|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.|
November 9, 1998
Mr. Michael T. Williams
Vertical Access Systems and Technology
2428 Whetstone Court
Salem, Oregon 97304
Re: 29 CFR 1926.500, 1926.501(a)(2), 1926.502(d); descent control devices,
figure eights, racks, Sky Genies
Dear Mr. Williams:
This is in response to your February 19, 1997, letter addressed to Mr. Roy Gurnham (former Director of Construction Standards and Compliance Assistance) asking whether there are OSHA requirements regarding the use of descent control devices in construction. I apologize for the long delay in providing this response.
Currently, the Occupational Safety and Health Administration (OSHA) has no specific rules governing the use of descent control devices. However, 29 CFR 1926.501(a)(2) requires that working surfaces must have "the strength and structural integrity to support employees safely. . ." Also, §1926.20(b)(4) and §1926.21(b)(2) require that employees be trained to properly use such equipment.
As you are aware, OSHA policy regarding use of such equipment has been previously stated in a memorandum on the subject dated March 12, 1991, and in an interpretation letter dated October 23, 1992. The policy described in those documents governing the use of these devices, summarized below, remains in effect, except that body belts cannot be used as part of the personal fall arrest system (see 29 CFR 1926.502(d)).
To ensure that descent control devices have the requisite strength and structural integrity when used in construction, employers must:
If you require any further assistance, please do not hesitate to contact us again by [fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-2020. 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.]
- Train employees in the use of the equipment before it is used;
- Inspect equipment each day before use;
- Properly rig the equipment. In all cases use sound anchorages and tiebacks. Particular care must be taken to provide tiebacks when counterweights, cornice hooks, or similar nonpermanent anchorage systems are used;
- Ensure that all lines installed (with knots, swages, eye splices, or similar methods) when rigging descent control devices are capable of sustaining the tensile loads imposed. A tensile load strength of 5,000 pounds is considered adequate.
- Ensure that ropes are effectively padded where they contact edges of the building, anchorage, obstructions, or other surfaces which might cut or weaken the rope;
- Provide for intermittent stabilization for descent in excess of 130 feet (this is recognized by the industry as an important safety capability for this type of system);
- Protect employees using descent control devices from falls in accordance with 1926.502(b). Therefore, a separate fall arrest system (full body harness with rope grab or similar device; lifeline; and anchorage) must be used. All components of the fall arrest system must be completely independent of the friction device and its support system so that any failure in a friction device, support seat (or harness), support line, or anchorage system of the descent control device will not affect the ability of the fall arrest system to operate and quickly stop the employee's fall;
- Provide for prompt rescue under 1926.502(d)(20) of employees in the event of a fall or assure that employees are able to rescue themselves.
Russell B. Swanson, Director
Directorate of Construction