Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

June 6, 1994

Mr. John C. Duley, Jr.
Safety Director
Omni Construction, Inc.
7500 Old Georgetown Road
Bethesda, Maryland 20814

Dear Mr. Duley:

This is in response to your January 25 letter requesting the Occupational Safety and Health Administration (OSHA) policy regarding fall protection for steel erection and the requirements for lifting tandem loads. I apologize for the delay in responding to your inquiry.

The reason this reply is this late is because both issues that you inquired about have been under review this past year. OSHA's policy addressing fall protection in steel erection has been finalized and a copy is enclosed.

With regard to multiple load lifting, please be advised that the Agency is developing guidance relative to the applicability of 1926.550(a)(19) to multiple load lifting. We will forward a copy of this policy when it becomes available. Again, we apologize for the delay and if we can be of any further assistance, please contact [the Directorate of Construction at (202) 693-2345].


Roy F. Gurnham, P.E., J.D.
Office of Construction and
Maritime Compliance Assistance


January 25, 1993

Mr. Dale Cavanaugh
Construction Compliance
U.S. Department of Labor/OSHA
200 Constitution Avenue, NW
Room N3610
Washington, DC 20210

Dear Mr. Cavanaugh,

I would like to request an interpretation of the fall protection requirements for steel erection.

I have always been under the impression that employees connecting steel were not required to use fall protection equipment, but employees bolting up or welding were required to tie off. Also, that employees walking from Point A to Point B on the steel do not have to be tied off as long as the flooring or decking is within 30 feet or two stories. Several steel erectors have advised me that they are not required by law to tie off at all times when connecting or walking steel.

Could I get a copy of the Federal law that applies to fall protection for steel erectors. Also, please include the requirements for lifting tandem loads.

OMNI Construction takes safety very seriously, we are always striving to make our job sites free form recognized hazards. We ask for OSHA's assistance concerning this matter.

Very truly yours,


John C. Duley, Jr.
Safety Director

cc: John Strong Mike Alto