Fall protection requirements for both residential and commercial HVAC systems; clarification of confined spaces

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.

September 13, 2001

Mr. Dennis Vance
Safety Specialist
Safety Services
711 Low Gap Road
Princeton, WV 24740

Re: Fall protection; HVAC; confined space;

Dear Mr. Vance:

Fall protection requirements for employees, other than roofers, working on low-slope roofs

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 15, 2002

Mr. Keith Harkins
Safety Manager
Linbeck/Kennedy & Rossi
One Maguire Road
Lexington, Ma 02421

Re: Whether a warning line at 6 feet used to protect roofing workers may also be used to meet fall protection requirements for HVAC construction workers; §1926.502(b)

Dear Mr. Harkins:

Fall protection requirements for construction workers doing work while on a roof

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.

December 15, 2003

Mr. Anthony O'Dea
ADP Marshall Construction
75 Newman Avenue
Rumford, RI 02916

Re: Fall protection requirements for construction workers doing work while on a roof.

Dear Mr. O'Dea:

Fall protection during roofing inspections, investigations, and assessments

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 12, 2004

Mr. Randy Stahl
Safety Manager
Korellis Roofing, Inc.
1333 169th Street
Hammond, IN 46324-2008

Re: Is fall protection required during small roofing repairs that take minimal time to complete?

Dear Mr. Stahl:

This is in response to your letter dated December 16, 2003, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your question as follows:

Fall protection non-conforming guardrail criteria for application of a de minimis policy.

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.

May 12, 2000

Mr. Barry A. Cole
Executive Vice-President
Steel Erectors Safety Association
of Colorado
5750 Pecos Street, Suite 6
Denver, Colorado 80221

Re: Fall Protection/Use of barricades; 1926.500, Subpart M

Dear Mr. Cole:

This is in response to your letter dated July 24, 1998, addressed to OSHA's Directorate of Construction. In the letter you ask a series of questions regarding 29 CFR 1926.500, Subpart M. We apologize for the long delay in responding.

Use of a warning line instead of conventional fall protection; Part 1926 Subpart M

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.

January 3, 2005

Mr. Dan Steigerwald
Safety Consultant
IMA Community Business
250 N. Water Street
600 IMA Plaza
Witchita, KS 67202

Re: Use of a warning line instead of conventional fall protection; Part 1926 Subpart M.

Dear Mr. Steigerwald:

Clarification of several residential construction and fall protection issues.

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.

December 17, 2003
 

Clarification regarding hazard access zones in steel erection

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 19 ,2014

Eric M. Dean
General Secretary
International Association of
Bridge, Structural, Ornamental and Reinforcing Iron Workers
Suite 400
1750 New York Ave. NW
Washington, DC 20006

Dear Mr. Dean:

Thank you for your March 12, 2013, letter to the Occupational Safety and Health Administration (OSHA). You ask OSHA to recognize the use of hazard access zones (HAZ) as an acceptable method to protect ironworkers who work in or near unfinished floor openings while performing steel erection work.