Fall protection is not required where there is no feasible means of providing it while working on vehicles or trailers.
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. Timothy J. Batz, CSP, ARM
Sr. Risk Control Consultant
IMA
1550 17th Street, Suite 600
Denver, CO 80202-2423
Re: Whether fall protection is required for employees working on vehicles and trailers; 29 CFR 1926.500; General Duty Clause
Dear Mr. Batz:
This is in response to your letter dated January 26, 2004, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your question as follows: