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 22, 1982

Mr. Lew Himmelrich
Descent Control, Inc.
Post Office Box 6405
Fort Smith, Arkansas 72901

Dear Mr. Himmelrich:

This is in response to your letter of March 3, 1982, requesting a clarification of the Sky Genie Boatswain's Chair System.

The OSHA General Industry and Construction standards for a boatswain's chair requires a main suspension line for supporting the chair. In addition, the employee must also be protected by an entirely independent lifeline and belt. The lifeline shall be securely attached to substantial members of the structure (not scaffold) or to securely rigged lines. The two independent suspension systems have no common components and will assure the safety of the employee in the event of a failure of the main suspension line by having the lifeline as a backup.

The Sky Genie Boatswain's Chair System utilizes the main suspension line and the lifeline through the Sky Genie Descent Control Unit. It is not clear, based on the information you have provided, whether the employee would be safely suspended by either line if the Sky Genie descent control unit was subjected to a failure. Additional data is needed before we can provide your clarification for the Sky Genie Boatswain's Chair System.

Your assistance in this matter will be appreciated. If I may be of further assistance, please contact me.

Sincerely,



John K. Barto
Chief,
Division of Occupational Safety Programming