan and on the
drawings developed for our client. Note that we also stated that a kneeling worker would require
2.5 feet (0.75m) greater Clearance than shown in these charts.
Required Clearance Below Platform

Required Clearance Below Platform

140 kg worker

2.5

91 kg worker

<0.6m Clearance Margin

2

1.5

Adequate Clearance
0.0

5.0
10.0
Distance from Rig Mast (m)

15.0

Required Clearance Below Platform (ft)

Required Clearance Below Platform (m)

9.0

Will Impact the Ground

310 lb worker

8.5

Will Impact the Ground

200 lb worker

8.0
7.5

<2 ft Clearance Margin

7.0
6.5
6.0
5.5
5.0

Adequate Clearance
0

10

20
30
40
Distance from Rig Mast (ft)

Figure 30
Final Clearance Charts provided with the system

50

The Clearance charts shown in Figure 30 dealt with the Clearance issues in the following ways:
We provided curves for both 310 lb workers (per ANSI Z359.6 and CSA Z259.16) but
showed the reduced Clearances for a worker who weighs 200 lbs. Other weights can be
interpolated between these curves, allowing the employer to select specific workers to do
the maintenance from the catwalk to maintain the 2 foot Clearance Margin.
The 2 ft Clearance Margin is shown as a yellow band, so the employer and worker know
whether the fall is expected to be stopped before the worker strikes the ground, and when
the final elevation of the feet will be less than typical two feet Clearance Margin above
the ground.
The red band indicates the zone where the worker may (lightly) impact the ground. This is
only for falls of a 310 lb worker at the very end of the catwalk.
In the procedures, workers were instructed to mount and exit the catwalk from the stairs
next to the Rig mast, leaving little reason for a worker to be at the far end of the catwalk
where it might be possible to reach the ground in a fall.

Improvements in SRL Technology

The authors of this paper believe that SRL technology is going to improve, and that braking
forces will be increasing in the next few years. In Canada this is being driven by the recently
published CSA Z259.2.2-14 standard, that now requires SRLs to have an average braking force
that is at least 1.8 times the maximum worker weight the device is labeled to be used with. The
minimum average force for a device certified for use by a 420 lb worker will be 756 lbs. The
deceleration ratios must also be marked on the housing of these devices, hopefully compelling
manufacturers to compete with each other to stop falls sooner, hopefully driving the average
braking forces even higher.

Conclusions
1. Low Clearance fall arrest systems are very difficult to engineer. Guardrails or
Travel restraint are always the desired solution. When Fall Arrest is the only
viable option, it must be carefully engineered by a Qualified Fall Protection
Engineer.
2. For the tops of mobile buildings that are nominally 10 feet (3m) high, there is not
enough Clearance for a fall arrest system to work.
3. On the tops of mobile buildings that are low and narrow enough to transport
down public highways, a single low HLL down the middle of the roof cannot
provide a travel restraint system that will prevent a worker from falling off the
roof (unless the system is engineered for the worker to use dual hip attachment so a lanyard short enough to prevent the fall will still allow the worker to stand
while traversing the roof).
4. For situations where there are low Clearances, particularly at heights such as six
feet where some jurisdictions make fall protection mandatory, deflecting
anchorage systems such as horizontal lifelines will not stop the fall within the
available Clearances. The fall arrest option requires a non-deflecting anchorage
system such as a rigid rail.
5. For situations where there are low Clearances above a horizontal platform where
a high anchorage is available, the authors have shown that it may be feasible to
use a dual SRL system, with one SRL mounted on the high anchorage and the

other SRL mounted near the end of the platform. With current SRL technology,
this approach is likely practical for platform elevations greater than 8 feet (2.4
meters) for standing workers and 10.5 feet (3.2m) for kneeling workers. If
following some of the new design rules and philosophies that allow workers to
impact the ground at low fall energies, this system can be marginally acceptable
for platform elevations as low as six feet (1.8m).
The use of the dual SRL system must be carefully engineered by a Qualified Fall
Protection Engineer. Performance of these systems varies dramatically according to the
REAL properties of the SRLs that are specified, the elevations of the SRL anchorages, the
length of the platform, and the weight of the workers.
It is expected that better performing SRLs will soon be available, providing higher braking
forces that will dramatically improve the performance of Dual SRL systems.

Bibliography
ANSI Z359.1-2007, Safety Requirements for Personal Fall Arrest Systems, Subsystems and
Components, American Society of Safety Engineers, 2007
ANSI Z359.6-2009, Specifications and Design Requirements for Active Fall Protection
Systems, American Society of Safety Engineers, 2009
CSA Z259.2.2-14, Self Retracting Devices, Canadian Standards Association, 2014
CSA Z259.16-04, Design of Active Fall Protection Systems, Canadian Standards Association,
2004
CFR 1910.66 Appendix C, United States Occupational Safety and Health Administration
CFR 1926.502(d) (16), United States Occupational Safety and Health Administration
Small, Greg, Clearance Calculations Made Easy, Proceedings of Safety 2013, ASSE Annual
Conference, Las Vegas, NV, 2013
________. Design considerations for Travel Restraint Horizontal Lifelines, Proceedings of ISFP
Conference, Las Vegas, NV, 2013
Work-related injuries and fatalities involving a fall from height, Safe Work Australia, October
2013, ISBN [PDF] 978-1-74361-187-6 [DOCX] 978-1-74361-188-3