OSHA Letter of Interpretation

concerning the use of Wishbone TM; to belt off to an adjacent structure while on an aerial lift that requires belting off to the aerial lift. The excerpt (text in italics with emphasis by ed. ) reads as follows , "However, limited situations may exist where an adjacent structure poses no reasonably foreseeable risk of failure . For example, such an instance might arise where the adjacent structure is a completed building or a completed (i.e., fully bolted-up) skeletal steel structure. In those instances, OSHA would consider the violation of §1926.453(b)(2)(iii) to be de minimis² and no citation would be issued ." To view the OSHA letter of interpretation in its entirety go to: http://www.osha.gov see interpretations dated 02/02/04. For additional information, see letters of interpretation dated 05/03/01 " Use of Aerial Lifts to Transport workers to Elevated work stations and the letter of interpretation dated 02/23/04 "Permissibility of attaching welding leads to an occupied aerial lift bucket and using an external lifeline to anchor fall arrest equipment."

De minimis²- under OSHA's de minimis policy, de minimis violations is those, which have no direct or immediate relationship to safety or health.


Product Specifications
  • Capacity: 310lbs. maximum personnel load including equipment.
  • Length : overall 14 inches.
  • Weight : 1 pound 9 ounces.
  • Ultimate breaking strength: 5000 pounds.

A safety representative for the Company (user) to determine usability shall inspect the Wishbone TM units at least once a year (annual). A record by unit serial number of such inspections shall be maintained by the Company for each unit inspected to include time in service and any items noted, condition of unit and if removed from service the reason for removal. The user shall make a daily inspection each day before use and any time during the day thereafter it is prudent to do so.

Daily Inspection

Prior to each daily use and any time conditions warrant the user shall perform the following inspections:
  • Check general condition and security of webbing and attachments.
  • Check that stainless slide pin is engaged through the nylon loop and into the aluminum tube retainer.
  • Check webbing for distortions, heating, burns, discoloration, fraying, staining, fading, wear, frayed or broken stitches.
  • Check hardware for wear, cracks, separation, looseness, and proper function of double locking snap hooks.
  • Check that three interlocking rings are properly connected and that the slide pin is engaged through the nylon loop and the retaining tube. (see Fig. "1")
  • Check the torque stripe on the hinge for cracking. If the torque stripe is cracked indicating separation of the hinge this means that the hinge will release at a value of less than 200lbs. (+-5%) (see Fig. "2") (this is not a serious condition indicating only that the hinge may release with less than 200lbs. force applied between connections "B" and "C" see Fig."3")
Upon conducting this daily inspection any questions or uncertainty regarding the condition of the unit or items found on this inspection or issues regarding suitability for use, should be directed to your supervisor and/or Company safety officer. The unit may be returned to the manufacturer for inspections at a nominal charge, when in doubt.

Uses and Limitations
  • Wishbone TM PERTS shall not be used to lift/suspend personnel or loads.
  • Wishbone TM is limited to a maximum load of 325lbs.
  • Wishbone TM has a suggested service life of 5 years from date of manufacture or on condition by inspection.
  • Wishbone TM lanyard and all of its components must be removed from service upon activation of the release hinge.
  • Remove Wishbone TM from service on condition when there is evidence of discoloration, fading, staining, or lack of suppleness of the webbing, elongation of rivet holes, fraying of webbing or stitching.
  • Remove Wishbone TM from service if subjected to or evidence of heating, melting, or singing of the webbing.
  • Remove Wishbone TM from service on condition, any of the hardware or material is excessively worn or has excessive play to include nylon line loop that is pinned through the rings.