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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 30, 1999
Mr. Stephen Mallinger
Office of Compliance
Room LA 200
John Adams Building
110 Second Street S.E.
Washington, D.C. 20540-1999
Dear Mr. Mallinger:
Thank you for your August 2, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs (DCP). Your letter has been referred to the Office of General Industry Compliance Assistance for an answer to your question regarding OSHA's policy on fall protection for elevator mechanics and inspectors.
Question. Is it OSHA's policy to require that some means of fall protection for elevator mechanics and elevator inspectors be used while they are working on top of an elevator car if an opening exists of sufficient size that a person could fall through?
Response. OSHA requires appropriate fall protection such as safety harnesses, safety nets, standard railings, etc. whenever there is a fall hazard. However, in your letter you discussed a variety of situations within elevator shafts where a particular method of fall protection may impose additional hazards. Therefore, each individual elevator shaft must be evaluated on a case-by-case basis to ensure that employees are properly protected and additional hazards are not introduced.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Compliance Programs