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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.
July 9, 2003
Mr. Doug Mercier
1345 15th Street
Franklin, PA 16232
Re: Section 1926.502(d)(6) prohibits snaphooks from being engaged to certain specified equipment unless "designed for" such a connection. What does the phrase "designed for" mean?
Dear Mr. Mercier:
This is in response to your letter dated December 10, 2002, to the Occupational Safety and Health Administration (OSHA). You ask for clarification of the fall protection standard §1926.502, Fall protection systems criteria and practices. We apologize for the delay in responding.
Your questions are paraphrased as follows:
Question (1): Section 1926.502(d)(6) prohibits snaphooks from being engaged to certain specified equipment unless "designed for" such a connection. What does the phrase "designed for" mean?
29 CFR 1926.502(d)(6) states:
(d) * * * (6) Unless the snaphook is a locking type and designed for the connections, snaphooks shall not be engaged:
(i) directly to webbing, rope or wire rope;
(ii) to each other;
(iii) to a Dee-ring to which another snaphook or other connector is attached;
(iv) to a horizontal lifeline; or
(v) to any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional disengagement could occur by the connected object being able to depress the snaphook keeper and release itself.
In the preamble of the final rule (59 FR 40705, August 9, 1994), OSHA explained the purpose of paragraph (d)(6) as follows:
This provision reflects OSHA's determination that certain connections increase the likelihood of rollout and that only locking snaphooks specifically designed for such connections are needed to provide adequate assurance of employee safety. Accordingly . . . OSHA is limiting the circumstances in which they can be used.
By its terms, the standard prohibits snaphooks from being "engaged" to (that is, snapped onto) certain objects unless two requirements are met: it must be a locking type snaphook and it must be designed for making such a connection. "Designed for" means that the manufacturer of the snaphook specifically designed the snaphook to be used to connect to the equipment listed in the standard.
For example, if you want to use a locking snaphook to engage to webbing (which is normally prohibited under paragraph (d)(6)(i)), you are allowed to do so only if the snaphook manufacturer specifically designed the snaphook to be engaged to webbing thatis used as part of a fall protection system. To determine if the manufacturer designed the locking snaphook for that purpose, you must either contact the manufacturer or find that use specifically identified in the product literature as an approved use.
Question 2: Is it a violation of OSHA standards to connect two locking snaphooks to one dorsal Dee-ring of a full body harness if the manufacturer of the snaphook states that it is not designed for such applications?
As stated above, §1926.502(d)(6)(iii) prohibits a snaphook from being connected to a Dee-ring to which another snaphook or other connector is attached unless the snaphook is a locking snaphook and is designed for the connection. In your scenario, the snaphooks are of the locking type, but the second snaphook is not designed to be connected to a Dee-ring to which another snaphook is attached. Therefore, it would be a violation of this provision to attach the second snaphook to the Dee-ring.
If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, [Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction