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, 1995

Mr. John R. Roma, P.E. Vice President
New England Foundation Co. Inc.
37 Lowell Junction Road
Andover, MA 01810-5905

Dear Mr. Roma:

This is in response to your December 14, 1994, letter requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing hoisting personnel into and out of drilled shafts with a drill rig. With regard to OSHA's position concerning the "Recommended Procedures for the Entry of Drilled Shaft Foundation Excavations" published by the International Association of Foundation Drilling, please be advised that if the recommendations of this publication are strictly followed, the employer would be in compliance with the intent of OSHA's hoisting and fall protection requirements. However, all the applicable "should" statements must be followed as if they were "shall" statements. For example, all personnel entering drilled shafts must be protected by a lifeline. OSHA does not consider the use of a lifeline to be an option as the wording in the ADSC manual suggests.

With regard to an anti-two-blocking device being required on a drill rig, please be advised that OSHA would consider the absence of an anti-two blocking device as de minimis if personnel are not hoisted above ground level and all appropriate employees are trained in the proper hoisting procedures.

If we can be of any further assistance please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


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