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 https://www.osha.gov.

May 24, 1976

Mr. John Mullins
Chairman, NEA
Safety Commission
National Erectors Association
Arlington, Virginia 22209

Dear Mr. Mullins:

This is in reference to your inquiry, concerning the Field Information Memorandum issued by the Atlanta Region regarding Personnel Protective Equipment, Steel Erection.

As requested in your letter, an inquiry was made and it has been determined that the field memorandum was issued as a result of questions raised at an Atlanta Regional conference with Area Directors. The Construction Standards 29 CFR 1926, failed to address heights where lifelines, lanyards, and safety belts will be worn. The 10-foot height limitation was based on the logical reasoning of the varying heights found in the construction standards at which the construction worker must be protected.

It is OSHA's opinion that the issuance of any citation must be based on the conditions observed at the time of the inspection. Compliance Safety and Health Officers must use professional judgment in those instances when the iron and steel worker must have sufficient mobility of action, especially when making initial connections. However, when an iron or steel worker is in a stationary position, some sort of protection must be provided, safety belts, nets or a suitable guarded work platform.

Conversations with various members of labor and management in the industry, as well as personnel in OSHA, reveal that some sort of effort should be made by all concerned, whereby, definite guidelines acceptable to everyone would be established. Please contact Mr. Frank Memmott, Senior Project Manager for Construction Standards for information concerning avenues of approach. His telephone number is (202) 523-8161.

Based on the consensus of the Regional Offices polled, no official action is planned at this time regarding the Atlanta field memorandum. Any further action by this office will depend upon the results of the meetings set up by Mr. Memmott.


Donald A. Shay, Director
Office of Compliance Programming