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.

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 workplace. However, manufacturers who choose to establish compliance with OSHA standards, may use other methods such as self-certification, certification by an independent third party (a registered professional engineer who has demonstrated knowledge of the standard's requirements), or testing by a recognized testing laboratory.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,

Richard Fairfax, Director
Directorate of Compliance Programs