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.

November 2, 1995

Mr. W. C. Byers
Board Chairman
National Steel Erectors Corporation
P.O. Box 709
Muskogee, Oklahoma 74402-0709

Dear Mr. Byers:

This letter is in response to your letter in which you requested an interpretation on the applicability of Subpart V, Power Transmission to radio, TV, and communication type Towers.

Although your company may perform operations similar to those described in Subpart V, the subpart does not apply to the erection or alteration of radio, television, or communication towers. As specified in paragraph 1926.950(a), the paragraphs you reference in this subpart are intended to be the requirements only during the construction of electric transmission and distribution lines and equipment. Consequently, there are no specific assembly provisions, including those you list and those of Subpart R, that apply to communication towers.

Since your company is not engaged in the construction of electric transmission and distribution lines and equipment, you would have to comply with the requirements of 1926.105, Safety Nets, for fall protection concerns. Of course, other hazards associated with tower construction are covered by other subparts of 29 CFR 1926.

If you have any further questions on this matter, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Offices of Construction and Maritime Compliance Assistance at (202) 219-8136.


John B. Miles, Jr.
Directorate of Compliance Programs