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 14, 1989

F.W. Lundy
Safety Director
BE & K Construction Company
Post Office Box 1676
Birmingham, Alabama 35202-1676

Dear Mr. Lundy

This is in response to your request of September 25, 1989 asking for a written confirmation of an interpretation of the fall protection provision for iron workers during "connecting" activities.

Your interpretation is correct. The OSHA regulations state that the connector is not required to have his safety belt/lanyard tied off during the actual receiving of the piece of iron being flown in by crane. However, once sufficient bolts are in place to secure the iron (usually one or two, hand tightened), the connector must then employ his fall protection.

If we can provide additional assistance feel free to contact our office.

Sincerely,



Gerald P. Reidy, Director
Office of Construction and Maritime
Compliance Assistance