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.

February 26, 1996

Mr. Leonard Meenan Jr.
30W152 Bruce Lane
Naperville, Illinois 60653

Dear Mr. Meenan:

This is in response to your January 25 letter requesting clarification of Occupational Safety and Health Administration (OSHA) regulations. As noted in the February 12 letter to you from our Regional Administrator's Office in Chicago, your letter was forwarded to this office for response. Your questions and our replies follow.

Question 1: Is a harness or body belt covered by the apparel standard under paragraph 1910.269(1)(6)(iii)?

Reply: No, a harness or body belt used for fall protection is not considered apparel and is not subject to the requirements under paragraph 1910.269(1)(6)(iii). Also, because of the thickness of such harnesses and body belts, ignition due to an electric arc is not likely.

Question 2: Does a harness have to be tested dielectrically, similar to body belts when used for fall protection required by paragraph 1910.269(g)?

Reply: Fall protection safety straps subject to the requirements under 1926.959 must withstand an A.C. dielectric test of not less than 25,000 volts per foot "dry" for 3 minutes. This requirement is intended to preclude the flow of electricity to ground by way of the safety straps if an employee is exposed to an electrical source when using fall protection equipment. Under 1926.959, dielectric testing of body belts is not required. There is no other OSHA standard which contains a similar requirement for other safety straps used for fall protection required under paragraph 1910.269(g).

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact Mr. Ronald Davies of my staff, telephone # (202) 219-8031, extension 110.


John B. Miles, Jr., Director
Directorate of Compliance Programs