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.

November 2, 1995

Mr. Mike Amen
Envirocon, Inc.
500 Taylor Street
P.O. Box 8243
Missoula, Montana 59807

Dear Mr. Amen:

This is in response to your letter of November 23, 1994 to the Occupational Safety and Health Administration (OSHA) in which you asked if a fall restraint system could be considered a form of fall protection to be used instead of guardrails, safety lines, or fall arrest systems. Yes, although the standard does not mention them, it is perfectly acceptable to use fall restraint systems to protect employees from fall hazards.

You also inquired as to how far from the edge a restraint system would have to keep the employee, considering that control lines specify six feet. OSHA's position is that as long as the restraint system prohibits the employee from falling off an edge, the employee can be within inches of the edge.

Lastly, you asked if the anchor points for restraints had to meet the same criteria as for fall arrest. OSHA has no specific standards for restraint systems, however, we suggest that as a minimum, fall restraint systems should have the capacity to withstand at least twice the maximum expected force that is needed to restrain the person from exposure to the fall hazard. In determining this force, consideration should be given to site-specific factors such as the force generated by a person walking, leaning, or sliding down the working surface.

If you have any questions, please [contact the Directorate of Construction at (202) 693-2020].


Roy F. Gurnham, P.E., J.D., Director
[Directorate of Construction]

[Corrected 10/22/2004]