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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

March 21, 1984

Mr. Frank G. Goldenberg
Erection Department
Montague-Betts Company
Post Office Box 11929
1619 Wythe Road
Lynchburg, Virginia 24506

Dear Mr. Goldenberg:

This is in response to your letter of March 5, concerning the application of 29 CFR 1916.500(d)(1) in view of two U.S. Court of Appeals decisions and an Occupational Safety and Health Review Commission decision.

We have been informed by the Office of the Solicitor of Labor that 29 CFR 1926.500(d)(1) should not be cited for any roofing operation. However, 29 CFR 1926.28(a) or 29 CFR 1926.105(a) may be applicable for certain roofing operations which do not fall within the 29 CFR 1926.500(g) definition of "built-up" roofing work.

If we can be of further assistance, please let us know.


John B. Miles, Jr., Director
Directorate of Field Operations