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.

December 6, 1991

Mr. Sidney Freedman
Director
Architectural Precast Concrete Services
175 West Jackson Blvd.
Chicago, Illinois 60604

Dear Mr. Freedman:

Your letter of September 12 to Ms. Barbara Bielaski requesting suggestions for the protection of workers on ladders performing initial connecting work has been forwarded to the Office of Construction and Maritime Compliance Assistance for reply. I apologize for the delay in responding to your inquiry.

In respect to the use of ladders positioned against columns on the side of structures as illustrated in the pictures accompanying your letter, OSHA requires the base of the ladder be secured if used on a slippery concrete surface (29 CFR 1926.1053(b)(7)) and that rails at the top of the ladder be supported equally (29 CFR 1926.1053(b)(10)). As an added precaution, body belt/harness systems could be rigged to lifelines attached to the columns, or means could be provided to secure the top of the ladder in place by the use of a wide fork-like attachment at the top of the ladder that would overlap the sides of the column to prevent the ladder from sliding off the column.

With regard to employees who are not on ladders, the general fall protection requirements of Part 1926, Subparts E and M and Section 5(a)(1) of the Act apply.

If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8124.

Sincerely,



Patricia K. Clark
Director
Directorate of Compliance Programs




September 12, 1991

Ms. Barbara Bielaski
OSHA, U. S. Department of Labor
Room N-3621
200 Constitution Avenue, N.W.
Washington, DC 20210

Dear Ms. Bielaski:

The question arose at our last Erection Safety meeting as to the best means of protection for the initial connectors placing the ledger beams on the columns.

The enclosed pictures show the connector standing on a ladder. In other cases, an elevating and rotating work platform can be used, except possibly in multistory (10-15 stories) construction.

Any suggestions that you might have for available means of protection for the worker on the ladder would be appreciated.

Very truly yours,



Sidney Freedman, Director
Architectural Precast Concrete Services