Web Officers
menon.gopal@dol.gov
herrera.jose.h@dol.gov

Regarding construction work in water storage tanks and Permit-required confined space requirements in construction.

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 8, 2016

Chris Lovelace
The Lovelace Group
5805 State Bridge Road
Suite G-444
Duluth, Georgia 30097

Dear Mr. Lovelace:

This is in response to a letter you submitted to the Occupational Safety and Health Administration (OSHA) via email on July 7, 2016, regarding construction work in water storage tanks and OSHA requirements for confined spaces in construction. We thank you for your interest in occupational safety and health, and have provided answers to your questions, below.

Guarding of edges in marine terminals

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 31, 2017

Mr. Tyler Phelan
Phillips 66
1075 W Sam Houston Parkway N, Suite 200
Houston, TX 77043

Dear Mr. Phelan:

The purpose of this letter is in response to the Letter of Interpretation Request we received on April 5, 2017. This response is to follow up on previous information you received from an E-Correspondence request you sent in on the applicability of OSHA standards to your company's "designated waterfront facility".

CPL 02-00-124; Multi-Employer Citation 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.

November 9, 2017

Mr. Anthony D. Tilton
Trent Cotney P. A.
Construction Law Group
113 South Monroe Street, 1st Floor
Tallahassee, Florida 32301

Re: CPL 02-00-124; Multi-Employer Citation Policy

Dear Mr. Tilton:

Clarification of "Controlling Contractor" duties under the Steel Erection Standard (1926 Subpart R)

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 30, 2002

The Honorable Dennis Moore
U.S. House of Representatives
Washington, DC 20515-1603

Dear Mr. Moore:

I am writing in response to your October 31, 2001, letter. I apologize for the long delay in responding. As a result of government mail delivery delays due to the anthrax decontamination process, we did not receive your letter until December 31, 2001.

Fall protection requirements of various construction (1926) standards.

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 18, 2001

Mr. Stephen E. Sandherr
Chief Executive Officer
The Associated General Contractors of America
333 John Carlyle Street
Suite 200
Alexandria, VA 22314

Dear Mr. Sandherr:

Thank you for your letter of August 27, 2001. Let me first thank AGC for continuing to work with OSHA to advance safety and health at the nation's construction sites through partnering programs.

Exemption from the requirement to wear hard hats for religious reasons.

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.

 

 

Minimum approach distances to insulated power lines by construction workers working close to, but not on, the lines.

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.

July 18, 2001

Mr. A. W. Schlendorf
Brookhaven National Laboratory
Building 103M
P. O. Box 5000
Upton, N.Y. 11973-5000

Re: 1926.451(f)(6); 1926.955 Table V-2; scaffolds; power lines; minimum approach distances

Dear Mr. Schlendorf:

This is in response to your March 5, 2001, letter to the Occupational Safety and Health Administration (OSHA).

Access requirements for cantilevered work platforms; use of unstable objects is prohibited.

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.

July 23, 2001

Jim Brown
Director of Safety and Health
Associated General Contractors
1050 Market Tower
10 West Market Street
Indianapolis, IN 46204

Re: 29 CFR 1926.451 (e)(1) and (c)(2)(iii); scaffolds; cantilevered work platforms

Dear Mr. Brown:

Clarification of utility "owner" as used in the Safety and Health Standards for Excavations, Underground Installations.

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 21, 2001  [Reviewed May 31, 2018]

Mr. Frank C. DeFelice, Jr.
32 Cherry Lane
Durham, Connecticut 06422

Re: §1926.651(b)(2); utility owners

Dear Mr. DeFelice:

Installation of the HBS Composite Action System's continous plate prior to erection of beam poses tripping hazard.

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 11, 2001

Atorod Azizinamini
W348 Nebraska Hall
Civil Engineering Department
University of Nebraska-Lincoln
Lincoln, Nebraska, 68588-0531

Re: HBS Composite Action System; §1926.754(c)(1)(i)

Dear Mr. Azizinamini:

This is in response to your letter of July 23 requesting an evaluation of the "HBS Composite Action System." You have requested a determination as to whether this system would be in compliance with §1926.754(c)(1)(i) of OSHA's new steel erection standard.