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 http://www.osha.gov.

February 26, 1985

MEMORANDUM FOR:     JOHN B. MILES, JR.
                    Director
                    Directorate of Field Operations

SUBJECT:            Clarification of 29 CFR 1926.700(a)
                    Re:  ANSI A10.9.10.3

We request a clarification of the term "clip" as used in the last sentence of the subject ANSI reference.

We believe that the word "clip" is used interchangeably with the more common field term "feet" to refer to the attachment devices on tilt up wall construction braces.

In addition, we require a determination as to whether the "feet" or "clips" shown in the attached photos are prohibited by the referenced standard. The subject brace assemblies are being used widely in this Region by tilt wall constructors. The assemblies are manufactured by Dayton Superior Concrete Assessories, Co. of Miamisburgh, Ohio. Our compliance officer has been assured by a factory representative that these braces meet the intent of ANSI A10.9 because the open end of the slot has a 3/16" high retaining lug to prevent accidental dislodgement of the brace from the attachment bolt.

We have no problem with the wall or floor attach points as these are engineered attachments. We have discussed this problem with Bill Simms, and he is awaiting this correspondence. If you have any questions, please contact Herbert M. Kurtz or Benton Nicholas.

Please respond directly to Gerald A. Baty, Area Director, Houston, Texas, and provide a copy of your response to Herbert M. Kurtz, Assistant Regional Administrator for Technical Support.

GILBERT J. SAULTER
Regional Administrator