- Standard Number:
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.
October 23, 2012
204 Manuel Court
Bay Point, CA 94565
Dear Mr. Medina:
Thank you for your May 29, 2012, fax to the Occupational Safety and Health Administration (OSHA) Directorate of Construction. You have a specific question regarding the compatibility of fall protection equipment from different manufacturers. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence. Your question has been paraphrased below.
Question: Does OSHA permit employers to use a harness from one manufacturer in conjunction with a lanyard from another manufacturer if one of the manufacturers states that its equipment is designed to be used only with components and subsystems from that manufacturer?
Response: Section 1926.502 "Fall protection criteria and practices" states in, in relevant 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 items listed in (i)-(v)].
As OSHA explained in the Hill Letter of Interpretation, individual components in a personal fall arrest system may be made by different manufacturers as long as they meet the compatibility requirements listed in 29 CFR 1926.502(d)(5). OSHA's non-mandatory guidelines for complying with Section 1925.502(d) are provided in Appendix C to Subpart M of Part 1926. Section II of Appendix C contains non-mandatory guidelines for personal fall arrest systems, and paragraph (c) provides the following guidance regarding compatibility determinations:
(c) Component compatibility considerations. Ideally, a personal fall arrest system is designed, tested, and supplied as a complete system. However, it is common practice for lanyards, connectors, lifelines, deceleration devices, body belts and body harnesses to be interchanged since some components wear out before others. The employer and employee should realize that not all components are interchangeable. For instance, a lanyard should not be connected between a body belt (or harness) and a deceleration device of the self-retracting type since this can result in additional free fall for which the system was not designed. Any substitution or change to a personal fall arrest system should be fully evaluated or tested by a competent person to determine that it meets the standard, before the modified system is put to use.
An employer should take into consideration a manufacturer's statement of compatibility when determining if fall arrest components are compatible. If a fall protection equipment manufacturer's manual states that its equipment is designed only to be compatible with its own components and subsystems, an employer must be able to demonstrate that the components of a fall arrest system produced by different manufacturers are, in fact, compatible with each other, as required by 1926.502(d)(5).
Please note that California administers its own OSHA-approved state plan, which is required by law to have a program of standards and enforcement that is at least as effective as the Federal OSHA requirements. However, it may enact more stringent requirements. Employers in a state with an OSHA-approved state plan must follow that state's more stringent requirements. For specific information on California's interpretation and enforcement policy with regard to this issue, please contact:
California Department of Industrial Relations
Division of Occupational Safety and Health
1515 Clay Street Suite 1901
Oakland, California 94612
PH: (510) 286-7000
FAX: (510) 286-7037
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction