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Worker exposure to impalement hazards while constructing upper rebar mats over rebar protrusions from lower levels

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.

March 27, 2006

Fred H. Codding
10382 Main Street
P.O. Box 280
Fairfax, Virginia 22030

Re: Worker exposure to impalement hazards while constructing upper rebar mats over rebar protrusions from lower levels; §1926.701(b)(1)

Dear Mr. Codding:

Whether it is permissible to use a concrete block hanging on a coupling pin as a counterweight to prevent a scaffold from tipping.

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.

June 17, 2005

Mr. Douglas A. Holman
1816 River Bend Road
Sevierville, TN 37876

Re: Whether it is permissible to use a concrete block hanging on a coupling pin as a counterweight to prevent a scaffold from tipping; §1926.451

Dear Mr. Holman:

Clarification as to whether operators of mobile cranes with operator cabs are subject to seat belt 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 27, 2004

Joel Marantan
Received via e-correspondence.

Dear Mr. Marantan:

This is in response to your question as to whether operators of mobile cranes with operator cabs are subject to a seat belt requirement. As described and further limited below, the answer depends upon whether the employee is driving that crane as opposed to being engaged in lifting operations at the job-site.

Clarification if a depression constitutes a hole or unprotected side/edge and associated fall protection 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.

September 30, 2004

Mr. Bob Kersten
Received via e-correspondence

Dear Mr. Kersten:

In your e-correspondence submitted June 28, 2004, and in subsequent telephone conversations with our staff, you asked about OSHA construction standards that pertain to a depression in a finished concrete ground floor.

We have paraphrased your question as follows:

Permissibility of using average excavation depth to determine protective system requirements for the excavation.

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 30, 2004 [Reviewed May 31, 2018]

Mr. Richard Johnston
Director of Loss
Hausmann Johnson Insurance
700 Regent Street
P.O. Box 259408
Madison, WI 53725-9408

Re: 29 CFR 1926.652(a)(1)(ii); whether averaging excavation depth is permitted for determining whether the protective requirements of §1926.652 apply.

Dear Mr. Johnston:

Whether the operator's cab of excavators must be equipped with seatbelts; §1926.602(a) and §1926.602(b).

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 9, 2006

Mr. Mark Troxell
Director of Safety Services
The Graham Company
The Graham Building
One Penn Square West
Philadelphia, PA 19102

Re: Whether the operator's cab of excavators must be equipped with seatbelts; §1926.602(a) and 1926.602(b)

Dear Mr. Troxell:

Whether plywood may be used as scaffold decking material over wood scaffold planks; 29 CFR 1926.450 and 1926.451.

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 18, 2006

Mr. Carroll Buchanan
ESI Group, Inc.
102 North 20th Street
Tampa, FL 33605

Re: Whether plywood may be used as scaffold decking material over wood scaffold planks; 29 CFR 1926.450 and 1926.451

Dear Mr. Buchanan:

This is in response to your fax submitted October 21, 2005, to the Occupational Safety and Health Administration (OSHA). Your question relates to the use of plywood as platform decking over wood scaffold planks. We apologize for the delay in responding.

Whether toilets at a construction jobsite must be in a sanitary condition to meet the requirements of 29 CFR 1926.51(c).

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 17, 2006

Mr. Daniel Noel
5521 Lanham Station Road
Lanham, MD 20706

Re: Whether toilets at a construction jobsite must be in a sanitary condition to meet the requirements of 29 CFR 1926.51(c).

Dear Mr. Noel:

Whether the motor on a portable concrete mixer has to be covered; 1926.300(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.

May 17, 2006

Mr. James Dean
7215 Mitchell Drive
Terrell, TX 75160

Re: Whether the motor on a portable concrete mixer has to be covered; §1926.300(b)(1)

Dear Mr. Dean:

This is in response to your letter dated July 29,2005, to the Occupational Safety and Health Administration in which you ask for guidance regarding the use of portable concrete mixers in construction applications. We apologize for the long delay in responding.

Do the requirements in §1926.756(c) apply to double connections made at a beam away from a column?

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 9, 2006

Mr. Doug Brown
General Manager
The Blackstone Group
6443 Inkster Road, Suite 270
Bloomfield Hills, Michigan 48301

Re: Do the requirements in §1926.756(c) apply to double connections made at a beam away from a column?

Dear Mr. Brown:

This is in response to your letter dated September 9, 2005, to the Occupational Safety and Health Administration. You ask for an interpretation of our Steel Erection standard, 29 CFR Part 1926 Subpart R. We apologize for the delay in responding.

We have paraphrased your question as follows: