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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.
September 21, 2007
Mr. Terry S. Folk
E.S. Wagner Co.
840 Patchen Road
Oregon, Ohio 43616
Re: Whether it is permissible to anchor a fall arrest system at an employee's feet
Dear Mr. Folk:
This is in response to your letter dated May 22, 2006, to the Occupational Safety and Health Administration (OSHA) in which you ask for an assessment of the validity of a manufacturer's claims about its fall arrest lanyard. You also assert that you believe it is not possible to meet OSHA fall protection requirements when the anchor point for a fall arrest system is at the employee's feet (that is, on the same level as the walking working surface). We apologize for the long delay in responding.
We have paraphrased your question as follows:
Question: Do the new "Ironman" and "Ironman Plus" brand lanyards comply with OSHA requirements?
Answer: OSHA is generally precluded from approving or endorsing specific products and generally does not conduct engineering assessments of products. Thus, we will not comment about the accuracy of the performance specifications claimed by the manufacturer of the Ironman and Ironman Plus lanyard systems. In this regard, we suggest that you contact the manufacturer to request details about the basis of its claims (for example, you could ask if the product was tested by an independent laboratory).
In addition, you mention in your letter that "attaching your lanyard at your feet is not an accepted practice nor does this practice normally meet OSHA's minimum protection requirements in a fall." OSHA requirements do not specifically prohibit an employer from anchoring a lanyard at or near an employee's feet. Instead, OSHA standards require that a personal fall arrest system be rigged such that an employee cannot free fall more than 6 feet, or contact any lower level. Title 29 CFR 1926.502(d)(16)(iii) states:
Personal fall arrest systems, when stopping a fall, shall:
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(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8m), nor contact any lower level.
We recognize both that anchoring at the employee's feet typically would result in exceeding a 6-foot free fall and that there are situations where compliance with the 6-foot free fall limitation is infeasible. OSHA elaborated on this issue in a January 13, 2000 interpretation letter to Mr. Peter G. Chaney of the Mechanical Contractors Association of America, Inc. The letter discusses the requirements for limiting fall arrest distances and states:
. . . [U]nder §1926.502(d)(16)(iii), a personal fall arrest system must limit an employee's free fall to not more than six feet. "Free fall" is defined in the standard as "the vertical displacement of the fall arrest attachment point on the employee's ... body harness between onset of the fall and just before the system begins to apply force to arrest the fall." If a 6-foot lanyard is rigged to an anchorage at floor level, the total free fall would be the sum of the vertical distance between the attachment point on the body harness and the floor (usually 4 to 4½ feet) plus the length of the lanyard (6 feet in this example), which totals about 10 feet. That means that the use of a 6-foot lanyard, rigged to an anchorage at the worker's feet would result in a free fall in excess of the 6-foot limit. That would only be allowed where the employer cannot provide a more suitable anchorage or other form of fall protection.
In a situation where limiting the free fall to 6 feet is infeasible,1 the employer would be required to limit the free fall to the extent possible and to ensure that the arresting force would not exceed 1,800 pounds (see §1926.502(d)(16)).
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.
Steven F. Witt, Director
Directorate of Construction
1 In many situations, the issue of fall distances can be eliminated altogether by using a restraint system that prevents the worker from stepping past the unprotected sides or edges of a walking/working surface. In lieu of a standard six-foot lanyard, retractable lanyards with inertia reels are another option that could be used to limit an employee's fall distance. [ back to text ]