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.
May 26, 1992
Mr. Steve Nichols President
American Roof
21808 NE. 175th
Woodinville, Washington 98072
Dear Mr. Nichols:
This is in response to your May 11 letter reguestlng a letter of compliance from the Occupational Safety and Health Administration (OSHA) for your Super Anchor Fall Arrest Bracket and Super Anchor Fall Restraint Safety Nail.
As you know, OSHA does not approve nor endorse products. The variable working conditions at jobsites and possible alterations or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. However, we have reviewed the product data enclosed with your letter and it appears that if the Super Anchor Fall Arrest Bracket and Safety Nail are properly installed and maintained, the user would be in compliance with Federal OSHA's fall arrest anchoring reguirements.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 523-8136.
Sincerely,
Roy F. Gurnham, P.E., Esq. Director
Office of Construction and Maritime
Compliance Assistance