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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

March 12, 1998

SMSGT. Edward L. Lamora
109 Airlift Wing
New York Air National Guard
1 Air National Guard Road
Scotia, NY 12302-9752

Dear SMSGT. Lamora:

This is in response to your January 30 letter and enclosures which included design information, including strength calculations, on a Passive/Active Fall Safety System stanchion, an invention patented by L. G. White (Patent Number 5653308). In your letter you requested that the Occupational Safety and Health Administration (OSHA) indicate whether the stanchion meets or exceeds OSHA fall protection standards.

The information you provided may be useful to an employer in determining whether a fall protection system in which the stanchions are components would meet OSHA requirements. Compliance would be determined by an OSHA Compliance Safety and Health Officer (CSHO) (using the references noted in the paragraph below) during workplace inspection of a fall protection system.

There are no specific requirements in the 29 CFR 1910 General Industry Standard on safety nets and supporting stanchions. However, OSHA has proposed to revise 29 CFR 1910 Subpart DWalking-Working Surfaces to include safety net fall protection requirements under paragraph 1910.28(h). A copy of the Notice of proposed Rulemaking (published in the Federal Register, Volume 55, Number 69, on Tuesday, April 10, 1990) is enclosed for your use. Please be advised that an employer who complies with a proposed rule will be considered in compliance with OSHA safety and health standards. Also, American National Standards Institute standard: ANSI A10.11 for the Construction and Demolition Operations - Personnel and Debris Nets, is referenced in Appendix D of the proposed standard. This National Consensus Standard is intended to serve as a nonmandatory guideline to assist employers and employees in complying with OSHA requirements and to provide other helpful information on safety nets.

We appreciate your interest in worker safety and health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202) 219-8031, extension 110.


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