Safety net at open hatches as fall protection

April 15, 1994
Mr. Roger Dargie
President
Safe Approach Inc.
[Recipient address omitted]
Dear Mr. Dargie:
This is in response to your February 7 letter requesting Occupational Safety and Health Administration (OSHA) acceptance of the Hatch Net 120 fall protection system. I apologize for the delay in responding to your inquiry.
As you know, OSHA neither approves nor endorses products. The variable working conditions at jobsites and possible alterations, misuse, or misapplication of an otherwise safe product could easily create a hazardous condition beyond the control of the manufacturer. However, this office and the Office of General Industry Compliance Assistance (GICA) have reviewed the product data enclosed with your letter and it appears that if the Hatch Net 120 fall protection system is used as intended, it would provide an effective means for preventing falls through open hatches.
Current OSHA standards addressing hatch openings require the use of guardrail systems, covers, or monitors. Your product, if used in addition to the required protection, would afford valuable additional safeguarding at hatch openings and would improve employee protection. In addition, it appears that your product would provide acceptable alternative fall protection for hatch openings when the protection required by the standards is not feasible.
Specific requirements for nets used as fall protection systems have been proposed for both general industry and construction work areas (copies enclosed). Nets meeting these proposed rules will be deemed in compliance with OSHA's safety net standards.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136, or Mr. Rollie Stroup of the GICA staff at (202) 219-8031.
Sincerely,
Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance
Enclosures

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