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

Requirements for use of high-visibility warning garments by construction workers in highway work zones.

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.

 

Evaluation of the use of aluminum forms as an exit route from trench excavations

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 11, 2004 [Reviewed November 22, 2017]

Charles O. Engelken
Wall-Ties & Forms, Inc.
4000 Bonner Industrial Drive
Shawnee, Kansas 66226

Re: Use of aluminum forms as a means of egress [exit route] from trench excavations.

Dear Mr. Engelken:

Permissibility of the welding of joists over 40-feet in length, while the hoisting line is kept in place, instead of field bolting.

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 20, 2003

Craig Davis
Safety Coordinator
Doherty Ornamental Iron, Inc.
P.O. Box 428
21110 West 311th Street
Paola, Kansas 66071

Re: Whether it is permissible to weld joists over 40 feet in length (while the hoisting line is kept in place) instead of field bolting them; §1926.757(a)(8).

Dear Mr. Davis:

Clarification of maintenance vs. construction activities; standards applicable to the removal and replacement of steel tanks and structural steel supports.

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 18, 2003

Mr. Raymond V. Knobbs
Minnotte Contracting Corporation
Minnotte Square
Pittsburgh, PA 15220

Permissibility of installing a trench shield so that the top is flush with the surface.

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 14, 2003 [Reviewed May 31, 2018]

Mr. Thomas A. Bush, CSP
Manager - EH&S Consultant
OSEA 3748 South Park Avenue
Buffalo, NY 14219-1802

Re 29 CFR 1926.652(g)(1)(ii)

Dear Mr. Bush:

This is in response to your letter dated April 10, 2003, to the Occupational Safety and Health Administration (OSHA) concerning trench shields (29 CFR 1926.652) being held flush with the top of the trench and road surface. We apologize for the delay in providing this response.

Use of quick disconnect with "pull-down sleeve" to satisfy requirement of a positive means to prevent pneumatic tools from becoming accidentally disconnected

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 14, 2003

John Kurtz
Executive Vice President
International Staple, Nail and Tool Association
512 West Burlington Avenue, Suite 203
La Grange, Illinois 60525-2245

Re: Use of quick-disconnect on pneumatic power tools; §1926.302(b)(1)

Dear Mr. Kurtz:

Compliance of an aerial lift fall protection device connected with a releasable tether and a non-releasable tether.

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.

 

Requirements for providing seatbelts for drivers whose size precludes their using seatbelts.

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 4, 2004

Mr. Robert Kunz
Safety Director
Cardi Corporation
400 Lincoln Avenue
Warwick, Rhode Island 02888

Re: Seat belts in construction: what are the OSHA responsibilities of an employer under §1926.601(b)(9) with respect to providing seat belts for workers whose size precludes their using seat belts that meet the Federal Motor Vehicle regulation incorporated by reference into the standard?

Dear Mr. Kunz:

Inspection, testing, and operation requirements for Woltman PVE 5021S pile driving equipment.

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 19, 2004

 

 

Fall protection requirements for work docks/bridges used during bridge 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.

February 9, 2004

Mr. Jack Swarthout
Scott Bridge Company Inc.
PO Box 2000
Opelika, Alabama 36803

Re: Work docks and work bridges; scaffolds; fall protection; working over water

Dear Mr. Swarthout:

This is in response to your letter of October 24, 2002, to the Directorate of Construction. We apologize for the long delay in providing this response.

We have paraphrased your questions as follows: