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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.
MEMORANDUM FOR REGIONAL ADMINISTRATORS
FROM: FRANK STRASHEIM ACTING ASSISTANT SECRETARY
SUBJECT: Team on Erection of Telecommunications Towers
The purpose of this memorandum is to solicit names for a team comprised of field staff working with staff from the National Office to develop a proposed enforcement strategy for responding to the anticipated boom in erecting telecommunications towers. Bart Chadwick, RA in Denver, has agreed to serve as team leader. The team win meet four or five times and complete its work by the end of FY 97. The first meeting will be held in Washington, D.C. in June.
By the way of background, the Directorate of Construction is in the process of preparing a notice of proposed rulemaking to revise the fall protection rules in Subpart M of 1926. Part of that revision effort will include proposing to address fall hazards associated with the erection of communications towers. You may know that the industry anticipates that over 180,000 towers will be constructed in 1997 and another 250,000 in 1998. We have already seen an increase in the number of falls from towers and we are aware that many new contractors are in the business of erecting communications towers. However, the standards-setting process is lengthy and we must act quickly if we are to be responsive to the needs of the those who work in the communications tower industry. We need to assemble a team of individuals who are willing to work hard to identify the hazards associated with tower construction and to make some recommendations for an interim solution or enforcement policy as well as make such recommendations for regulatory language for the upcoming Subpart M revision. Our immediate concern is to address the fall hazard, access (riding the load), and the use of gin poles. There are other concerns that the team may identify for further work, but the immediate concern is development of interim guidelines for the most pressing problems.
Please send the names of individuals who want to participate in this effort to Russell B. Swanson, Director of Construction, by May 30. It would be helpful to have participation from employees who have experience in the tower inspection activities. We will try to schedule the first meeting in June to go over the project and to decide on a course of action.