Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

July 30, 1996

Mr. Leonard Meenan Jr.
30W152 Bruce Lane
Naperville, Illinois 60563

Dear Mr. Meenan:

This is in response to your March 22 letter comments on our February 26 response to your previous January 25 letter. Please accept our apology for the delay in responding. Our response to your second letter follows.

You referenced (in item one of your letter) the clarification in our February 26 letter stating that a harness used for fall protection is not considered "apparel" and therefore would not be subject to the requirements of paragraph 1910.269(l)(6)(iii). This clarification is reaffirmed. Harnesses and body belts are components used in personal fall protection systems which should be selected to match the particular work situation. Selection and use of personal fall protection systems are addressed in Appendix A to Subpart I in the enclosed proposed rule on fall protection system (see page 13438).

You referenced (in item two of your letter) the reply to question 2 of our February 26 letter in which we clarified that a body belt used as a component in a pole strap fall protection system is not required to be dielectrically tested. This clarification is reaffirmed. Please note that dielectric testing of all fabrics used for safety straps, but not body belts, is required under paragraph 1926.959(b). Also, in response to item three of your letter, we reaffirm that "there is no other OSHA standard that contains a similar requirement for other safety straps used for fall protection required under paragraph 1910.269(g)." Section 1910.130, which you referenced in your second letter, is only a proposed standard.

In item 4 of your letter, you stated that 1910.269 "at best is a general standard with no specific information dealing with aerial work. In fact, in 43 pages of standard, other than eight sentences, 1910.269(g)(2)(vi), the only aerial work spoken of goes no higher than a step ladder." OSHA believes that 1910.269 contains necessary and appropriate requirements for the protection of employees performing electric power generation, transmission, and distribution work at heights of more than 4 feet (1.22 meters) above the ground.

However, 1910.269 does not duplicate requirements contained in other standards protecting employees from fall hazards, namely, 1910.67 and Subpart V of Part 1926. OSHA intends to revise Subpart V and 1910.269 rules dealing with fall protection equipment to incorporate the latest fall protection technology in electric power generation, transmission, and distribution work. Enclosed is a copy of the draft revision of Subpart V for your review and comment.

In item five of your letter, you stated that you have tested a harness that melted "at around 400 degrees." No other testing information is provided in your letter. An electric arc testing methodology must be used to determine ignition of the harness due to electric arc exposure. We welcome any test data that you can provide on the performance of fall protection systems when exposed to electric arcs.

Thank you for your interest in employee safety and health. If we can be of any 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