Standard Interpretations - Table of Contents|
| Standard Number:||1926.502; 1926.751; 1926.752(d); 1926.753(c)(1)(i); 1926.753(c)(2); 1926.753(d); 1926.757(a)(9); 1926.759(b); 1926.760(a)(2); 1926.760(b)(3); 1926.760(c); 1926.760(c)(3); 1926.760(d)(3); 1926.760(e)|
|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.|
SENRAC evaluated whether the trigger height in steel erection should be different than that in subpart M and concluded that it needed to be higher . . . The special circumstances of steel erection can make conventional fall protection very difficult to deploy below 15 feet. For many steel erectors, especially connectors, the work starts at the top level of the structure. This means that anchor points above foot level are often limited or unavailable. Because of the nature of the structure, the available fall arrest distance is usually about 15 feet.66 FR 5244 - 5245.
The extent of the measures that a controlling employer must implement to satisfy this duty of reasonable care is less than what is required of an employer with respect to protecting its own employees. This means that the controlling employer is not normally required to inspect for hazards as frequently or to have the same level of knowledge of the applicable standards or of trade expertise as the employer it has hired.Inconsistencies
In the final rule, OSHA has made the provision more consistent with subpart M where possible. A new paragraph was added to subpart R's appendix D regarding flagging or marking of the control line with highly visible material. The only remaining difference in the control line requirements is the allowable distance from the leading edge. A control line for a controlled decking zone is to be erected not more than 90 feet from the leading edge, while the maximum distance permitted in Subpart M is 25 feet. The longer maximum distance in Subpart R is needed because of the size of the bays that are decked.(10) "In §1926.760(e) OSHA should not establish contractual terms."
|Standard Interpretations - Table of Contents|
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