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

Use of aerial lift or scissor lift guardrails as a work or scaffold platform.

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 23, 2002

Frances Youney
C.Y. Concepts, INC.
440 Stone Road
Rochester, N.Y. 14616

Re: Whether workers may stand on scaffold guardrails; anchor points; §§1926.450, 1926.502(d).

Dear Mr. Youney,

This is in response to your August 6, 2002, letter to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in answering your inquiry.

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:

Typographical error in internet text of 1926.800(r)(13)(ii).

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 29, 2002

Teyen Hu, P.E.
Office Engineer
U.S. Army Corps of Engineers
SPL-CO-SR

Dear Teyen Hu:

Registered professional engineer approval requirements for manufactured trench protection systems deeper than 20 feet.

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 16, 2003 [Reviewed May 31, 2018]

John M. Maas
2304 Bel-Aire Court
Green Bay, WI 53404-5017

Re: Whether an excavation contractor is required to get the approval of a registered professional engineer when using a manufactured trench protection system under §1926.652(c)(2); Subpart P; excavations; registered professional engineers; trench shields

Dear Mr. Maas:

Steel erection concrete testing requirements and number of samples required to be taken

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 19, 2002

Paul Bartleson
Safety Director
Kraemer Brothers, LLC
925 Park Avenue
Plain, WI 53577-0219

Re: steel erection concrete testing requirements; number of samples required; §1926.752(a)(1)

Dear Mr. Bartleson:

Fall protection requirements for employees working from a "work bridge" in concrete construction work

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 9, 2002

ATI–Advance Technology, Inc.
Attn: Mr. Thomas A. Berry
1762 North St. Francis
Wichita, Kansas 67208

Re: Whether fall protection is required for workers on work bridges; whether workers on work bridges must be protected against impalement on vertical rebar; §§1926.450(b) and 1926.701(b); work bridges; scaffolds; concrete; rebar

Dear Mr. Berry:

Corrected Tables A and B for 1926 Subpart R, 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 19, 2002

R. Donald Murphy
Managing Director
Steel Joist Institute
3127 10th Avenue North Ext.
Myrtle Beach, SC 29577-6760

Re: Errors in Tables A & B of 29 CFR Part 1926 Subpart R (steel erection standard)

Dear Mr. Murphy:

Steel erection standard requirements concerning installation of perimeter safety cable.

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 17, 2002

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

Dear Mr. Cole:

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:

Life jacket and skiff requirements when working over or near water.

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 5, 2003

Rodney Von Holten
Safety Director
Halverson Construction Co., Inc.
620 North 19th
P.O. Box 6039
Springfield, IL 62708

Re: Life jacket and skiff requirements in 29 CFR 1926.106.

Dear Mr. Von Holten: