Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents
• Standard Number: 1926.652; 1926.652(g)(1)(ii)

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.


November 14, 2003

Mr. Thomas A. Bush, CSP
Manager - EH&S Consultant
OSEA 3748 South Park Avenue
Buffalo, NY 14219-1802

Re 29 CFR 1926.652(g)(1)(ii)

Dear Mr. Bush:

This is in response to your letter dated April 10, 2003, to the Occupational Safety and Health Administration (OSHA) concerning trench shields (29 CFR 1926.652) being held flush with the top of the trench and road surface. We apologize for the delay in providing this response.

We have paraphrased your question as follows:

Question: Scenario - Our construction project calls for a trench to be excavated through a concrete or blacktop road surface. Excavation needs to be done in such a way that steel plates can cover the trench and support smooth traffic flow while unoccupied. In this situation, is it permissible under OSHA's excavation standards to install the trench shields flush with the top of the concrete or blacktop road surface?

Answer
There is no specific prohibition against installing a trench shield so that the top of the shield is flush with the top of the road surface in the situation you describe.1 Therefore, it is permissible.

If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,

Russell B. Swanson, Director
Directorate of Construction

1 Keep in mind that §1926.652(g)(1)(ii) states:
Shields shall be installed in a manner to restrict lateral or other hazardous movement of the shield in the event of the application of sudden lateral loads. [back to text]
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