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.


November 26, 2007

Mr. Grant J. Sanford
7151 Wilson Cr. Rd.
Ellensburg, WA 98926

Re: Whether the "Clear Gear Lanyard Elevator" conforms to OSHA construction standards.

Dear Mr. Sanford:

This is in response to your letter dated July 3, 2007, to the Occupational Safety and Health Administration (OSHA). In your letter, you request that OSHA determine whether the Clear Gear Lanyard Elevator device complies with OSHA construction standards. We apologize for the delay in responding.

We have paraphrased your questions as follows:

Question (1): The Clear Gear Lanyard Elevator is a device that is designed to gather and elevate a fall arrest lanyard above tools and tool bags to prevent the lanyard from becoming entangled with them. Does OSHA approve the use of this device?

Answer (1): OSHA is generally precluded from approving or endorsing specific products. The variable working conditions at job sites and possible alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the equipment manufacturer. However, where appropriate, we try to give some guidance to help employers assess whether products are appropriate to use in light of OSHA requirements.

Question (2): Is the Clear Gear Lanyard Elevator in conformance with OSHA construction standards?

Answer (2): The Code of Federal Regulations at 29 CFR 1926.502(d) sets out the requirements for personal fall arrest systems.1 None of those provisions specifically address a device such as the one you are asking about. As long as the use of the device does not prevent any of the fall arrest components, or system as a whole, from meeting the requirements in §1926.502, the device would be in conformance with the OSHA construction standards.2

In addition, please note that there are States that administer their own OSHA-approved State plans. Federal law requires such States to have a program of standards and enforcement that is at least as effective as federal OSHA requirements. These States may enact more stringent requirements than federal OSHA requires. Employers in States with OSHA-approved state plans are required to follow the State plan.

The State of Washington administers an OSHA-approved State plan. You may contact them at:


Washington Department of Labor and Industries
PO Box 44001
Olympia, Washington 98504-4001



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 You can find 29 CFR 1926.502(d) at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10758#1926.502(d) [ back to text ]





2 We do not have the resources to undertake an analysis of your device in this regard.[ back to text ]