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• Standard Number: 1926.100(a); 1926.451(h)(1)

December 2, 1991

Mr. Paul Vincent Bonfiglio
Safety Advisor
Vincent Safety Services Company
357 Hempstead Turnpike, Suite 206
West Hempstead, New York 11552

Dear Mr. Bonfiglio:

This is in response to your September 26 letter requesting an interpretation of the Occupational Safety and Health Administration's requirement for the use of protective helmets. I apologize for the delay in responding to your inquiry.

In regard to whether workers erecting scaffolding with nothing above them are required to wear protective helmets, please be advised that although there may be no hazards from falling objects during scaffolding erection, possible danger of head injury still exists. Employees are susceptible to impact-type head injuries while handling scaffolding material at head level, bending and leaning between scaffolding members and from slips and falls. Therefore, protective helmets are required.

If we can be of any further assistance, please contact Roy F. Gurnham or Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs

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