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 19, 1993
Mr. Barry White
Barry White Associates
11116 Powder Horm Drive
Potomac, Maryland 20854
Dear Mr. White:
This is in response to your December 9 letter requesting review and comments on the "Reeves Sleeve" stretcher model #122.
As you recognize in your letter, the Occupational Safety and Helath Administration (OSHA) does not approve nor endorse products. The variable working conditions at jobsites and possible alterations or misapplication of an otherwise safe product could easily create a hazardous conditon beyond the control of the manufacturer. However, we have reviewed the product data in the brochure enclosed with your letter and it appears that if the "Reeves Sleeve" is properly applied, and training in the use of the product is conducted, the user would be in compliance with OSHA standards such as 29 CFR 1926.651(g)(2)(i) dealing with emergency rescue equipment.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Roy F. Gurnam, Esq., P.E.
Director of Construction
and Maritime Compliance Assistance