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.

September 25, 1995

Mr. Gregory Clements
Roofmaster Products Company
P.O. Box 63309
Los Angeles, California 90063-0309

Dear Mr. Clements:

This is in response to your letter of January 17 to the Occupational Safety and Health Administration (OSHA) in which you asked whether OSHA's new fall protection standards for construction (29 CFR 1926.500-503) will prohibit use of safety belts with side dee rings as part of a personal fall arrest system, or whether we will grandfather in older belts. You point out that effective February 6, 1995, you will add rear dee rings to the belts you manufacture.

Side dee rings are acceptable for work positioning devices, such as those used by linemen, employees doing rebar work, or tree trimmers, but are not acceptable for fall arrest systems.

Our standards define "positioning device system" as "...a body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning." "Personal fall arrest system" is defined as, "...a system used to arrest an employee in a fall from a working level. It consists of an anchorage, connectors, a body belt or body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these. As of January 1, 1998, the use of body belts for fall arrest is prohibited."

Positioning devices are covered under 1926.502(e) and do not require a rear dee ring. Fall arrest systems, however, must have the lanyard attached to a dee ring at the back to minimize injury to the wearer. Belts used for fall arrest with side dee rings are not in compliance, are dangerous to the wearer, and will not be grandfathered as being acceptable; however, most safety belt manufacturers have stated that if their belts are rotated ninety degrees so that the side dee ring is in the center of the back, then the belt can be used for fall arrest.

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