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OSHA 1926.104

Lifelines and safety belts requirements

1926 Subpart E

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.104(a), when must a lifeline, safety belt, or lanyard be removed from service?

Remove a lifeline, safety belt, or lanyard immediately after it has been subjected to in-service loading; it must not be used again for employee safeguarding. This is required by 1926.104(a).

  • "In-service loading" means actual loading during use (not controlled static test loads).
  • If you are unsure whether equipment was loaded during an event (for example, a fall that was arrested), treat it as in-service loaded and remove it.

Under 1926.104(a), can lifelines, safety belts, or lanyards be used for anything other than protecting employees?

No — lifelines, safety belts, and lanyards must be used only for employee safeguarding. The rule explicitly limits their use to protecting employees under 1926.104(a).

  • Do not use these items for hoisting materials, towing, restraint of equipment, or other non-safety-personnel purposes.

Under 1926.104(b), what minimum anchorage strength is required when securing a lifeline above the point of operation?

Anchorages or structural members that secure lifelines above the point of operation must be capable of supporting a minimum dead weight of 5,400 pounds. See 1926.104(b).

  • That 5,400-pound capacity is a minimum; consider higher-rated anchorages for redundancy or additional factors such as impact forces or shock loading.

Under 1926.104(c), what type of lifeline must be used for rock-scaling or where the line may be cut or abraded?

For rock-scaling operations or where a lifeline may be subjected to cutting or abrasion, use a minimum 7/8-inch wire-core manila rope. This requirement is in 1926.104(c).

  • Wire-core manila offers better resistance to cutting and abrasion than conventional natural-fiber ropes.

Under 1926.104(c), what are the minimum requirements for lifelines used in other (non-abrasive) applications?

For lifelines in other applications, use at least 3/4-inch manila or an equivalent rope that has a minimum breaking strength of 5,000 pounds, as stated in 1926.104(c).

  • "Equivalent" means a rope material or construction with comparable performance; document how the selected rope meets or exceeds the 5,000-pound breaking strength requirement.

Under 1926.104(d), what are the minimum specifications for safety belt lanyards and the maximum allowed fall distance?

Safety belt lanyards must be at least 1/2-inch nylon (or equivalent), with a maximum length that limits a fall to no greater than 6 feet, and the rope must have a nominal breaking strength of 5,400 pounds. See 1926.104(d).

  • "Maximum length" should account for any attachments, connectors, and potential stretch so the actual free-fall cannot exceed 6 feet.

Under 1926.104(e), what are the material and plating requirements for safety belt and lanyard hardware?

All safety belt and lanyard hardware must be drop-forged or pressed steel and cadmium plated in accordance with Type 1, Class B plating of Federal Specification QQ-P-416; the surface must be smooth and free of sharp edges, per 1926.104(e).

  • Inspect hardware for burrs, sharp edges, pitting, or plating failure; any defective hardware should be removed from service.

Under 1926.104(f), what tensile strength must safety belt and lanyard hardware (except rivets) withstand?

All safety belt and lanyard hardware, except rivets, must withstand a tensile load of 4,000 pounds without cracking, breaking, or permanent deformation, as required by 1926.104(f).

  • If hardware shows any sign of permanent deformation after testing or use, it must be removed from service.

Under 1926.104(f), are rivets required to meet the 4,000-pound tensile strength requirement?

No — rivets are explicitly excluded from the 4,000-pound tensile strength requirement in 1926.104(f).

  • Even though rivets are exempt from that specific tensile test, riveted connections should still be inspected and maintained per good practice and other applicable standards.

Under 1926.104(a), if a lifeline passes a static load test but has been involved in a fall (in-service loading), can it remain in service?

No — a lifeline that has been subjected to in-service loading (such as arresting a fall) must be removed from service even if it would otherwise pass a static load test; the standard requires immediate removal after in-service loading in 1926.104(a).

  • Static tests performed in controlled conditions are not a substitute for the removal requirement after actual use in a loading event.

Under 1926.104(c) and 1926.104(d), can synthetic ropes or non-manila materials be used if they are listed as "equivalent"?

Yes — the standard allows use of "equivalent" materials in place of manila or nylon provided they meet the performance criteria (for example, minimum breaking strength), as stated in 1926.104(c) and 1926.104(d).

  • When using an "equivalent" material, document the technical basis (manufacturer data, test reports) showing it meets or exceeds the standard's strength and performance requirements.

Under 1926.104, who is responsible for determining whether a non-manila rope is an "equivalent" and suitable for lifeline use?

The employer is responsible for ensuring that any "equivalent" rope meets the standard's performance requirements and is suitable for the intended use; the standard describes the minimum specifications in 1926.104(c) and 1926.104(d). OSHA's guidance on employer responsibility for PPE selection and hazard assessment reinforces that obligation (see OSHA's PPE hazard assessment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

  • Conduct a hazard assessment and keep documentation that the chosen material meets or exceeds the stated breaking strengths and other characteristics.

Under 1926.104, does the standard specify how often lifelines, belts, and lanyards must be inspected?

No — 1926.104 sets equipment performance and removal-after-use rules but does not prescribe a specific inspection interval; employers must therefore implement an appropriate inspection and maintenance program consistent with the standard's requirements and their hazard assessment. See 1926.104(a) and OSHA's PPE hazard assessment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 for employer responsibilities.

  • Best practice: perform a pre-use visual inspection by the user before each shift and periodic detailed inspections by a competent person; remove any equipment that has been subjected to in-service loading or shows signs of damage.

Under 1926.104(b), does the lifeline anchorage have to be located above the point of operation?

Yes — lifelines must be secured above the point of operation to an anchorage or structural member that meets the minimum capacity specified in 1926.104(b).

  • "Above the point of operation" reduces potential fall distances and swing hazards compared with anchorages located below the worker.

Under 1926.104, can lifelines used on suspended conveyances or scaffolds be subject to the same lifeline requirements, and where can I find OSHA guidance about when a conveyance is treated as a suspended scaffold?

Yes — lifelines used on suspended conveyances or suspended scaffold configurations are subject to applicable lifeline and fall protection requirements, and OSHA has clarified that certain conveyances meet the definition of a suspended scaffold (therefore bringing scaffold fall protection rules into play). See the OSHA interpretation on suspended scaffolds at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05 and refer to 1926.104(b)-(f) for lifeline, lanyard, and hardware requirements.

  • If a conveyance is a suspended scaffold, also follow the scaffold fall protection requirements applicable to that operation (see the cited interpretation for details).

Under 1926.104(d), does the "no greater than 6 feet" fall limit for lanyards refer to the lanyard length alone or to the fall distance the worker could experience?

The "no greater than 6 feet" limit in 1926.104(d) refers to the fall the worker could experience — employers must use lanyards whose maximum effective length (including attachments and predictable stretch) limits the fall to 6 feet or less.

  • When planning, account for connector lengths, harness D-ring location, lanyard stretch, and any slack to ensure the actual free-fall does not exceed 6 feet.

Under 1926.104(e), are sharp edges on safety belt or lanyard hardware acceptable?

No — hardware surfaces must be smooth and free of sharp edges under 1926.104(e).

  • Sharp edges can cut webbing, rope, or cause user injury; inspect hardware and replace any pieces with burrs, nicks, or corrosion that create sharp areas.

Under 1926.104(f), what should an employer do if safety belt or lanyard hardware fails the 4,000-pound tensile capability test?

If hardware (other than rivets) cannot withstand a tensile load of 4,000 pounds without cracking, breaking, or permanent deformation, it must be taken out of service and replaced; this is required by 1926.104(f).

  • Do not use suspect or failed hardware for employee safeguarding; document test results and corrective actions.

Under 1926.104(c), when should a wire-core manila rope be chosen over a standard 3/4-inch rope?

Choose 7/8-inch wire-core manila rope for lifelines when the operation involves rock-scaling or any area where the lifeline may be subjected to cutting or abrasion, as specified in 1926.104(c).

  • Use wire-core where surface hazards (sharp rock, edges, abrasive structures) could damage ordinary fiber ropes.

Under 1926.104, can lifelines and safety belts be reconditioned or repaired after being loaded in service or showing damage?

No — any lifeline, safety belt, or lanyard that has been subjected to in-service loading must be removed from service and cannot be returned to employee use; additionally, items showing damage should be removed and replaced, per 1926.104(a).

  • For damaged but not in-service-loaded equipment, follow manufacturer guidance; if repairs are allowed by the manufacturer and restore original specifications, document the repair and requalification before returning to non-life-safety uses if permitted — but do not return to employee fall protection use unless the manufacturer explicitly approves and the repair meets the original standard requirements.

Under 1926.104, if I select an "equivalent" plating or metal for hardware instead of cadmium plating, what must I be able to demonstrate?

You must be able to demonstrate that the alternate hardware material or plating provides equal or better corrosion resistance and performance and that the hardware still meets the mechanical requirements (smooth surfaces and tensile capability) stated in 1926.104(e) and 1926.104(f).

  • Keep manufacturer data, test reports, or engineering justification showing equivalency to the Federal Specification plating performance and that hardware will withstand the required loads without defect.