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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 https://www.osha.gov.
May 11, 2005
3940 Industrial Boulevard
P.O. Box 2280
West Sacramento, CA 95691
Re: Under Subpart M, whether a lanyard may be connected to another lanyard by a snaphook, provided the potential fall distance is six feet or less.
Dear Mr. Hayes:
This is in response to your letter dated January 26, 2005, to the Occupational Safety and Health Administration (OSHA). You asked about the requirements for fall protection equipment, specifically lanyards and snaphooks, and whether two lanyards may be connected to one another.
We have paraphrased your question as follows:
Question: Under the requirements in Part 1926 Subpart M, may one lanyard (which does not have an integral deceleration device) be attached to another lanyard (which does have an integral deceleration device), using locking snaphooks, provided that the free fall distance would not exceed six feet?
Answer: Title 29 CFR 1926 Subpart M defines a "lanyard" in §1926.500(b) as follows:
"...a flexible line of rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage."
In the situation you described, the lanyards have locking snaphooks on either end. One lanyard is connected to the safety line, the other is connected to the worker's harness, and the two are joined in the middle.
Title 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. [Emphasis added].
The snaphooks must be designed by the manufacturer to be connected to each other without failing. Also, in planning the system to comply with the requirements in §1926.502, keep in mind that the use of two lanyards may increase the distance to a complete stop in a fall.
In summary, if two lanyards are hooked to one another with locking snaphooks, and one end is connected to a safety line and the other to a harness, the snaphooks must be designed by the manufacturer for such use. Care should be taken to ensure that sufficient distance exists for complete fall arrest to occur.
If you need additional information, please 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