- Standard Number:
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.
November 16, 1988
Mr. Michael A. D'Amico
Storer Cable Communications
21 East Main Street
Clinton, Connecticut 06412
Dear Mr. D'Amico:
This is in response to your letter of September 23, 1988, to Mr. John B. Miles, concerning the use of fall protection devices during service activities by CATV personnel. Your letter was forwarded to this office for response.
The fall protection requirements of 29 CFR 1910.268, copy enclosed, are presented in that standard. When ladders are used by employees engaged in CATV work, 29 CFR 1910.268(h)(1) and (7) specify that ladders shall be properly secured in place, shall be secured (lashed) to strand, or securely lashed to the pole. In addition, 29 CFR 1910.268(g)(1) specifies that, when work is performed at positions more than 4 feet above the ground or while the worker is on a pole or a tower, safety belts and straps shall be provided and used. It is assumed that such safety belts are tied off via lanyards to fixed structure (other than a ladder) capable of providing a sufficient anchorage. Additionally, 29 CFR 1910.268(n)(7) specifies that safety belts and straps be used when adequate railings are not provided on elevated work platforms. 29 CFR 1910.268(n)(8) specifies that at all elevated work locations where adequately guarded work areas are not provided, workers shall use safety belts and straps.
Therefore, where it is necessary for an employee to work directly from a ladder at an elevation of more than 4 feet above the ground, that worker must be provided and must use a safety belt and strap. In no event is it acceptable for the worker to tie-off to a portable ladder while working aloft. A safety drop line shall be affixed to permanent structure and the worker shall tie-off to the safety drop line.
If I can be of further assistance, please contact us.
Thomas J. Shepich, Director
Directorate of Compliance Programs