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.

August 21, 1992

Richard F. Andree, CSP, PE, Ph.D
Executive Vice President
Safety & Health Management Consultants, Inc.
161 Williams Street
New York, New York 10038

Dear Dr. Andree:

Your letter of July 31 to Ms. Dorothy Strunk, Acting Assistant Secretary of Labor, requesting an interpretation of an Occupational Safety and Health Administration (OSHA) standard addressing body belts used for climbing power transmission or distribution poles has been referred to this office for reply.

With regard to whether a climber's safety belt can be used with a pole strap to climb a pole if the belt manufacturer's instructions prohibit its use for fall arrest, please be advised that a safety belt and pole strap system is as an acceptable means of fall protection for employees climbing poles. OSHA considers a lineman's pole strap and safety belt to be a fall prevention or restraint system, not a fall arrest system, and, therefore, there is no conflict between the safety belt manufacturer's instructions and federal standards for fall protection while climbing poles.

Please note that although OSHA standards allow the use of body belts in both systems, we agree with this manufacturer that belts should not be used for fall arrest.

If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff in the Office of Construction and Compliance Assistance at (202) 523-8136.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs