August 15, 1997

Michael T. Williams
Vertical Access Systems & Technology
1332 Wallace Road
Salem OR 97304

Dear Mr. Williams:

This is in response to your letter asking several questions about rescue work and confined spaces.

You asked if OR-OSHA views employees of a fire department rescue service differently from other rescue employees. OAR 437-02-1910.146 makes no distinction between these two classes of employees.

You asked if employees being lowered into a vat for the purposes of training or for confined space rescue would need fall protection. There is no requirement in the standard for a second line if the employee is connected to lowering equipment and wearing a body harness that meets the requirements of the standard.

However, all such equipment must be used in accordance with the manufacturer’s instructions.

Therefore, if the tripod instructions state that a second lifeline must be used, we would expect to see one in use. Your question (4) on rescue is not clear but generally some form of fall protection is required when working from heights regardless of the function being performed.

You asked about ODOT employees or others needing fall protection while suspended to inspect bridges. The answer would depend upon how they were suspended. The use of a boatswain’s chair for such work requires a second method of fall protection while certain other methods do not.

Your last question about fall protection equipment standards can only be answered dependent upon what type of system is in use. Varying standards require equipment to meet stated design or performance standards. These vary from standard to standard.

Sincerely,

Marilyn K. Schuster, Manager
Standards & Technical Resources Section
Oregon Occupational Safety & Health Division

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