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.

April 4, 1991

J. Thomas Wolner, P.E.
R & D Engineering
D B Industries, Inc.
P.O. Box 46
Red Wing, Minnesota 55066

Dear Mr. Wolner:

Thank you for your inquiry of January 25, requesting clarification whether a separate line is required when raising or lowering an employee in a full body harness attached to a winch line and whether a winch line can be used as a safety line for an employee ascending or descending a fixed ladder.

The situation you described is not covered by existing Occupational Safety and Health Administration (OSHA) standards. Therefore, the Agency addresses the safety of suspending employees in full body harness from winches through its enforcement of Section 5(a)(1) of the OSH Act. Under this approach, OSHA references the safety principles applicable to similar equipment (in this case, boatswain's chairs, single-point and two-point suspended scaffolds) and related national consensus standards.

Under Section 5(a)(1) OSHA requires a separate safety line as a back-up personal fall protection system for employees suspended in full body harness from winches. The single point suspension system and the separate safety line system need to be attached to independently supported separate anchor points.

The OSHA safety standard 29 CFR 1910.27, fixed ladders, requires cages, wells, or ladder safety devices on ladders of more than 20 feet in length. When an employee is ascending or descending a fixed ladder, a winch line may be attached to an employee's full body harness to act as a personal fall protection system without an additional safety line being required, when the supporting cable is straight for its entire length and the operator does not sway the employee or fix the cable to any intermediate points to change his original path of travel. The winch line must be continuously adjusted in length during such use, to avoid excessive vertical forces on the employee, tripping hazards, and falls against a slack winch line.

OSHA will accept protection to employees from hazards when the employer's action provides equal or greater employee protection than that required by an applicable standard. This authority is provided through the enclosed de minimis violations policy. For lengths of climb on fixed ladders which under 29 CFR 1910.27 require ladder cages or safety devices, the use of a winch line supporting an employee in full body harness would constitute a de minimis violation.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.



Patricia K. Clark, Director
Directorate of Compliance Programs