I’m Greg Small, the Professional Engineer retained to oversee and conduct quality control, testing analysis, and certifications on the Ballantyne Gear fall‑protection system, the Eveook System. I am writing this letter of recommendation for the Ballantyne Gear Eveook Fall Protection System.
1. I received a Civil Engineering degree in 1979 from The University of British Columbia in Vancouver, BC, Canada, and a Master’s Degree in Structural Engineering from the University of Alberta in Edmonton, Alberta, Canada.
2. I am a licensed Professional Engineer in Canada (AB) and the United States (AZ).
3. I chaired the development of the CSA (Canadian Standards Association) Z259.16 standard in Canada, which was adopted in the United States as ANSI (American National Standards Institute) Z359.6 for the design of Active Fall Protection Systems.
4. I have trained more than 1,000 engineers in the engineering techniques I developed for the analysis of Active Fall Protection Systems.
5. I am the founder of Elevated Insight and founded High Engineering Corp in 2005, which was sold to Parsons Engineering in 2016. Prior to that, I was employed as Vice President of Engineering at Gravitec Systems from 1996 to 2003. From 1979 to 1996 I worked as a Railway Bridge Engineer where I first was required to develop engineering techniques to protect bridge workers from falls.
6. My Curriculum Vitae indicating additional information on my background and professional qualifications and experience is available on request.
7. I first met Flent Ballantyne, the founder of Ballantyne Gear, at the ANSI Z359 Fall Protection meeting in 2011, where he attended the Z359.18 standard on anchorage connectors I was chairing at that time.
8. Ballantyne Gear retained me as a Professional Engineer to provide engineering support for further enhancements to the Ballantyne Gear fall‑protection system, to oversee quality control, testing, and certifications. I will refer to the Ballantyne Gear fall‑protection system, as it was when I first started working with them, as the “Original System” and the current system as the “Current System.”
9. Two of the safety enhancements we were seeking included protecting the installer and avoiding dangerous swing falls. With the Original System, the installer was required to be on the roof, without fall protection. At that time, being on the roof unprotected during installation was standard practice and not prohibited by OSHA. Ballantyne Gear and I were determined to develop methods to protect persons installing and using the system from both risks.
10. Classic anchorage systems for roof fall protection generally involve one or more fixed anchorage locations to be mounted on the roof. Roofing activities often require workers to move over most of the roof surface. Often, they are not adjacent to the anchorages that their personal fall protection must be connected to. Their level of safety decreases as they get further from their anchorages. If they fall, gravity always pulls and/or swings them to the lowest possible elevation, which will be controlled by the length of their connection to the anchorage and the location of the anchorage. When they have long anchor lines, these systems often allow serious injuries from impacting the ground or swinging into obstructions. The photograph in Figure 1, below, illustrates a classic fall‑protection scenario for a residential roofer who is working a long distance from his anchorage, who is not adjusting the line connecting him to his anchorage. If he falls, he has so much rope that he will impact the ground and/or swing into something at a speed that could cause serious injuries.
Classic fall protection is ineffective when the worker is too far from the anchorage.
The worker needs to move side to side on this roof. Even if properly trained and supervised, he still needs a lot more anchorages to do this work safely. This will increase the cost of anchorages, the number of damaging penetrations into the roof structure, and will slow the work down as the worker needs to transfer to different anchorages as he moves along the roof.
The Current Eveook System, shown below, does not require any penetrations of the roof and causes only minimal cosmetic damage to the roof in the very rare event that a fall occurs. It allows the anchor point (the rope grab/fall arrester that attaches the lifeline to the Eveook anchor line that is crossing the roof) to lock onto the anchor line anywhere between the two Eveooks. The anchor line of the Eveook System can be installed in any direction across the roof, provided the tensioned anchor line stays perpendicular to the edges of the roof. Figures 2 and 3 show photographs of the Current System.
The length of the worker’s lifeline, connecting him to the Eveook anchor line, gives a larger protected working area. The length of the lifeline can be restricted such that the user can reach, but not fall, from the roof edge.
The user can easily slide and relock his connection of the lifeline to the anchor line, such that the user can often maintain travel restraint for the full length of a building without detaching his or her lifeline from the anchor line, making it impossible to fall off the roof (the worker is protected by travel restraint, which is safer than fall arrest and does not require a rescue plan). A six‑foot lifeline (lanyard) connecting a worker to the anchor line between Eveooks creates a safe working zone that is up to approximately 12 feet wide along the entire length of the anchor line. Roof work can be organized to sequentially move the 12‑foot working zone as many times as needed to protect access to the entire roof surface. Shown in the images above are adjustable lifelines that can span from one to thirty feet, allowing a safe working zone that is up to approximately 60 feet wide at any point along the entire length of the anchor line.
11. Workers tend to want as wide a working zone as possible (as illustrated in Figure 1). Unfortunately, with classic fall protection, this increases the probability of sustaining a fall off the roof and increases the potential magnitude of a swing fall. Ballantyne Gear has developed robust Eveook System layouts, procedures, and training to minimize the number of required relocations of the Eveook anchor line and the need to remove and reattach the worker’s lifeline every time they move to a new work zone, which has greatly reduced the possibility of falls, including swing falls, while increasing the safety and efficiency of the system.
12. Significant work has gone into addressing the challenges faced in evolving to the Current Eveook System. Ballantyne Gear and I have conducted extensive and expensive research and development, computer modelling, and confirmation testing to prove the viability and safety of the new Eveook System, including:
a. Travel restraint on sloped roofs, such that a fall cannot occur, using a synthetic horizontal anchor‑line rope, which has proven to be very reliable. These synthetic ropes are far more functional than less‑expensive but more conventional straps, since they can support a fall arrester, whereas the straps only support free‑sliding connectors, such as a carabiner.
b. The stretch (and sag) properties of the Eveook anchor line and the user’s adjustable lifeline have been improved through a selection of stronger and stiffer synthetic ropes that exhibit much less stretch and behave in a more linear fashion, reducing fall‑clearance requirements and creating a system that is strong enough to protect up to eight users on one system (generally four users on each side of the primary ridge).
c. Finding a fall arrester that also works as a rope grab and includes a built‑in 1,300‑pound energy absorber, improving safety and efficiency. This fall arrester can be used for fall arrest, fall restraint, and positioning. Because of the 1,300‑pound energy absorption, it reduces the fall‑clearance requirement compared to the clearance requirement of the more standard 600‑pound energy absorber.
d. Developing a more reliable understanding and prediction of the variability of the frictional forces and development of suitable friction factors to absorb some of the energy of a fall. This understanding was a result of the hundreds of friction tests that we made with multiple rope sizes and materials, multiple roofing materials, and multiple roof pitches.
e. Learning how the deflection of the anchor line over “significant ridges,” such as might be provided by dormers, a roof peak, or other transverse features, allows them to act as pseudo‑intermediate supports to the main anchor line, reducing the sags and clearance requirements.
f. Development of a new body for the Eveook anchors that is stiffer and stronger than the original.
g. Determining, through testing, the forces that an eave anchor must exert on a roof before the roof might sustain damage, and confirming that these forces are well beyond what would occur in a typical fall. We have also proven that both the eave anchor and the roof have a very robust factor of safety and that a roof can absorb significant energy, if required, to resist some kind of major abuse of the Eveook System.
h. Development of a highly complex computer model that goes well beyond the industry norms of horizontal lifeline analysis to predict the behavior of the anchor line in the Current Eveook System. It incorporates the research and development listed in a‑g above to confirm that the Current Eveook System safely protects workers on roofs and other applicable at‑height locations.
While I was engaged in the engineering work listed above, Ballantyne Gear researched and developed practical options for installing the entire Eveook System while maintaining three points of contact with a portable ladder. The following YouTube video link confirms how the installer is protected from falls since the fall‑protection system can be installed before anyone sets foot on the roof and how the person installing the second Eveook, from a ladder, uses fall protection provided by the first Eveook. On some low‑height roofs, the system can be completely installed without anyone being on a ladder without fall protection. https://youtu.be/rqm-lTlfL-0?si=ekz0pBZoJkk2aKT3
As a result of testing at an independent ISO 17025 lab, onsite testing, and the work described above, on December 22, 2020, I certified the Eveook System and method of installing and using it meets the ANSI Z359.6‑2016 Standard in the United States and the CSA Z259.16‑15 in Canada as an engineered fall‑protection system for workers on sloped roofs. This required that all the individual parts of the system be tested to meet their individual requirements and that the complete system be tested to meet the requirements of the ANSI Z359.6 and the CSA Z259.16 Standards. Furthermore, I certified that the Eveook System and Method meets OSHA 1910.140 and 1926.501 Standards.
13. To the best of my knowledge, the Eveook System I have certified is the only fall‑protection system for residential‑style sloped roofs in the United States or Canada that has been engineered to the standards listed in the above paragraph.
Respectfully,
Greg Small
Date: April 28, 2025
Los Angeles, CA
Houston, TX
Jonesboro, AR
Kalamazoo, MI
Houston, TX
Blaine, MN
