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 28, 1995

Mr. J. Nigel Ellis
Dynamic Scientific Controls
P.O. Box 445
Wilmington, Delaware 19899-0445

Dear Mr. Ellis:

This is in response to your letter of April 4 to the Occupational Safety and Health Administration (OSHA) in which you expressed your concerns with Appendix C, Paragraph 1.(b)(3), in the 29 CFR 1926.500-503 fall protection standards, which states that the frequency response of the load measuring system when testing fall arrest equipment should be set at 500 Hz.

We agree that 100 Hz is more appropriate and would be consistent with other current American (ANSI Z359.1-1192) and Canadian (CSA Z259.11-M92) standards. Since Appendix C of the fall protection standards is a non-mandatory appendix, no citations will be issued if 100 Hz is used instead of 500 Hz for the frequency response of the load measuring system when testing fall arrest equipment.

We have provided our standards-setting personnel with a copy of your letter for possible adjustment of the appendix.

If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.


Roy F. Gurnham, P.E., J.D.
Office of Construction and Maritime
Compliance Assistance