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Requirements for attachable scaffold ladders used in construction; toe-hold minimum distance requirement.

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 17, 2003

John Schuler Construction
4726 Knollwood Court
Oceanside, CA 92056

Re: OSHA requirements for attachable scaffold ladders used in construction - §1926.451(e); fall protection; toe-hold clearance.

Dear Mr. Schuler:

Requirements for perimeter columns and perimeter safety cables in 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.

August 26, 2003

Mr. Troy Russell
Safety Director
Superior Steel, Inc.
5225 North National Drive
Knoxville, Tennessee 37914

Dear Mr. Russell:

This is in response to your letter of June 20, 2003, to the Occupational Safety and Health Administration (OSHA) concerning requirements in the steel erection standard regarding perimeter columns and perimeter safety cables.

We have paraphrased your question below:

Applicable regulations to a metal cable ladder that is similar to a Jacob's Ladder.

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 3, 2003

Mr. James A. Simmons, III
Commonwealth Dynamics
5008 Richard Lane
Jacksonville, FL 32216

Re: Is a metal cable ladder a "Jacob's ladder," and if not, what regulations apply to them?

Dear Mr. Simmons:

Evaluation of Fiber-Lam "Super Brace" compliance with construction fall protection requirements for guarding structural openings.

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 3, 2003

Mr. David Thelen
Winchester Homes
1325 Western Avenue
Baltimore, MD 21230

Re: Does the "Super Brace," manufactured by Fiber-Lam, meet OSHA construction fall protection requirements for dimensions and strength for guarding openings in the frames and walls of a structure during its construction?

Dear Mr. Thelen:

Compliance requirements for the use of U-bolt-type cable clamps in horizontal lifelines.

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 31, 2003

Mr. Melvin C. DeClue, CSP
MELDEC Group
1201 East Calvert Hill Road
Columbia, MO 65202-7485

Re: Whether U-bolt-type cable clamps are permitted to be used in horizontal lifelines

Dear Mr. DeClue:

Revised response regarding the storage of materials on a scaffold for more than one shift's 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.

 

Permissibility of transporting blasting caps with other explosives in the same vehicle where an IME 22-1993 container is used.

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 27, 2003

Curtis H. Childress, CSP, ALCM
Risk Control Training Manager
The St. Paul Companies
2327 Flint Hill Road
Powhatan, Virginia 23139

Re: Whether it is permissible to transport blasting caps with other explosives in the same vehicle where an IME 22 container is used; 29 CFR 1926.902(d).

Dear Mr. Childress:

Field-cured concrete sample cylinders must be subjected to similar conditions as the footings/walls; acceptable use of the Windsor Probe/Pin testing method.

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 27, 2003

Andrew G. Forrest, Jr.
Safety Coordinator
Lincoln Construction Inc.
4790 Shuster Road
Columbus, OH 43214-1997

Re: Whether a controlling contractor may heat concrete cylinder samples in performing concrete strength testing under 29 CFR 1926.752(a)(1); whether a controlling contractor may use a Windsor Probe and Pin test to meet the requirements for testing concrete footings, piers, and walls prior to authorizing commencement of steel erection under 29 CFR 1926.752(a)(1).

Compliance of using warning lines and/or control access zones for fall protection on roofs with a slope greater than 4:12.

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 26, 2003

Mr. Michael C. Wright, PE, CSP, CPE
Managing Principal
LJB, Inc.
3100 Research Blvd.
PO Box 20246
Dayton, OH 45420-0246

Re: Whether warning lines and/or control access zones can be employed for roofing work (residential and non-residential) on roofs with a slope greater than 4:12

Dear Mr. Wright:

Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners.

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 25, 2003

James H. Brown
Director of Safety and Health
Associated General Contractors of Indiana, Inc.
1050 Market Tower, 10 West Market Street
Indianapolis, IN 46204

Re: Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners

Dear Mr. Brown: