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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.
February 19, 2004
Mr. Chuck Hill
Re: Under §1926.502, whether components of fall protections systems from different manufacturers may be used together, provided they have compatible shapes and dimensions.
Dear Mr. Hill:
This is in response to your e-mail dated February 11, 2004, to the Occupational Safety and Health Administration (OSHA). You ask about the requirements for fall protection equipment (i.e., a safety positioning strap and a body belt) and whether the equipment components must be manufactured by the same company or can be made by various manufacturers.
We have paraphrased your question as follows:
Question: May fall protection safety equipment components be manufactured by different companies or must one manufacturer make each individual system?
Section 1926.502 "Fall protection systems criteria and practices" states in part:
(d)(5) and (e)(7):
Snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected member, or shall be a locking type snaphook designed and used to prevent disengagement of the snaphook by the contact of the snaphook keeper by the connected member. Effective January 1, 1998, only locking type snaphooks shall be used.
(d)(6) and (e)(8):
Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged [to the listed devices] ...
These provisions require that snaphooks used in personal fall arrest systems and in positioning devices be sized to be compatible with the member to which they are connected, or be of a locking type designed to prevent disengagement of the snaphook. In addition, for certain specified connections, only locking snaphooks designed for those connections can be used.
In sum, individual components in a fall arrest (or in a positioning device system) may be made by different manufacturers as long as they meet these compatibility requirements.
If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, 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