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• Standard Number: 1926.501(b)(5)

June 20, 1995

Mr. Chuck Pryor
Sverdrup/Kaiser
Safety Manager
4949 Eastgate Mall
San Diego, CA 92021

Dear Mr. Pryor:

This is in response to your February 8 letter requesting a clarification of our December 23, 1994, letter to Mr. Fred Codding concerning fall protection during the construction of rebar assemblies.

The Occupational Safety and Health Administration's letter to Mr. Codding and a compliance interpretation issued on February 2, 1995, apply to built-in-place rebar assemblies only. You are correct in your understanding that this policy does not apply to rebar assembly sections built on the ground and which are then lifted into place by a crane or other equipment. In this situation fall protection is required at all times for employees working above six feet in height (including while climbing or moving point to point).

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,



Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance



February 8, 1995

Mr. Roy Gurnham
Director
Office of Construction and Maritime
Assistance
OSHA
Room N3610
200 Constitution Ave., N.W.
Washington, D.C. 20210

Re: Clarification of your letter dated December 23, 1994

Dear Mr. Gurnham:

Referencing your letter dated December 23, 1994, addressed to Mr. Fred Codding, would you please clarify what you mean by "rebar assemblies built in place " as it relates to employees moving from point to point without being "tied-off".

As I read your letter it appears that if the rebar (mat, wall, curtain, column, etc.) is assembled on the ground and "flown" in by a crane or other equipment this situation does not meet the "rebar assemblies built in place" criteria. Which means that the rebar personnel climbing on the rebar must be protected from falling 6 feet, or greater, even while moving.

Your earliest attention and responses to these questions will be greatly appreciated.

Sincerely,



Chuck Pryor
Sverdrup/Kaiser
Safety Manager
4949 Eastgate Mall
San Diego, CA 92021

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