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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.
August 11, 1995
Mr. Tom Overstreet
Fontana Steel Inc.
Post Office Box 2219
Rancho Cucamonga, CA 91729-2219
Dear Mr. Overstreet:
This is in response to your July 11 letter in which you express concern about the Occupational Safety and Health Administration (OSHA) policy regarding the use of rebar assemblies as ladders.
The policy expressed in the December 23, 1994 letter to Mr. Codding was the result of and directly reflects the original petition received from Mr. Codding. As the policy is, in essence, an exemption from the plain reading of the language of 29 CFR 1926.501(b)(5), it was OSHA's intention to limit the policy to the scope of the original petition. Mr. Pryor's letter to OSHA simply requested a clarification of the policy and was not a petition to change or expand the policy.
In addition to receiving your letter, Mr. Codding has again been in contact with this office to see if the policy could be extended to rebar assemblies that are hoisted into place. Mr. Codding is in the process of putting together a presentation to demonstrate the need to expand the exemption. A date has not yet been set for the presentation but it is expected to occur before the end of September. Based on the information provided by you and Mr. Codding, OSHA will determine at that time whether or not to change the rebar policy. In the meantime, you may want to contact Mr. Codding at (703) 591-1870 to coordinate your information.
If you have any further questions, please do not hesitate to contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.
Roy F. Gurnham, P.E., J.D.
Office of Construction and Maritime