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.

September 15, 1980

Ms. Carole C. Harris
Law Offices Keller and Heckman
1150 17th Street, N.W. Suite 1000
Washington, D.C. 20036

Dear Ms. Harris:

This is in response to your letter concerning the applicability of 29 CFR 1910.268 to pipeline transmission companies and gas utilities.

29 CFR 1910.268 does set standards that apply to telecommunications centers and telecommunications field installations which are located either outdoors or in building spaces used for such field installations as indicated in your letter. You also pointed out that your clients, pipeline and gas companies, are not in the telecommunications business; therefore, the companies are not covered by 29 CFR 1910.268 standards.

Fixed ladders used by employees employed by pipeline and gas companies must comply with the ladder requirements in 29 CFR 1910.27.

I hope this information will be helpful. If we may be of further assistance, please call or write.


John K. Barto,
Chief Division of Occupational Safety Programming