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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 https://www.osha.gov.
February 7, 1992
MEMORANDUM FOR: GILBERT J. SAULTER, Director Regional Administrator THROUGH: LEO CAREY, Director Office of Field Programs FROM: PATRICIA K. CLARK, Director Directorate of Compliance Programs SUBJECT: National Interpretation/Policy Regarding Fall Protection For Steel Erection Operations.
This is in response to your August 26 memorandum requesting a national interpretation/policy regarding fall protection for steel erection operations. I apology for the delay in responding to your inquiry.
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.