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.

September 8, 2004

Mr. Milan Racic
International Brotherhood of Boilermakers
452 West Willow Court
Fox Point, Wisconsin

Thank you for your June 13, 2004 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP).You requested OSHA's opinion of an article written by Bill Weems and Phil Bishop, titled: "Will Your Safety Harness Kill You?"

OSHA had already reviewed the above article in connection with its issuance, earlier this year, of a Safety and Health Information Bulletin (SHIB), Suspension Trauma and Orthostatic Intolerance to provide guidance and recommendations for addressing the hazards of suspension trauma and orthostatic intolerance. The SHIB provides employers and employees with important hazard information and outlines OSHA's recommendation for preventing prolonged suspension in personal fall protection systems. Specifically, the SHIB recommends that employers develop a plan that includes implementing procedures to prevent prolonged suspension, identifying signs and symptoms of orthostatic suspension, and performing rescue and treatment as quickly as possible. I have enclosed a copy of the SHIB for your review, and you may also download it from OSHA's webpage at

In addition, OSHA's proposed rule to revise the Part 1910 standards on walking-working surfaces and fall protection (Subparts D and I) also includes a rescue provision when personal fall arrest systems are used (Proposed §1910.129(c)(6); 55 FR 13423, April 10, 1990). OSHA is in the process of updating the economic analysis of the proposed rule and plans to reopen the record for additional comment when the analysis is complete. When the record (S-029) is reopened, OSHA invites you to submit comment, information, and data on the hazards of fall suspension and orthostatic intolerance and any additional measures you recommend OSHA adopt to address those hazards. OSHA will carefully review and consider all the evidence submitted to the record in developing the final standards on Subparts D and I. (For information on developments in this rulemaking or to submit comments during the reopening, please consult OSHA's webpage.)

Thank you for your interest in occupational safety and health. We hope you find this information helpful.


Richard E. Fairfax, Director
Directorate of Enforcement Programs

[On May 2, 2003 a Notice of reopening of the rulemaking record and public comment period on the Walking and Working Surfaces, Personal Protective Equipment (Fall Protection Systems) Proposed Rule was published in the
Federal Register at 68:23527-23568. It included the text of the April 10, 1990 proposed standard.]