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.
July 8, 1994
Ms. Mary E. Sharp
L.R. William & Sons, Inc.
733 Annapolis Road
Gambrills, Maryland 21504
Dear Ms. Sharp:
Thank you for your letter of May 17, in which you express your concerns about the Occupational safety and Health Administration (OSHA) policies in regard to fall protection during steel erection activities at your worksites.
As you know, in regard to the citations issued for your Orlando, Florida project, it is not appropriate to discuss this matter outside the proper litigation channels. However, I can state categorically that the citations were not issued for any political purposes. They were issued for observed alleged violations of OSHA's standards.
With regard to the Christmas-Treeing issue, there has already been substantial communication with your company on this subject conducted at appropriate lower levels. It is not necessary for me to intervene at this point in time.
In closing, let me assure you that the objectives stated in "ABC Today" remain my objectives. With the steel erection standard now being reviewed, we are moving in the direction necessary for resolving many of the concerns of the steel erection industry. Although Mr. Willson was not selected to participate on the requested rulemaking committee, the proper selection process was followed and was in no way politically manipulated. I look forward to your company's full participation in other portions of this rulemaking process.
Joseph A. Dear