OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

March 26, 1979

John Nigel Ellis, Ph.D.
President
Research and Trading Corporation
1206 King Street
Wilmington, Delaware 19801

Dear Dr. Ellis:

This is in response to your recent request for an official interpretation of the intent of 29 CFR 1926.104. You have also requested that this office evaluate your Evalok products against the above standard and any applicable general industry standards. This National Office interpretation supersedes the Regional response dated February 28, 1979, concerning the same subject.

As indicated in your letter, the Evalok 30 rope break strength is approximately 4000 lbs. and the Evalok 50 cable break strength is approximately 3000 lbs. Both of the above lifelines fail to comply with the 5400 lbs. strength requirement contained in 29 CFR 1926.104. However, your retracting reel locking type system is more sophisticated, in that the disc brake attached to the lock acts to cushion a fall to less than six inches for a 350 lb. drop weight as verified by Pittsburgh Testing Laboratory reports.

Automatic fall protection devices such as the Evalok products, are not specifically regulated in our General Industry or Construction Standards. Employees using the Evalok products as automatic taut lifeline's installed to prevent a free fall of an employee to less than six inches appear to comply with the intent of OSHA's personal protective and life saving equipment requirements, provided the devices function at all times as indicated by the Pittsburgh Testing Laboratory reports.

A copy of this interpretation will be mailed to all OSHA Regional Administrators. The development of an Instruction to the OSHA field staff regarding personal lifelines of the retracting reel locking type as they apply to existing lifeline standards does not appear necessary at this time.

If I may be of any further assistance, please feel free to contact me.

Sincerely,



Bruce Hillenbrand
Acting Director
Federal Compliance
and State Programs