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 https://www.osha.gov.

June 6, 1980

Mr. Jack Buchanan
Director, Safety Services
Kansas Gas and Electric Company
P.O. Box 208
Wichita, Kansas 67201

Dear Mr. Buchanan:

This is in response to your request which was forwarded from our Wichita Area Office concerning the use of your slip on tool hook.

It is our interim opinion that your tool hook does not meet the requirements of 29 CFR 1926.951(b)(2). Since this tool hook is in direct contact with the lineman's body, there could be a danger of electrical shock. As stated in 29 CFR 1926.951(b)(2), "the cushion part of the body belt shall contain no exposed rivets on the inside." This also would mean that no metal parts at all should be exposed on the inside of the belt.

A copy of your correspondence and picture, along with a copy of this interim response, is being sent to our National Office requesting review, concurrence, correction and/or additions as applicable. Upon receipt of a reply, we will give you a final answer.

We appreciate your concern for occupational safety and health, and if we can be of further assistance, please let us know.

Sincerely,



Charles E. Adkins
Assistant Regional Administrator
Office of Technical Support