Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

December 13, 1974

Mr. W. L. Christensen
Safety Director
Rust Engineering Company
1130 So. 22nd Street
P. O. Box 101
Birmingham, Alabama 35201

Dear Mr. Christensen:

This is in response to your letter of November 7, 1974, which was forwarded to this office by Al Branson of the Associated General Contractors.

It is my understanding that a member of my staff contacted you on November 18, 1974, and resolved the question you raised. For the record, a Field Information Memorandum (FIM) does not alter a standard. The memorandum may or may not address the entire standard as in the case of FIM #74-80.

The issuance of FIM #74-80 was precipitated by two different opinions on the subject of "caught between", therefore, that was the subject addressed. In order to maintain continuity with the standard, the last paragraph refers back to 29 CFR 1926.550(a)(9), to indicate that the hazards as described must be considered in each case.

Your interest in safety and health are greatly appreciated. If I may be of any further assistance to you, please feel free to contact my office.


John K. Barto, Chief
Division of Occupational
Safety Programming