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.

January 26, 1996

Mr. J. Thomas Wolner, ME, P.E.
Engineering Manager
DB Industries, Inc.
3965 Pepin Ave.
Red Wing, MA 55066-1837

Dear Mr. Wolner:

This is in response to your October 20, 1995 letter requesting a determination of compliance from the Occupational Safety and Health Administration (OSHA) for the Manucroche quick connector.

As you know, OSHA does not endorse or issue formal letters of approval for products. However, when provided with adequate information, we can offer an opinion as to whether or not a product affords compliance with certain regulations. We have reviewed the test data and product information that you enclosed in your letter and the Manucroche Quick Connector device appears to meet the connector criteria for fall arrest systems in §1926.502(d). In addition, OSHA will consider the Manucroche connector device to be a connector and not a snaphook for the purposes of §1926.502(d).

For your information, I have enclosed a copy of a letter addressing anchorage for fall arrest systems used on scaffolds. If you have questions, please contact the Directorate of Construction at (202) 219-7207.


Roy F. Gurnham, P.E., J.D.
Office of Construction Services
Directorate of Construction