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 http://www.osha.gov.

June 3, 1998

John J. McCarthy
Lovell Safety Management Co.
125 Maiden Lane
New York, NY 10038-491

Dear Mr. McCarthy:

This is in response to your letter, dated February 2, 1998, to the Occupational Safety and Health Administration (OSHA) in which you asked whether shock absorbing lanyards were mandatory in a personal fall arrest system.

Shock absorbing lanyards are not mandatory but are often used to comply with OSHA's Subpart M requirements. The specifications for a personal fall arrest system are in 29 CFR 1926.502(d). One of the provisions in this section requires that when using a full body harness, the system must limit the maximum arresting force exerted on an employee to 1,800 pounds. One means of complying with this section is to use a shock absorbing lanyard.

If you require further assistance, please do not hesitate to contact us again by writing to: Directorate of Construction-Office of Construction Standards and Compliance Assistance, Room S-1506, 200 Constitution Avenue, N.W., Washington, D.C. 20210.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction