August 28, 1995

Mr. J. Nigel Ellis
President
Dynamic Scientific Controls
P.O. Box 445
Wilmington, Delaware 19899-0445

Dear Mr. Ellis:

This is in response to your letter of April 4 to the Occupational Safety and Health Administration (OSHA) in which you expressed your concerns with Appendix C, Paragraph 1.(b)(3), in the 29 CFR 1926.500-503 fall protection standards, which states that the frequency response of the load measuring system when testing fall arrest equipment should be set at 500 Hz.

We agree that 100 Hz is more appropriate and would be consistent with other current American (ANSI Z359.1-1192) and Canadian (CSA Z259.11-M92) standards. Since Appendix C of the fall protection standards is a non-mandatory appendix, no citations will be issued if 100 Hz is used instead of 500 Hz for the frequency response of the load measuring system when testing fall arrest equipment.

We have provided our standards-setting personnel with a copy of your letter for possible adjustment of the appendix.

If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.

Sincerely,



Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance