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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.
February 7, 1992
MEMORANDUM FOR: BYRON M. CHADWICK REGIONAL ADMINISTRATOR THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS SUBJECT: Fall Protection During Steel Erection
This is in response to your August 7 facsimile of an August 7 letter to you from Mr. Mitch B. Wisenor of MK-Environmental Services concerning fall protection for ironworkers. We apologize for the delay in responding to you.
We have been advised by the Office of the Solicitor that Review Commission cases have determined that, other than 29 CFR 1926.105(a), there are no specific fall protection provisions outside Subpart R that apply to steel erection connection related activities. Consequently, the general duty clause is the only provision that can be cited for steel erection fall hazards where the fall distance is less than 25 feet. To assist in establishing the existence of the necessary four elements of a (5)(a)(1) citation, the National Office is developing an information package for use by all regions. Although not complete at this time, the information that has been compiled may be obtained by contacting Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.
August 7, 1991
Mr. Byron R. Chadwick
U.S. Department of Labor - OSHA
1961 Stout Street
Denver, CO 80294
Dear Mr. Chadwick:
Per my conversation with Ms. Cindy Cross (U.S. Department of Labor - OSHA), I have been directed to present all inquiries in writing to your attention. Unfortunate as this may be, as the questions to be proposed are structural/miscellaneous steel erection related, and this phase of the construction may very well be completed before a response can be received, I am still extremely interested in the resulting interpretations.
During the act of erecting/connecting structural beams to previously erected columns, and choosing a height of 10 feet above any adjacent finish floor or subgrade elevation, is it acceptable to allow erection personnel (ironworkers) to walk unprotected atop the beams? By unprotected I am referring to walking atop the beam without the use of safety belt and lanyard, handrailing, and/or safety net.
Along the same lines, is it acceptable to allow erection personnel (ironworkers) to "shinney", shall we say, or otherwise crawl up and down previously erected and anchored structural columns, again unprotected?
Your interpretation and timely response to these questions, and any details pertaining to definition will be greatly appreciated.
Mitch B. Wisenor
MK Environmental Services