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.

 


July 17, 2008

Letter # 20080226-8302

RE: Whether the Demolition standard applies to moving a residential structure. 29 CFR 1926 Subpart T – Demolition.

Question: When moving an entire residential structure, does 29 CFR 1926 Subpart T, the Demolition standard, apply?

Answer: It is our understanding that moving a residential structure typically involves the following process: First, employees complete pre-move tasks such as disconnecting utilities. Then, holes are made in the foundation, and steel I-beams are run through the holes and under the structure. Dunnage piers are built up to support hydraulic jacks. The jacks then lift the entire structure from its foundation. After placement of the beams on dollies, the structure is moved to its new location and laid on the new foundation. Finally, post-move tasks such as connecting to utilities lines are commenced.

The provisions of the demolition standard, 1926 Subpart T (1926.850-1926.860), address hazards associated with demolition. The procedure described above is not a demolition process; in fact, it is in a sense the opposite – a procedure designed to keep the structure intact. Therefore, the demolition standard would not typically apply to such a procedure.

Noah Connell, Acting Director
Directorate of Construction