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.

August 10, 1983

Mr. Ernest E. Punches
Application Engineer
DB Industries, Inc.
P.O. Box 46
Red Wing, Minnesota 55066

Dear Mr. Punches:

This is in response to your latest letter of July 12, 1983, concerning a clarification of the applicable standards for a body belt and lanyard used by a lineman working from the bucket or aerial boom trucks.

The requirements of 29 CFR 1926.959(b) apply to lineman's body belts, safety straps, and lanyards as described below. It should be noted that some of the requirements applying to all three items address hardware primarily found on one unit of equipment. For example, 29 CFR 1926.959(b)(4) applies to body belts, safety straps, and lanyards, but it addresses D rings, which are used on body belts.

        Body belts, safety straps, and lanyards

        29 CFR 1926.959
                       (b)(1)(ii) - fabric and leather
                       electrical tests
                       (b)(1)(iii) - D.C. tests
                       (b)(4) - D rings
                       (b)(5) - stitching
                       (b)(6) - snaphooks
                       (b)(7) - testing

        Safety Straps only
        29 CFR 1926.959(b)(1)(i) - electrical tests

        Body belts only

        29 CFR 1926.959(b)(2) - cushion portion of belt
                       (b)(3) - tool loops

I hope this information is helpful to you. If I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Barto
Chief, Division of Occupational
Safety Programming