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.

March 6, 1998

Mr. J. Nigel Ellies, President
Dynamic Scientific Controls
P.O. Box 445
Wilmington, DE 19899-0445

RE: 29 CFR 1926.20(b); 1926.21(b); 1926.500(b); 1926.502(d)

Dear Mr. Ellis:

This is in response to your letter of November 11, 1997, to the Occupational Safety and Health Administration (OSHA.) You expressed concern about body harnesses that incorporate body belts encircling the waist. You also note that some workers do not use, or remove, parts of the body harnesses.

The term "body harnesses," as defined in subpart M: Fall Protection (1926.500(b),) means "straps which may be secured about the employee in a manner that will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest and shoulders with means for attaching it to other components of a personal fall arrest system." This definition does not exclude the use of a waist or chest strap as part of the full body harness as long as the harness properly distributes the fall arrest forces. Also, section 1926.502(d)(16) requires the "system" (as a whole) to limit the maximum arresting force on an employee to 1,800 pounds (8 kN.)

With regard to the improper use of the equipment, if employees are properly trained, they are less likely to misuse equipment. Sections 1926.20(b) and .21(b) require employers to train employees and ensure that equipment is used properly.

There is no evidence on the record showing that employees would be harmed in a fall while properly wearing an appropriately designed full body harness that has a waist strap encircling the body. However, the agency plans to open subpart M later this year and we encourage you to comment on this issue and submit any relevant information during the rulemaking process.

If you require any further assistance, please do not hesitate to contact us again by writing to: Directorate of Construction - Office of Construction Standards and Compliance Assistance, Room N3621, 200 Constitution Avenue, N.W., Washington D.C. 20210.

Russell B. Swanson, Director
Directorate of Construction