Standard Interpretations - Table of Contents
• Standard Number: 1910.66 App C; 1926.502(d)

September 2, 1999

Mr. Jason B. White
Elk River, Inc.
P.O. Box 1767
Cullman, AL 35056-1767

Dear Mr. White:

Thank you for your July 26, 1999 letter to Charles N. Jeffress, Assistant Secretary, Occupational Safety and Health Administration. Your questions on personal fall arrest systems have been referred to the Directorate of Compliance Program's (DCP's) Office of General Industry Compliance Assistance. Your specific question has been restated below for clarity.

Question. If a product fully complies with the dynamic strength and dynamic performance tests defined in 29 CFR §1910.66 Appendix C Section I and Appendix C of 29 CFR §1926 Subpart M, would that product be considered to be in compliance with OSHA regulations, if the ultimate breaking strength was less than the 5,000 pound requirement?

Response. Lanyards and vertical lifelines which tie-off an employee must have a minimum breaking strength of 5,000 pounds. In addition, self-retracting lifelines and lanyards which do not limit free fall distance to two feet or less, ripstitch lanyards, and tearing and deforming lanyards must have a minimum tensile load capacity of 5,000 pounds. The rationale for the 5,000 pound tensile strength is due to such factors as the uncertainty of measuring arresting forces in addition to the degradation of equipment due to dirt, light, and misuse. Therefore, if the product does not meet these tensile strength requirements, then it would not be in compliance with the applicable OSHA standard.

As a general rule, OSHA does not test products, issue formal certificates of approval for products or practices, or endorse products used in the