MEMORANDUM FOR REGIONAL ADMINISTRATORS
FROM: FRANK STRASHEIM
ACTING ASSISTANT SECRETARY
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.
SUBJECT: Team on Erection of Telecommunications Towers
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.