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

Clarification of 'at least every 12 months' annual crane inspection 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.

September 10, 2015

Mr. Thomas A. Cady, CSP
Senior Safety Manager
The Boldt Company
2901 Business Park Drive
Stevens Point, WI 54482

Dear Mr. Cady:

Installing a barrier film over asbestos-containing flooring

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.

April 21, 2014

Douglas R. Lawson, Ph.D., CIH
URS Corporation
1155 Elm St, Suite 401
Manchester, New Hampshire 03101

Dear Dr. Lawson:

Rationale for and hazards of hoisting compressed gas cylinders

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.

April 9, 2015

Cole Miner, NYC SSM, CSFSM
7 Irma Avenue
Port Washington, NY 11050

Dear Mr. Miner:

Clarification of 1904.31 regarding who is responsible for recording injuries and illnesses when supervision is shared by a prime contractor and subcontractors.

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.

April 25, 2017

Mr. Fred Hartz
Holtec International
200 Braddock Avenue
Turtle Creek, PA; 15145

Dear Mr. Hartz:

Interpretation of what constitutes a salt of 4,4' Methylenedianiline (MDA)

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.

April 21, 2014

Mr. Charles E. Barbieri
Foster Swift Collins & Smith PC
313 S. Washington Square
Lansing, Michigan 48933

Dear Mr. Barbieri:

Compatibility requirements of fall protection equipment from different manufacturers.

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, 2012

Chris Medina
204 Manuel Court
Bay Point, CA 94565

Dear Mr. Medina:

Definition of multi-employer worksite

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 20, 2012

Allen L. Clapp, P.E., P.L.S.
President
Clapp Research Associates, P.C.
6112 Saint Giles Street
Raleigh, North Carolina 27612

Dear Mr. Clapp:

Fall protection for workers having to walk/work along bridge decks when the edges are finished with a 32 in. high barrier wall.

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 3, 2013

Mr. Larry Fortier CRSP
District HSE Manager
PCL Constructors, Inc.
Transportation Infrastructure Group
3810 Northdale Boulevard
Suite 200
Tampa, Florida  33624

Dear Mr. Fortier:

Regulations governing sloping and benching systems for 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 2, 2013

André K. Catellier, PE, President
RNR-Construction Incorporated
8589 Thys Court
Sacramento, CA 95628

Dear Mr. Catellier:

Thank you for your August 23, 2012 letter to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in our reply.

Allowable gap requirement between the trench shield and trench sides.

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 11, 2013

Ken Edwards
Technical Director
Association of Equipment Manufacturers
6737 W. Washington Street, Suite 2400
Milwaukee, WI 53214

Dear Mr. Edwards: