March 13, 1996

Mr. David H. Kieper
Colorado Rural Electric Association
1313 West Forty-sixth Avenue
Denver, Colorado 80211

Dear Mr. Kieper:

This is in response to your April 19, 1995 letter To Mr. David Herstedt in the Denver Regional Administrator's Office of the Occupational Safety and Health Administration (OSHA). Your letter was forwarded the this office for response. Please accept our apology for the delay in responding. Your questions and our replies follow.

Question 1:

Will OSHA require locking type snaphooks on pole strap systems used by linemen after 1 January 1998?

Reply:

No. However, a pole strap used as part of a work positioning system must meet the snaphook keeper design requirements under paragraph 1926.959(d)(6). No change in this requirement is anticipated by the deadline you identified.

A pole strap used as part of a fall arrest system must meet, in addition to other applicable requirements, paragraph 1926.502(d)(5) which permits only locking snaphooks as of January 1, 1998.

Question 2:

Rural electric cooperatives are connecting electrical service to a consumer's home and have no option but to climb on the consumer's roof and install electric line attachments. None of the conventional means of fall protection (guardrails, personal fall arrest systems, or safety nets) can be used because we do not believe our customers would agree to the installation of an anchorage on their roofs. How would an employer best address this issue to provide from employee safety and comply with OSHA regulations?

Reply:

The fall protection requirements under paragraph 1910.269(g) do not apply to the type of work application you describe. (See Note 1 following paragraph 1910.269(g)(2)(v)) However, the fall protection requirements under paragraph 1910.23(c)(1) do apply to such a workplace application. Where the guardrails required under that paragraph are infeasible, an employer must use alternative means of protection. An employer who follows the interim fall protection compliance guidelines for residential construction contained in OSHA Instruction STD 3.1 dated December 8, 1995 will be deemed to be in compliance with the paragraph 1910.23(c)(1) fall protection requirements when applicable to work on residential roofs where conventional means of fall protection cannot be used. A copy of STD 3.1 is enclosed for your use.

Question 3:

Can a harness be used in place of the body belt for aerial lift fall protection required under paragraphs 1910.67 and 1926.556? Also, will either a body belt or a harness be allowed for aerial lift fall protection after January 1, 1998?

Reply:

A harness may be used in place of a body belt for aerial lift fall protection required under paragraphs 1910.67(c)(2)(v) and 1926.556(b)(2)(v). The deadline of January 1, 1998 is applicable only to the prohibited use of a body belt as a component of a personal fall arrest system covered by Subpart M of Part 1926-The Safety and Health Regulations For Construction.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202) 219-8031, extension 110.

Sincerely,



John B. Miles, Jr., Director
Directorate of Compliance Programs