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July 11, 1984

Mr. David E. Kitts
Department of the Navy
Code 106.213
Building 48
South Broad Street
Philadelphia Naval Shipyard
Philadelphia, Pennsylvania 19112

Dear Mr. Kitts:

This is in response to your recent letter regarding fall protection for employees while erecting, dismantling or making alterations to scaffolds in excess of five (5) feet in height in ship repairing or shipbuilding operations.

The intent of Section 1915.77(c) is not to require employees, engaged in such operations, to be secured at all times by the wearing of safety belts and lifelines. The need for rapid mobility, lack of adequate life line attachment points and possibility of a greater hazard by entanglement is recognized.

However, we do feel there is a need for employees to wear safety belts and lifelines, which may be rapidly secured to the scaffold frame, as there are times when it would be feasible to be secured against a fall.

Section 1915.71(b)(7) states "No scaffold shall be erected, moved, dismantled or altered except under the supervision of competent persons." Competent persons must therefore be capable of recognizing and evaluating employees exposure to the hazards involved and be capable of specifying when and how protective measures must be taken that will protect against a fall.

A reasonably prudent employer engaged in shipyard operations would recognize the particular hazardous circumstances of meeting our scaffolding requirements by utilizing skilled employees.

We hope this information clarifies our position. If we can be of further assistance in this matter, please feel free to contact Bert Lindquist in our Division of Maritime Compliance Assistance, telephone (202) 523-8131.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations