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• Standard Number: 1926.502

January 30, 1996

Ms. Jodie R. Helland
Co-Director, Kenguard Systems
Route 5 Box 190 Hwy. 178
Chippewa Falls, Wisconsin 54729

Dear Ms. Helland:

This is in response to your November 7, 1995, letter requesting a letter of compliance from the Occupational Safety and Health Administration (OSHA) for your Kenguard System.

As discussed with Mr. Dale Cavanaugh of my staff, OSHA does not endorse products or issue formal certificates of approval for products or practices. However, when provided with adequate information, we can offer an opinion as to whether or not a product affords compliance with certain regulations. We have reviewed the pictures and product data accompanying your letter and although you did not provide any engineering test data, it appears that if the Kenguard System is properly installed it would meet the applicable fall protection equipment criteria in 29 CFR 1926.502.

Please note that when wire rope is used as the top rail of a guardrail system, the wire rope cannot deflect below 39 inches above the working level when loaded with a 200 pound test weight. This can often be achieved by looping or clamping the wire rope at the posts. Otherwise, when a worker bumps or falls into the rail, the slack that is in the top rail would all be pulled towards the contact point and the worker would not be restrained.

If we can be of any further assistance, please contact the Directorate of Construction at (202) 219-7207.

Sincerely,



Roy F. Gurnham, P.E., J.D.
Director
Office of Construction Services
Directorate of Construction




November 7, 1995

Roy F. Gurnham, P.E., J.D.
200 Constitution Ave. Northwest
Washington D.C. 20210

Mr. Gurnham:

My name is Jodie Helland, I am the co-director of Kenguard Systems., LLC. Yesterday I spoke with your associate, Mr. Dale Cavanaugh, regarding the request of a letter of compliance.

Enclosed you will find pictures of our product and the results of tests to which we subjected the rafter posts. Also, a copy of our brochure is included for your consideration.

I appreciate your attention in this matter. I believe I have sent sufficient information, however, if I can be of any assistance, please call me at (715) 382-5102.

Sincerely,



Jodie R. Helland



November 7, 1995

Roy F. Gurnham, P.E., J.D.
200 Constitution Ave. Northwest
Washington D.C. 20210

Re: Testing of the KenGuard System

Dear Mr. Gurnham:

In February of 1995, N-Tech Manufacturing in Barron, Wi., set up testing on site. The rafter post was exposed to 700 pounds of direct pressure before showing signs of stress. A follow up test was performed at one of our job sites, while the posts were set up as they are to be used. Using an electronic weight scale, the cable was tested in the middle of the twenty-five foot span. Digital read out held to 1026 pounds of pressure before one post began to bend. We believe the bending of the post is secondary, as the cable is the lifeline and is rated to 9000 pounds, also, the purpose of the posts is to keep a man from hitting the ground (concrete) which bending has no real effect.

Our Guardrails only need to withstand 200 pounds of pressure, which, since they are made of the same high tinsel steel, this is not an issue.

We believe we meet and/or exceed the necessary OSHA standard 1926.500 for Guardrails and Handrails. I think it has the capacity to prevent accidents and save lives. Once again, I would like to thank you for your time, and in the case of questions give you my phone number-(715) 382-5102.

Sincerely,



Jodie R. Helland


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