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.

October 1, 1992

Matthew V. McFarland
Safety Specialist
Safety and Health Management
Consultants, Inc.
161 William Street
New York, New York 10038

Dear Mr. McFarland:

Your letter of September 9 to Ms. Dorothy Strunk, Acting Assistant Secretary of Labor, requesting an interpretation of an Occupational Safety and Health Administration (OSHA) standard addressing body belts and pole straps used for climbing wooden power transmission poles has been referred to this office for response.

OSHA has adopted the position that a positioning device may be used for fall protection when an employee is climbing a wood pole as well as when the employee is working at specific locations on the pole. This is because the short strap length in a typical system precludes the employee from free falling a sufficient distance that could cause damage to the system. It functions more or less like a tether, significantly reducing impact loading. It thus can provide appropriate fall protection. Fall arrest systems are those designed to arrest a free falling employee. Because such systems are subject to considerable impact forces, there are stringent guidelines for their manufacture and use. We believe this is what the manufacturer means to say on the instructional tags. However, you may wish to contact the manufacturer yourself to determine the exact nature of the instruction.

If we can be of any further assistance, please contact Roy F. Gurnham or Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance on (202) 219-8136.

Sincerely,



Roger A. Clark,
Acting Director
Directorate of Compliance Programs