Edison Electric Institute - 02/13/2015
IN THE UNITED STATES COURT OF APPEALS
FOR THE DISTRICT OF COLUMBIA CIRCUIT
Requirements for PRCS attendants; Fall arrest system anchorage point
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.
August 28, 1995
Christopher Seniuk M.P.A., C.S.P., C.I.H.
Assistant Vice President
Director of Safety and Health Services
Lovell Safety Management Co., Inc.
161 William Street
New York, N.Y. 10038-2675
Dear Mr. Seniuk:
This is response to the questions in your letter of May 10, 1995. The questions and responses are as follows:
Q 1.
Are attendants always required anytime employees enter a permit-required confined space (PRCS)?
R.
Scaffolds may serve as fall arrest anchorages.
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.
April 2, 1998
Mr. John Palmer
Scaffold Training Institute
Houston Training Center
311 East Walker
League City, TX 77573
Subject: 1926.502(d)(15) and 1926.451(a)
Dear Mr. Palmer:
This is in response to your letter of October 31,1997, addressed to Roy Gurnham, Occupational Safety and Health Administration (OSHA), in which you highlighted the concerns using the scaffold as an anchorage point for a personal fall arrest system under 29 CFR 1926.502(d)(15) as well as meeting the requirements of 1926.451(a).
Fall protection anchorage points: guardrail systems and cranes
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.
June 8, 1998
Jerry M. Gillooly
Safety Manager
Bohl Crane, Inc.
534 Laskey Road
Toledo, Ohio 43612
Dear Mr. Gillooly:
This is in response to your March 3 letter addressed to Mr. Roy Gurnham, Occupational Safety and Health Administration (OSHA) seeking an interpretation of 29 CFR §1926.502(d)(23) and guidance in identifying acceptable methods for accessing a crane runway from an aerial lift.
Reinforcing steel (rebar) assemblies: questions regarding fall protection and training.
NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.
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 9, 1999
Mr. J. Robert Harrell
President
Safety Management Services
4012 Santa Nella Place
San Diego, CA 92130-2291
GFCI and coverplate requirements in construction;use of fall arrest systems and scaffolding.
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.
October 14, 1999
Mr. Dennis Vance
Safety Services
711 Low Gap Road
Princeton, WV 24740
Subject: 1926.404(b)(ii) and 1926.404(b)(iii); 1926.502(d)(15); 1926.502(d)(17); 1926.451(a); GFCI's; Cover Plates for Receptacle Boxes; Harness Attachment Points for Fall Arrest Equipment
Dear Mr. Vance:
Whether a manufacturer-stipulated minimum anchor point elevation of 18 feet precludes the use of a shock absorbing lanyard in an aerial lift.
NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.
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.
Applicability of the steel erection standard to repair and installation of metal roofing and roofing accessories.
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.
November 8, 2002
Mr. Jeff Baum
The SHARP Program
4840 W. 15th Street, Suite 1000
Lawrence, KS 66049
Re: Whether the repair and installation of metal roofing and roofing accessories is covered by the steel erection standard; steel decking; §§1926.502(d)(15), 1926.750(b), 1926.751, and 1926.760(d)(2)
Dear Mr. Baum:
Wire rope clips on suspension scaffolds; safety latches on large crane hooks; order of assembly for hanging scaffolds; and horizontal lifeline design.
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 4, 2004
Martin D. Spencer Jr.
Northeast Area Rigging Coordinator
International Brotherhood of Boilermakers
5745 Big Tree Road
Orchard Park, NY 14127
Re: Wire rope clips on suspension scaffolds; safety latches on large crane hooks; hanging scaffolds - order of assembly; jobsite fabricated lifting accessories - criteria; and horizontal lifelines: use of wire rope clips, anchorages, number of persons allowed to be connected, requirements relating to sag, and use of synthetic rope.
Dear Mr. Spencer:
Fall protection requirements for employees working on an elevator car frame.
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 2, 2010
Letter #20071002-8005
Re: Fall protection requirements for employees working on an elevator car frame.