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.

June 13, 1990

Mr Kurt M. Stetzer
Assistant Director of Industry Relations
Western Pennsylvania Heavy
& Highway Construction
Industry Advancement Program
1201 Banksville Road
Pittsburgh, Pennsylvania 15216

Dear Mr. Stetzer:

This letter is in response to your question about compliance with the requirements of OSHA Standard 29 CFR 1926.106(d), which reads as follows:

At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.

To be considered in compliance with the aforementioned standard, an employer must have a lifesaving skiff available that could, at the minimum, retrieve an employee from the water no more than three (3) to four (4) minutes from the time they entered the water. However, if there are any additional hazards, such as very cold water, rapids an employee could be swept into, etc., the lifesaving skiff would have to be able to retrieve an employee before they sustained injuries as a result of those additional hazards.

In addition to the preceding, an employer is required to comply with all other applicable standards including, but not limited to, the requirements that an injured employee be treated by medical personnel or an employee certified in first aid within three (3) to four (4) minutes from the time the injury occurred. This could mean that first aid treatment would have to begin in the lifesaving skiff.

If you require any additional information regarding this matter, please contact John McFee of my staff at 215-596-1201.


Regional Administrator