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.

December 4, 1996

Mr. Lynn A. Warren
Supervisor, Safety and
Environmental Health
P.O. Box 1500
Somerville, New Jersey 08876-1251

Dear Mr. Warren:

This is in response to your letter of October 7 requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) fall protection standard as it pertains to exceeding the 6 foot free fall distance.

OSHA cannot anticipate every circumstance that must be present before an employer can permit a free fall more than 6 feet. In general, OSHA will permit an employer to exceed the 6 foot free fall limit whenever there is no anchorage point to which the employer can attach that will enable the employer to rig the personal fall arrest system to limit the free fall to 6 feet or less--an infeasibility situation. In that case, the employer may exceed the 6 foot free fall, but must ensure that the maximum arresting forces (MAF) listed in the standard are not exceeded. The MAF for an employee using a body harness must be limited to 1800 pounds and if the employee is using a body belt, the forces must be limited to 900 pounds. It is doubtful that you could exceed a free fall of more than 6 foot and keep the forces under 900 pounds with a body belt. [As of January 1, 1998, the use of body belts for fall arrest is prohibited."] Therefore, OSHA recommends that a full body harness be used. For additional information, please see the enclosed interpretation M-3 which explains the conditions under which OSHA allows an employer to deviate from the requirements in §1926.502 (d) (16).

Thank you for your continued interest in occupational safety. If you have any questions, you may contact me or Ms. Barbara Bielaski of my staff at (202) 219-7207 xl3l.


Russell B. Swanson, Director
Directorate of Construction