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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.

June 18, 1980

Mr. Paul B. Osborne
General Operations Manager
Eller Outdoor Advertising Co. of Colorado
P.O. Box 1468
Denver, Colorado 80201

Dear Mr. Osborne:

This is in response to your inquiry concerning the positioning of the safety line on billboards for the protection of employees.

The method of protecting employees working on elevated billboard platforms two to three feet wide, with a safety belt and lanyard 4 feet long attached to a safety line approximately 12 inches above the platform does not comply with the intent of 29 CFR 1910.23(c)(1). However, a system designed (such as shorting the lanyard) so as to prohibit employees from backing off the front edge of the platform, thereby preventing any fall possibility would appear to comply with the intent of the standard.

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

Sincerely,



John K. Barto Chief,
Division of Occupational Safety Programming