Positioning hook for concrete formwork under proposed rule

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 13, 1993

Mr. James D. Miller
Safety Director
J.E. Dunn Construction Company
[Recipient address omitted]
Dear Mr. Miller:

This is in response to your May 13 letter in which you request the Occupational Safety and Health Administration (OSHA) to comment on the design and use of positioning hook on concrete I apologize for the delay in responding to your inquiry.

OSHA currently has no construction standards that apply to positioning devices. As you know, to address this type of equipment, OSHA issued a Notice of Proposed Rulemaking for Subpart M -- Fall Protection on November 25, 1986 (51 FR 42718). In the notice (copy of relevant pages are enclosed) it was proposed to require positioning device connecting assemblies to have a minimum tensile strength of 5000 pounds. That rule was intended to ensure that if a positioning device component is used in a body belt/harness system, it would have the proper capacity to handle the larger impact forces. That rule has not been finalized and comments to the record indicate that lower capacity hardware (down to at least twice the potential impact load) should be allowed if the hardware is clearly marked or attached to the positioning device system in such a way that it cannot be used in a body belt/harness system where greater forces are likely to occur. If your equipment meets this concern, then it would meet the intent of the proposed rule.

If you need further assistance, please don't hesitate to contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,
Roy F. Gurnham, P.E., Esq. Director
Office of Construction and Maritime
Compliance Assistance

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