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.

September 25, 1984

Mr. E.E. Plumb
Boeing Aerospace Company
M/S 6K-82
Post Office Box 3999
Seattle, Washington 98124

Dear Mr. Plumb:

This is in response to your inquiry of September 5, requesting an interpretation of 29 CFR 1926.104.

The requirements of 29 CFR 1926.104 for life-lines do not specifically regulate the manufacture of equipment such as a safety block with a retractable steel wire. However, the standard does regulate the installation and use of lanyard equipment.

The safety blocks, when used in accordance with the manufacturer's instructions, appear to meet the intent of the Occupational Safety and Health Act and applicable regulations.

If we can be of further assistance, please feel free to contact us.


John B. Miles, Jr., Director
Directorate of Field Operations