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.
April 21, 1994
MEMORANDUM FOR: WILLIAM Q. WIEHRDT
Assistant Regional Administrator
Technical Support
THROUGH: H. BERRIEN ZETTLER
Deputy Director
Directorate of Compliance Programs
FROM: ROY F. GURNHAM, Director
Office of Construction and
Maritime Compliance Assistance
SUBJECT: Request for Review of Potential 5(a)(1) Citations for
Fall Protection in Steel Erection
We have reviewed your requests to issue citations to P.S. Deppe Construction, Inc. and to Halverson Midwest Joint Venture for failure to provide fall protection during bridge construction. We concur with your request to issue one citation under either section 5(a)(1) or 1926.95(a) (or grouped together into one citation) to each employer.
If you have any further questions please contact me (at extension 150) or Mr. Dale Cavanaugh (at extension 149) of my staff at (202) 219-8136.