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.

September 1, 1987

MEMORANDUM FOR:     Gilbert J. Saulter
                    Regional Administrator

ATTENTION OF:       Jerry Bailey
                    Assistant Regional Administrator 
                    for Technical Support

                    Thomas J. Shepich, Director, 
                    Compliance Programs

SUBJECT:            OSHA Standard 29 CFR 1910.177(d)(3) Restraining Devices
                    and Barriers

The performance criteria of 29 CFR 1910.177(d)(3) describe the requirements of an acceptable restraining device or cage. 29 CFR 1910.177(b) provides the definition o a straining device. Therefore, any marketed, manufactured or engineered device which meets the minimum requirements for a straining device as presented by the standard is acceptable.

The safety cage assemblies offered by Ken-Tool, as described in the company brochure, provide for compliance with the standard.

Original photos are returned as requested.