September 26, 1995
| MEMORANDUM FOR: |
RICHARD TERRILL, Acting Regional
Administrator Seattle Regional Office
|
| THROUGH: |
JOHN B. MILES, JR., Director
Directorate of Compliance Programs
|
| FROM: |
ROY F. GURNHAM, Director
Office of Construction and Maritime Compliance Assistance
|
| SUBJECT: |
Fall Protection Standards |
This is in response to a December 19, 1994 letter from former regional
administrator James Lake, who transmitted correspondence from Van Howell, a
compliance officer in the Boise area office. Mr. Howell has several
suggestions and concerns about the new fall protection standards for
construction.
We have noted his suggestions and concerns and thank him for them. In
addition, we would like to address one issue raised by Mr. Howell. Mr.
Howell felt that employees working on reinforcing steel should be required to
be tied off when moving point to point, since reinforced steel structures do
not require uniform spacing, allow employees to move horizontally rather than
vertically as ladders do, and can expose employees to falls of fifty feet or
more. Mr. Howell enclosed an accident report concerning a fatality which
occurred when an employee fell approximately thirty feet from a concrete form
while climbing down the formwork.
We have limited our interpretation to allow moving point to point without
fall protection to rebar assemblies that are built in place and only up to
twenty-four feet above the lower level. We agree that employees do not
normally move horizontally on fixed ladders, but we do not currently have
sufficient accident data on falls from rebar to support applying more rigid
standards to this situation. Our interpretation does not apply to formwork.
On formwork, employees must be protected from falls at all times where the
fall distance is six feet or more, including when movement is from point to
point.
Policy discussions are currently ongoing on whether to allow employees to
move point to point without fall protection up to twenty-four feet above the
lower level on prefabricated rebar cages. No decision on this issue has been
reached yet.
If you have any questions, please call me or Dale Cavanaugh of my staff at
(202)219-8136.
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