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.

September 24, 1990

Richard F. Andree, Ph.D.
Executive Vice President
Safety and Health
Management Consultants, Inc.
161 William Street
New York, New York 10038

Dear Mr. Andree:

Thank you for your letter of August 7, concerning fall protection standards for pole climbing.

Your understanding of my letter of July 23, is essentially correct. The term, "working in elevated positions," as used in my previous letter, was intended to clarify that, whenever a worker is at an elevated position and exposed to a fall hazard from which serious bodily harm con result, the worker must at all times be protected with effective fall protection equipment. Most certainly, the worker who must ascend and descend a pole must be continuously protected from a fall during such activities, including passing around an obstacle such as a pole cross brace.

If we may be of further assistance, please contact us.


Gerald F. Scannell
Assistant Secretary