Retracting lifelines and construction fall protection

June 19, 1984

J. Nigel Ellis, Ph.D., CSP
President
Research & Trading Corporation
[Recipient address omitted]
Dear Dr. Ellis:

This is in response to your letter of May 24, 1984, requesting consideration of your RTC-2700 Series Retractalok devices as meeting the intent of the Occupational Safety and Health Administration (OSHA) Fall Protection Standards.

OSHA's standard 29 CFR 1926.104 calls for 5400-pound and 3/4- inch manila or l/2 inch nylon lifelines where free falls of six feet are anticipated. However, you state that the RTC-2700 Series Retractalok is designed to limit falls to inches, thereby avoiding the severe shock-loading of a six-foot fall impact.

Assuming that the device will function as indicated in your Lehigh University Test Report dated August 5, 1982, a lifeline break strength of 3000 pounds would be satisfactory for the units. The units, when used according to the manufacturer's 1983 revised instructions, do meet the intent of OSHA's regulations.

If you have further questions, please feel free to contact Mr. John B. Miles, Jr., Director, Directorate of Field Operations.

Sincerely,
Patrick R. Tyson
Deputy Assistant Secretary

[Requester letter reproduced on OSHA page; omitted here.]

January 17, 1983

J. Nigel Ellis, Ph.D.
President
Research and Trading Corporation
[Recipient address omitted]

Dear Dr. Ellis:

This is in response to your recent inquiry requesting an interpretation of 29 CFR 1926.104.

29 CFR 1926.104 requirements for life-lines do not specifically regulate the manufacture of equipment such as your RTC-2700 series Retractalok. However, section 1926.104 does regulate the installation and use of lanyard equipment.

The units, when used in accordance with the manufacturer's 1982 revised instructions, appear to meet the intent of the Occupational Safety and Health Act.

If I may be of further assistance, please feel free to contact me.

Sincerely,
John K. Barto
Chief, Division of Occupational
Safety Programming