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.

March 10, 2004

Mr. Richard Marshall
Safety Director
Richard Goettle, Inc.
9696 Skillman Street, Suite 280
Dallas, Texas 75243

Re: When personal fall protection is used at a drill shaft, is a warning line also required?

Dear Mr. Marshall:

This is in response to your letter dated December 23, 2003, to the Occupational Safety and Health Administration (OSHA). You ask for guidance with respect to the use of fall protection during drilling operations. We apologize for the delay in responding.

We have paraphrased your question as follows:

Question: When drill shaft employees are all using personal fall arrest systems to protect them from falling into the drill shaft, is a warning line positioned 15 feet away from the edge of the hole also required?

29 CFR 1926.501(b)(7)(ii) states:

Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet or more in depth shall be protected from falling by guardrail systems, fences, barricades, or covers.



Where a guardrail system, fence or barricade is infeasible, use of personal fall arrest systems is an acceptable alternative. As long as all the exposed employees are protected with a personal fall arrest system, there is no additional requirement for a warning line.

If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction



1We note that in your letter you referred to a particular OSHA inspection in a case that has now been closed. If you have questions regarding the specific facts involved with that inspection, please contact the OSHA Regional Office responsible for the inspection. [ back to text ]