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.
January 25, 1988
Mr. Roman V. Dorosz
Vice President, Engineering
Reach All, Inc.
1300 Port Terminal Drive
P.O. Box 1047
Duluth, Minnesota 55816-0047
Dear Mr. Dorosz:
This is in further response to your letter of November 10, 1987, and is prompted by a conversation between Mr. Jim Beck of GTE and Mr. Bode of my staff.
Our prior response of December 17, 1987 did not convey complete clarification of the process for employee transfer from the aerial device to a fixed structure. Therefore, when employees must transfer to a fixed structure and while the employee is standing upon the base platform of the basket or cage the employees lanyard should be expeditiously transferred to an attachment point on the fixed structure. This may be safely accomplished by first attaching a drop line to the fixed structure while the basket is located at a point from which it is convenient to do so. Then after lowering the basket to the height and location from which transfer may be accomplished, the employee may conveniently transfer his or her lanyard to a grab on the drop line before leaving the safety of the basket. In no event are employees advised to leave the safety of the basket floor until their lanyard is securely attached in a manner which will provide fall protection. It should be noted that the attachment point on the fixed structure must be above the employees work location. The attachment and the drop line must be capable of supporting a minimum dead weight load of 5400 pounds per person.
We believe this further clarification will alleviate the concerns expressed by Mr. Beck and more fully expresses the method for accomplishing this work task in a safe manner.
If we may be of further assistance, please contact us.
Thomas J. Shepich, Director
Directorate of Compliance Programs