February 7, 1992
MEMORANDUM FOR: GILBERT J. SAULTER, Director
THROUGH: LEO CAREY, Director
Office of Field Programs
FROM: PATRICIA K. CLARK, Director
Directorate of Compliance Programs
SUBJECT: National Interpretation/Policy Regarding Fall Protection
For Steel Erection Operations.
This is in response to your August 26 memorandum requesting a national
interpretation/policy regarding fall protection for steel erection
operations. I apology for the delay in responding to your inquiry.
We have been advised by the Office of the Solicitor that Review Commission
cases have determined that, other than 29 CFR 1926.105(a), there are no
specific fall protection provisions outside Subpart R that apply to steel
erection connection related activities. Consequently, the general duty
clause is the only provision that can be cited for steel erection fall
hazards where the fall distance is less than 25 feet. To assist in
establishing the existence of the necessary four elements of a (5)(a)(1)
citation, the National Office is developing an information package for use by
all regions. Although not complete at this time, the information that has
been compiled may be obtained by contacting Mr. Roy F. Gurnham or Mr. Dale
Cavanaugh of my staff in the Office of Construction and Maritime Compliance
Assistance at (202) 523-8136.