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

Use of hydro-vacuum excavation equipment and other acceptable means to locate underground utility installions.

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, 2003 [Reviewed November 22, 2017]

Mr. Joseph Caldwell
Consultant
Governmental Liaison
Pipeline Safety Regulations
211 Wilson Boulevard
Suite 700
Arlington, Virginia 22201

Re: Use of hydro-vacuum or non-conductive hand tools to locate underground utilities; §1926.651(b)(2) and (b)(3).

Dear Mr. Caldwell:

Permissibility of using guardrail systems other than perimeter safety cables 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.

July 21, 2003

Mr. Jerry Breneman
16001 Park Ten Place
Houston, TX 77084

Re: In steel erection, may a guardrail system other than a safety cable be used to meet the requirement for a perimeter safety cable under Part 1926 Subpart R?

Dear Mr. Breneman:

This is in response to your E-correspondence of September 17, 2002, to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in providing a response.

We have paraphrased your question as follows:

Fall protection requirements during installation and removal or tarps and sheeting on/from scaffolds; qualifications of person determining safety on scaffold with wind imposed forces.

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 16, 2003

 

 

Acceptability of using extensible boom forklifts to lift steel joist for spreading by hand

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 23, 2003

Michael A. McCarroll, CSP
PROSAFE Solutions, Inc.
P.O. Box 606
Villa Rica, GA

Re: Whether 1926 Subpart R permits an extensible boom forklift to be used to lift joists up for spreading by hand; whether OSHA requirements limit the number of joists that may be lifted by an extensible boom forklift.

Dear Mr. McCarroll:

Compliance of Non-Stop base tower and extension frames with scaffold access requirements.

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 23, 2003

Mr. Justin Breithaupt
Non-Stop Scaffolding, Inc.
1314 Hoadley Street
Shreveport, LA 71104

Re: Whether Non-Stop base tower and extension frames meet scaffold access requirements, §1926.451(e)(6) and (7)

Dear Mr. Breithaupt:

Hard hats are not required where there is no exposure to head injuries.

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.

February 20, 2004

Mr. Bret W. Barnard
WBM Heritage Roofing, Inc.
P.O. Box 186
Kyle, TX 78640

Re: Hard hat requirements for workers on a roof; §1926.100

Dear Mr. Barnard:

This is in response to your letter dated February 4, 2004, to the Occupational Safety and Health Administration (OSHA) concerning §1926.100. You request clarification of the standard as it applies to the wearing of hard hats on a roof-top construction site.

We have paraphrased your question below:

Requirements for leaving construction vehicles unattended and running on an off-highway job-site.

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 14, 2004

Mr. Paul Hayes
Safety Manager
Global Hawk Facilities Renovation Project
Skanska
P.O. Box 9009
Beale AFB, California 95903

Re: Whether any OSHA construction standards prohibit vehicles from being left running and unattended.

Dear Mr. Hayes:

Fall protection requirements for stairwells and mechanical chase openings surrounded by interior stud walls in residential 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.

December 22, 2003

Gerald M. Howard
Executive Vice President
Chief Executive Officer
National Association of Home Builders
1201 15thSt., NW
Washington, DC 20005

Dear Mr. Howard:

Re: Fall protection requirements for stairwells and mechanical chase openings surrounded by interior stud walls in residential construction.

Designation of an entire floor as a controlled decking zone for steel decking 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 22, 2003

Mr. Doug Schneider
Safety Solutions, Inc.
1045 S. 217th Street
Elkhorn, NE 68022

Re: In steel erection, is it permissible to designate an entire floor of a building as a Controlled Decking Zone (CDZ) and limit access to the CDZ by limiting access to that entire floor?

Dear Mr. Schneider:

Registered professional engineer approval requirements for combination trench shield and sloping system trenches with a depth greater 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.

December 22, 2003 [Reviewed May 31, 2018]

Mr. David V. Dow
Trench Safety and Supply, Inc.
3000 Ferrell Park Cove
Memphis, TN 38116

Re: Whether a sloping system used in conjunction with trench shields in an excavation that exceeds 20 feet in depth must be approved by a registered professional engineer; whether that engineer must be registered in the state where the excavation work is taking place.

Dear Mr. Dow: