Standard Interpretations - Table of Contents
• Standard Number: 1926.502; 1926.502(d)(3); 1926.502(d)(4)

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.

September 30, 2010

Letter #20100427-9737

Re:  Whether OSHA will rely on ANSI Z359.1-2007, regarding snaphook compressive strength requirements, in enforcing the general duty clause with respect to personal fall arrest systems in construction, as announced in letter #20070920-8088.

Question:  Will OSHA rely on the increased minimum gate compressive strength requirements in ANSI Z-359.1-2007, §§ 4.3.1.1.2 & 4.3.1.1.3 in enforcing the general duty clause with respect to snaphooks, including carabiners, on personal fall arrest systems used in construction?

Answer: No. OSHA is rescinding letter #20070920-8088.

Before discussing the reasons for rescinding this letter, an initial explanation as to why OSHA is referring to ANSI standards is necessary. The construction fall protection standard provides that snaphooks (which, as defined in the standard, includes carabiners) used in personal fall arrest systems must have a minimum tensile strength of 5,000 pounds and must be proof-tested to a minimum tensile load of 3,600 pounds without