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 27, 1993

Mr. Kevin D. Ouellette
Engineering Manager
SINCO Products Inc.
One SINCO Place
P.O. Box 361 East
Hampton, Connecticut 06422

Dear Mr. Ouellette:

This is in further response to your letter of July 16, regarding your product "SINCO Retract-A-Matic 6 Lifeline (RAM 6A)." You requested in your letter that the Occupational Safety and Health Administration (OSHA) review and comment on your strength test data for this product with respect to the nonmandatory strength method for personal fall arrest systems in paragraph II(c) of Appendix C to 29 CFR 1910.66. You stated in your letter that SINCO Products, Inc. is looking to confirm that this product meets the intent of the OSHA standards. Please accept our apologies for the delay in responding.

In your letter you stated that the "RAM 6A" deceleration device, by design, limits free fall to approximately 1" (2.54 cm). Test Data Sheet #92004 enclosed with your letter states "the unit caught the weight within 2" (5.08 cm). In fact, this 1" (or 2") distance is "deceleration distance" which is defined in paragraph I(b) of Appendix C. The aforementioned test data sheet states that "A test weight of 600 pounds was dropped." However, the free fall distance that the test weight was dropped was not identified. [Note: "Free fall" and "free fall distance" are defined in paragraph I(b) of Appendix C]. Also, other testing information, including the following, was omitted.

  1. Rigidity of the anchorage (see paragraph II(b)(2)).
  2. Whether a body belt or body harness was used (see paragraph II(c)(3)).
  3. Configuration of the test weight (see paragraph II(b)(4)).



Please note that the general conditions for testing in paragraph II(b) must be followed in order to determine whether or not your strength test is equivalent to the strength test described in paragraph II(c) of Appendix C.

As noted in the "Additional non-mandatory guidelines" of section III to Appendix C, the employer should select the kind of personal fall arrest system which matches the particular work situation. Any possible free fall distance should be kept to a minimum. In compliance with paragraph I(e)(3), personal fall arrest systems shall be rigged such that an employee can neither free fall more than six feet (1.8 m), nor contact any lower level. In compliance with paragraph I(d)(iv), personal fall arrest systems, when stopping a fall, shall have sufficient strength to withstand twice the potential energy of an employee free falling a distance of six feet (1.8 m) or the free fall distance permitted by the system, whichever is less. The strength test of paragraph II(c) or an equivalent test may be used to demonstrate personal fall arrest system compliance with this system performance strength criteria. Please note that the "Design for system components" requirements, which include strength criteria for individual components, must be met in addition to the system performance strength criteria.

In your letter you describe your SINCO Retract-A-Matic 6 Lifeline (RAM 6A) to consist of a swivel shackle, deceleration device with an automatic self-retracting lanyard and sur-lock snap hook. An anchorage and body belt or body harness and associated connectors must be included along with the "RAM 6A" assembly described above to be considered a "personal fall arrest system" as defined in paragraph I(b) of Appendix C. Also, the system care and use requirements of paragraph I(c) must be met.

Adding, removing, or replacing (except in kind) components constitutes a change which requires the modified personal fall arrest system to be reevaluated for compliance with mandatory section I requirements. In addition to the system performance strength criteria addressed previously, personal fall arrest systems must meet the arresting force and deceleration distance limitations of paragraph I(d). The force test and the deceleration device test in paragraph II(d) and II(c), respectively, may be used to determine compliance with corresponding paragraph I(d) system performance criteria.

Please note that the contents of this letter are advisory. OSHA does not effectively endorse, approve, or certify and does not consent to such representation in advertising of equipment or materials which, through misuse or misapplication, may cause safety or health related hazards. When provided with sufficient information concerning a new product, OSHA will offer an opinion on whether compliance with OSHA's standards is anticipated.

Thank you for your interest in occupational safety and health. If we maybe of further assistance please contact us.


Roger A. Clark, Director
Directorate of Compliance Programs

[Corrected 10/20/2006]