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.

November 20, 1979

Mr. George N. Hailey, Jr.
W. S. Bellows Construction Corporation
P.O. Box 2132
Houston, Texas 77001

Dear Mr. Hailey:

This is in response to your letter dated August 1, 1979, addressed to Mr. Gilbert J. Saulter, OSHA's Dallas Regional Administrator. Your letter was forwarded to this office for response.

You indicated in your correspondence that while installing high rise elevators from a temporary work platform properly guarded with guardrails, the elevator operators normally use a safety belt attached to a cable, and the cable extends the full length of the shaftway. However, you indicate you have a problem with overhead protection, in that a fixed cover cannot be provided on the car and if employees are depending on being saved by their safety belts attached to the lifeline, the overhead protection would strike them causing serious injury or death.

If supplementary platform support wire ropes are used with an automatic safety locking device, providing equivalent employee protection, lifelines would not be required and a fixed cover could be provided over the car platform. In addition, after the car and counterweight safetier have been installed (as required in the reference ANSI A17.1 Safety Code for Elevators, Dumbwaiters, Escalators, and Moving Walks), lifeline or equivalent protection may not be required for exposed employees.

If we may be of further assistance, feel free to call or write.


Grover C. Wrenn Director,
Federal Compliance and State Programs