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.
May 5, 1992
Mr. J. M. Van Name, P.E.
Work Rules Subcommittee
P.O. Box 7254 St.
Davids, Pennsylvania 19087-7254
Dear Mr. Van Name:
This is in response to your March 8 letters to Mr. Roger Clark and Mr. H. B. Zettler concerning work in progress to develop fall protection standards for electrical and communications utility work. I apologize for the delay in responding to you.
Thank you for informing us of the projects being undertaken by the Work Rules Subcommittee of the National Electrical Safety Code (NESC) and by the Engineering in the Safety, Maintenance, and Operation of Lines Subcommittee of the Transmission and Distribution Committee of the Institute of Electrical and Electronics Engineers (IEEE). The Occupational Safety and Health Administration (OSHA) hopes that this work will result in a standard that can be used as a basis to revise as necessary, OSHA's regulations on fall protection for utility work.
You requested the names of individuals who should be kept informed of the activities of these groups and who could also contact you as necessary. Mr. David Wallis (telephone, 202-523- 8161) of the Office of Electrical, Electronic, and Mechanical Engineering Safety Standards (Director, Joseph Pipkin) is the project engineer for the proposed electric power generation, transmission, and distribution standard (§1910.269). He will be a liason for standards development and will keep the Office of Construction and Civil Engineering Safety Standards (Director, Gerald P. Reidy) and the Office of Fire Protection Engineering and Systems Safety Standards (Director, Chappell Pierce) informed of your work. Mr. Roy Gurnham or Mr. Dale Cavanaugh of the Office of Construction and Maritime Compliance Assistance can be contacted for Subpart V compliance issues.
Thank you for your groups' interest in fall protection. We are confident that the work performed under the auspices of the NESC and the IEEE will result in fewer injuries to electrical and communication employees.
Patricia K. Clark, Director
Directorate of Compliance Programs