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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.
DOL-OSHA-DEP-2020-005 - This document does not have the force and effect of law and is not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
May 21, 2020
Mr. Stefan Bright
International Window Cleaning Association
7918 Jones Brunch Drive, Suite 300
McLean, Virginia 22102
Dear Mr. Bright:
This is in response to a letter to the Occupational Safety and Health Administration (OSHA) from International Window Cleaning Association's past-president Jason York, requesting clarification of the OSHA standard at 29 CFR § 1910.27(b), Rope descent systems, as it may apply to the Industrial Rope Access Systems (IRAS). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. Your paraphrased questions and our responses are below.
Question 1: If an industrial rope access system is used on a building in a manner which allows a worker to descend in a controlled manner and, as needed, stop at any point during the descent to perform work, then will it be considered by OSHA to be a rope descent system (RDS) as defined in 29 CFR § 1910.21(b)?
Response 1: No. Under 29 CFR § 1910.21(b), RDS means “a suspension system that allows an employee to descend in a controlled manner and, as needed, stop at any point during the descent. A rope descent system usually consists of a roof anchorage, support rope, a descent device, carabineer(s) or shackle(s), and a chair (seat board). A rope descent system also is called controlled descent equipment or apparatus. Rope descent systems do not include industrial rope access systems.” The definition for RDS clarifies that rope descent systems do not include IRAS. As such, 29 CFR § 1910.27(b) does not cover or apply to IRAS. However, other OSHA fall protection standards, including 29 CFR §§ 1910.28, 1910.29, 1910.30, 1910.140 apply to IRAS, and IRAS anchorage requirements are covered under 29 CFR §§ 1910.140(c)(12), 1910.140(c)(13) through 1910.140(c)(13)(ii).
Question 2: Do identification and certification requirements for anchorages under 29 CFR § 1910.27(b) apply to building owners or employers when IRAS are used on a building to perform work in the same manner that an RDS would be used?
Response 2: No. The requirements contained in 29 CFR § 1910.27(b), including the identification and certification requirements for anchorages, do not apply to IRAS.
Thank you for your interest in occupational safety and health. We hope that 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 interpretations 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 any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs