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.

March 8, 2002



Mr. Gus Strats
President
Summit Anchor Company
5406 Duke Court
Frederick, MD 21703

Dear Mr. Strats:

Thank you for your April 30, 2001 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions-not delineated within your original correspondence. You had a question regarding an equipment tie back and lifeline tied off to the same anchoring point.

Please accept our apology for the delay in responding to your letter. However, as you were advised by telephone, the response to your letter required extensive research, and several levels of departmental review, including legal analysis.

Question 1: In General Industry, does OSHA allow window cleaners to simultaneously tie off the equipment tie back and lifeline to the same anchorage point?

Reply: Although OSHA does not have a specific General Industry standard that addresses anchorages for equipment tie-backs and lifelines, there is a general requirement for personal protective equipment at 29 CFR 1910.132. Section 1910.132(c) states that “personal protective equipment shall be of safe design and construction for the work to be performed.” Because the standard does not contain equipment specifications, OSHA would evaluate an employer's compliance with the requirement by consulting other sources of relevant information on safe design and construction. In the context of window cleaning, one such source would be the recently published ANSI I-14.1-2001, which, at section 9.1.3, permits the simultaneous use of an anchorage as an equipment tie-back and lifeline anchorage if it is “capable of supporting the anchorage load factor multiplied by the combo of the fall arrest load and the tie-back load.”

Thank you for your interest in occupational safety and health. We hope you find this helpful. 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. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,


Richard E. Fairfax, Director
Directorate of Compliance Programs