- Standard Number:
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.
June 24, 1993
Mr. Barry White
Barry White Associates
11116 Powder Horn Drive
Potomac, Maryland 20854
Dear Mr. White:
This is in response to your June 7 letter requesting review and comments on the "Reeves Sleeve" stretcher model #122.
As you recognized in your letter, the Occupational Safety and Health Administration (OSHA) neither approves nor endorses products. The variable working conditions at job sites and possible alternations or misapplications of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. We have reviewed the product data in the brochure you provided to OSHA and are of the opinion that employer most likely would be in compliance with the OSH Act when using a Reeves Sleeve for emergency rescue in the workplace as follows:
1. The Reeves Sleeve is maintained in serviceable condition through proper maintenance as determined by inspection procedures described in the brochure;
2. The Reeves Sleeve is used in accordance with manufacturer recommendations noted in the brochure; and
3. Training is conducted on the use of a Reeves Sleeve for the intended emergency rescue.
Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.
Sincerely,
Raymond E. Donnelly, Director
Office of General
Industry Compliance Assistance
January 19, 1993
Mr. Barry White
Barry White Associates
11116 Powder Horn 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 Health 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 condition 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.
Sincerely,
Roy F. Gurnham, Esq., P.E.
Director of Construction
and Maritime Compliance Assistance
December 9, 1992
Mr. Roy Gurnham Director
Office of Construction
and Maritime Program Assistance
Room 3610
U.S Department of Labor-OSHA
200 Constitution Avenue, N.W.
Washington, DC 20210
Dear Roy:
Hope you are still enjoying your new (I guess it's not so new now) job. Roger must like you. He follows you around.
Hope you can do something for me. A friend is manufacturing a new stretcher that is great for rescue. Its flexibility allows it to maneuver out of tight places like confined spaces, and it will not allow the victim to fall if rescue is needed from a high position.
Some potential buyers have delayed, saying the stretcher is not approved by OSHA. They think OSHA only permits something called a "Stokes" stretcher. I know OSHA does not approve anything; these potential buyers are really saying they do not know if the Reeves Sleeve meets OSHA requirements.
I sent this information to Safety Standards first because that's where I thought I needed to go to get a letter saying, "As far as OSHA is concerned, the Reeves Sleeve meets OSHA requirements."
Mike, and Gerry Reidy and Tom all said the stretcher looks fine, but that such letter has to come form Compliance Programs. So I am sending this to you, hoping you will place it in the proper channels. I will call you in a few in a few days to find out what to do next. Be glad to bring the manufacturer to meet with you after the first of the year, along wiht a Reeves Sleeve to show you, if that would be necessary.
Thanks, Roy, appreciate it. Happy holidays!
Sincerely yours,
Barry White