March 13, 1996
Mr. David H. Kieper
Colorado Rural Electric Association
1313 West Forty-sixth Avenue
Denver, Colorado 80211
Dear Mr. Kieper:
This is in response to your April 19, 1995 letter To Mr. David Herstedt in the Denver Regional
Administrator's Office of the Occupational Safety and Health Administration (OSHA). Your letter
was forwarded the this office for response. Please accept our apology for the delay in responding.
Your questions and our replies follow.
Question 1: Will OSHA require locking type snaphooks on pole strap systems used by linemen
after 1 January 1998?
Reply: No. However, a pole strap used as part of a work positioning system must meet
the snaphook keeper design requirements under paragraph 1926.959(d)(6). No
change in this requirement is anticipated by the deadline you identified.
A pole strap used as part of a fall arrest system must meet, in addition to other
applicable requirements, paragraph 1926.502(d)(5) which permits only locking
snaphooks as of January 1, 1998.
Question 2: Rural electric cooperatives are connecting electrical service to a consumer's home
and have no option but to climb on the consumer's roof and install electric line
attachments. None of the conventional means of fall protection (guardrails,
personal fall arrest systems, or safety nets) can be used because we do not believe
our customers would agree to the installation of an anchorage on their roofs. How
would an employer best address this issue to provide from employee safety and
comply with OSHA regulations?
Reply: The fall protection requirements under paragraph 1910.269(g) do not apply to the
type of work application you describe. (See Note 1 following paragraph
1910.269(g)(2)(v)) However, the fall protection requirements under paragraph
1910.23(c)(1) do apply to such a workplace application. Where the guardrails
required under that paragraph are infeasible, an employer must use alternative
means of protection.
An employer who follows the interim fall protection
compliance guidelines for residential construction contained in OSHA Instruction
STD 3.1 dated December 8, 1995 will be deemed to be in compliance with the
paragraph 1910.23(c)(1) fall protection requirements when applicable to work on
residential roofs where conventional means of fall protection cannot be used. A
copy of STD 3.1 is enclosed for your use.
[This document was edited on 12/5/2012 to strike information that no longr reflects current OSHA policy.]
Question 3: Can a harness be used in place of the body belt for aerial lift fall protection
required under paragraphs 1910.67 and 1926.556? Also, will either a body belt or
a harness be allowed for aerial lift fall protection after January 1, 1998?
Reply: A harness may be used in place of a body belt for aerial lift fall protection required
under paragraphs 1910.67(c)(2)(v) and 1926.556(b)(2)(v). The deadline of
January 1, 1998 is applicable only to the prohibited use of a body belt as a
component of a personal fall arrest system covered by Subpart M of Part 1926-The
Safety and Health Regulations For Construction.
We appreciate your interest in employee safety and health. If we can be of further assistance,
please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202)
219-8031, extension 110.
John B. Miles, Jr., Director
Directorate of Compliance Programs