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.

May 7, 1982

Ms. Sandra B. Kloster
Littler, Mendelson, Fastiff & Tichy
Attorney at Law
111 Almaden Boulevard, Suite 400
San Jose, California 95113

Dear Ms. Kloster:

This is in response to your letter of April 19, 1982, concerning the correct testing Procedure for tree-trimming saddle belts.

The Occupational Safety and Health Standards do not provide testing procedures for tree-trimming saddle belts at the present time. However, the American National Standards Institute, Inc. ANSI Z133.1-1979 contains safety requirements for pruning, trimming, repairing, maintaining, and removing trees, and for cutting brush. Paragraph 3.2.6 of ANSI Z133.1-1979 requires safety belts or tree-trimming saddle belts as specified in American National Standard Requirements for Safety Belts, Harnesses, Lanyards, Lifelines, and Droplines for Construction and Industrial use, ANSI A10.14-1975, or a saddle formed by a double bowline on a bight shall be worn to protect workers above ground level.

The testing procedure mentioned in your letter appears to comply with the intent of the Occupational Safety and Health Act of 1970 provided the test is preformed as set out in ANSI A10.14-1975. You informed a member of my staff that you have obtained a copy of the ANSI A10.14-1975 standard.

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

Sincerely,



John K. Barto
Chief,
Division of Occupational Safety Programming