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.
April 8, 1992
Mr. Richard Van Auken
Human Resources and Safety Manager
P.O. Box 269000
Kansas City, Missouri 64126
Dear Mr. Van Auken:
This is in response to your February 24 letter requesting the Occupational Safety and Health Administration (OSHA) to comment further on the Sky-Web system. I apologize for the delay of this response.
We appreciate the time and effort made by Butler Construction to acquaint OSHA with the capabilities and benefits of the Sky-Web system. However, as explained at the February 21 meeting with you, it is the policy of the Occupational Safety and Health Administration not to approve or endorse products. The variable working conditions at jobsites and possible alteration or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the product manufacturer. However, we have reviewed the information provided by Butler Construction and it appears the Sky-Web system, if properly installed and maintained, would provide adequate interior fall protection and be in compliance with OSHA's fall protection standards.
As requested in your letter, a copy of this letter along with other information you have provided, will be forwarded to our field offices.
If you need any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8124.
Patricia K. Clark Director
Directorate of Compliance Programs