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May 30, 1996

Mr. Reynolds
Division Safety Manager
Pacific Supply
1155 North Emerald Avenue
Modesto, California 95351-1560

Dear Mr. Reynolds:

This is in response to your letter to the Occupational Safety and Health Administration (OSHA) in which you requested copies of any interpretation letters dealing with whether vendors or suppliers of roofing material have to be tied off while delivering supplies to residential or commercial roofs. You also asked if it was acceptable to use fall restraint systems on roofs rather than fall arrest systems.

OSHA issued a February 1995 interpretation relating to vendors or suppliers of roofing materials, in which OSHA stated that vendor's employees would not have to be tied off or otherwise protected from falling while delivering roofing materials. A copy of that interpretation is enclosed. The interpretation applies to residential roofs or roofs of similar structure.

With regard to fall restraints, they are acceptable to use on roofs. The anchorage points and other criteria specified in 29 CFR 1926.502(d) should be followed at a minimum, unless an engineer specifies otherwise, since a slip could occur near the peak of the roof and the person may not be restrained until near the bottom or eave of the roof.

If you have any questions, please contact me at (202) 219-8136.

Sincerely,

Roy F. Gurnham, P.E., J.D.
Director
Office of Construction Services