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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 1, 1995

Mr. Lance Murray
Safety Representative
General Atomics
P.O. Box 85608
San Diego, California 92186-9784

Dear Mr. Murray:

Your letter addressed to Mr. James Foster, dated October 14, 1994, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing fall protection in the power distribution industry, (29 CFR 1910.269 and 29 CFR 1926.502) was forwarded to the Office of Construction and Maritime Compliance Assistance for response.

With regard to how the construction fall protection standard relates to maintenance operations, please be advised that the fall protection requirements contained in paragraph 1910.269 for maintenance activities are unaffected. The only change to 1910 was to paragraph 1910.269(g)(2). When the fall protection equipment criteria in 1926, Subpart E was revised and moved to Subpart M, the reference to 1926, Subpart E in paragraph 269(g)(2) was amended to reference the new fall protection equipment criteria in 1926, Subpart M. With this exception, all standards related to your maintenance operations remain the same.

If you have any further questions on this matter, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Thank you for your interest in occupational safety and health.


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