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 https://www.osha.gov.

June 19, 1984

J. Nigel Ellis, Ph.D., CSP
Research & Trading Corporation
Post Office Box 445
Wilmington, Delaware 19899

Dear Dr. Ellis:

This is in response to your letter of May 24, 1984, requesting consideration of your RTC-2700 Series Retractalok devices as meeting the intent of the Occupational Safety and Health Administration (OSHA) Fall Protection Standards.

OSHA's standard 29 CFR 1926.104 calls for 5400-pound and 3/4- inch manila or l/2 inch nylon lifelines where free falls of six feet are anticipated. However, you state that the RTC-2700 Series Retractalok is designed to limit falls to inches, thereby avoiding the severe shock-loading of a six-foot fall impact.

Assuming that the device will function as indicated in your Lehigh University Test Report dated August 5, 1982, a lifeline break strength of 3000 pounds would be satisfactory for the units. The units, when used according to the manufacturer's 1983 revised instructions, do meet the intent of OSHA's regulations.

If you have further questions, please feel free to contact Mr. John B. Miles, Jr., Director, Directorate of Field Operations.


Patrick R. Tyson
Deputy Assistant Secretary

May 24, 1984

Mr. Patrick R. Tyson
Deputy Assistant Secretary
US Department of Labor-OSHA
NDOL Building
200 Constitution Ave., N.W.
Washington, D.C. 20210

Dear Mr. Tyson:

Retracting Lifeline Fall Arrest Devices Meeting the Intent of the OSHA Act.

Based on a recent refusal by the Michigan Department of Labor, Bureau of Safety and Regulation, to accept Mr. Barto's letter of 1/17/83 (attached) concerning our RTC-2700 Series Retractalok devices, I am requesting that you can determine and state that these devices do specifically meet the intent of the Occupational Safety and Health Act.

Although Mr. Barto's letter was accepted by the State of California and led to California approval along with our test report, the lack of acceptance in Michigan has caused and is causing us severe problems in our interstate commerce with Michigan resulting in rejection of many pieces of RTC equipment from at least one major employer in the State.

I can also state that since marketing this particular equipment from 1980, many hundreds of devices have been sold and used in all the States for the purpose of fall protection in lieu of 3/4" manila lifelines which often cannot meet the 5400 lb. strength requirement when a six-foot free fall is anticipated. The specific advantage of the RTC-2700 retracting lifeline is the self-containment and taut lifeline which can reduce free falls to a few inches, thus requiring a lifeline strength of only 3000 lbs.

A particularly popular application has been the dual use as a confined entry lifeline and retrieval system for tanks and shafts which allows a buddy worker to lift his incapacitated co- worker without having to enter the confined area and thereby endanger himself.

These units have been successfully used in Europe since the mid- 1950's for general industry and construction work. No problem to our knowledge has been found by our supplier or ourselves with regard to the reliability of the locking mechanism under diverse usage conditions including extreme cold at -30oC. RTC is responsible for these devices in the USA and changes are made to designs as required and RTC has been familiar with the characteristics of retracting lifeline devices since 1973.

RTC is responsible for quality control on the equipment when it is accepted from our supplier and when we recondition the devices. Our procedure is enclosed. The proper self-reeling of the equipment, efficient locking and absence of damage to any parts are important checks on the suitability of the devices for their intended purpose.

I have enclosed information on the testing of the RTC-2700 Series from Lehigh University for your review.

Our instruction package $590 dated 6/83 is enclosed and which is revised from time to time as new information becomes available.

For the purpose of inspection, it is our intention to add an inspection marker to the lower end of the cable signifying to the CSHO whether exposure to a heavy load stress has occurred even though the equipment can take many heavy drops without loss of arresting efficiency. We also currently ask for return of equipment annually (after the second year) for the purpose of RTC inspection and cable replacement if necessary.

This equipment we feel is necessary and useful for the purpose of fall protection and based on the 15-year experience of RTC in the field of fall arrest devices, we are vitally concerned with its proper use and maintenance and reliability for employee safety.

Therefore, after studying this information, we request that you consider the draft letter reply which I have enclosed for your consideration so that signed copy can be presented to the State of Michigan for the purpose of their permitting a de minimus citation which will grant us relief from the present out-of- date standards confusion in Michigan and resulting disruption to our interstate business.

Thank you.

Yours sincerely,

J. Nigel Ellis, Ph.D., CSP

January 17, 1983

J. Nigel Ellis, Ph.D.
Research and Trading Corporation
Post Office Box 445
Wilmington, Delaware 19899

Dear Dr. Ellis:

This is in response to your recent inquiry requesting an interpretation of 29 CFR 1926.104.

29 CFR 1926.104 requirements for life-lines do not specifically regulate the manufacture of equipment such as your RTC-2700 series Retractalok. However, section 1926.104 does regulate the installation and use of lanyard equipment.

The units, when used in accordance with the manufacturer's 1982 revised instructions, appear to meet the intent of the Occupational Safety and Health Act.

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


John K. Barto
Chief, Division of Occupational
Safety Programming