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Use of double-walled tanks as the only form of protection from collision damage.

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 31, 2002

Patricia H. Falls
Firstline Safety Management, Inc.
P.O Box 3069
Winchester, VA 22604

Re: Whether use of double-walled tanks meets the requirement in §1926.152(e) that tanks be protected from collision damage

Dear Ms. Falls,

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:

CSHO use of external GFCI testers to enforce 29 CFR 1926.404(b)(1)

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 9, 2003

 

 

Clarification of 1926.502(d)(6) term "designed for" in snaphook connections.

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 9, 2003

Mr. Doug Mercier
1345 15th Street
Franklin, PA 16232

Re: Section 1926.502(d)(6) prohibits snaphooks from being engaged to certain specified equipment unless "designed for" such a connection. What does the phrase "designed for" mean?

Dear Mr. Mercier:

Use of approved GFCI's that do not have open-neutral protection.

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 7, 2003

David Touhey
Contract Risk Management, Inc.
P.O. Box 211
Concord, NH 03302-0211

Re: Whether GFCIs are required to have "open-neutral protection."

Dear Mr. Touhey:

We are writing in response to your letter of August 20, 2002, to the Occupational Safety and Health Administration (OSHA) regarding "open-neutral protection" in ground-fault circuit interrupter (GFCI) devices. We apologize for the long delay in providing this response.

Marking and proof-testing requirements for special custom-designed lifting 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.

July 7, 2003

Barry A. Cole
Executive Vice President
Miller Safety Consulting, Inc.
5750 Pecos Street, Suite #6
Denver, CO 80221

Re: §1926.251(a)(4) requirement for marking and proof-testing special custom-design or other lifting accessories

Dear Mr. Cole:

Mortar testing requirements and controlling contractor responsibilities under the Steel Erection Standard

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 27, 2002

Sean Purcell
Safety Officer
RPCarbone Company
5885 Landerbrook Drive, Suite 110
Cleveland, OH 44124-4031

Re: What are an employer's obligations under Part 1926 Subpart R with respect to testing mortar? What OSHA responsibilities does a controlling contractor have under Subpart R when it subcontracts duties placed by Subpart R on the controlling contractor? §1926.752(a)(1); mortar testing requirements; contracting-out duties of controlling contractor

Dear Mr. Purcell:

Field bolting and welding requirements for steel joist assembly

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 22, 2002

Lee V. Clarbour
Vice President
Arlington Structural Steel, Company, Inc.
1727 East Davis Street
Arlington Heights, IL 60005

Dear Mr. Clarbour:

Electrical standard requirements concerning covers for electrical pull boxes, junction boxes, and fittings.

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 3, 2002

John Tanase
Safety Coordinator
R.W. Leet Electric, Inc.
3225 East Kilgore Road
Kalamazoo, MI 49001

Dear Mr. Tanase:

This is in response to your letter of March 11, 2002, in which you request interpretations of several OSHA electrical standards. In your letter, you describe two situations and ask two questions about the applicability of particular standards in §1926.405. We will address only your specific questions -- not other issues that may be raised by these scenarios.

Repair requirements for the cord plug (attachment plug) of double-insulated tools.

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.

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.