Tunnel rules for cut-and-cover subway stations

September 23, 1980

Mr. John P. Murray
Project Safety Manager
Parsons Brinckerhoff/Tudor
[Recipient address omitted]
Dear Mr. Murray:

This is in response to your letter, concerning cut and cover construction in the Atlanta subway project.

We have contacted the Regional and Area offices in Regions III and IV regarding cut and cover tunnel construction and the enforcement of OSHA Instruction STD 3.1. Our review of this matter indicates that the Regions are uniformly enforcing the cut-and-cover instruction which became effective on December 1, 1979. However, it is true as you indicated in your letter that Area Directors do not always apply tunnel safety standards to underground subway stations. Underground subway stations are not always tunnels. The tunnel standards are enforced when a cover, temporary or permanent, extends over the top of the subway station excavation to the extent, that hazards such as those existing in tunnel operations, may be present.

If you still are of the opinion employees are exposed to preventable hazards in underground areas, please provide us with additional details or the employee work exposure, location, etc., and this office will review the situation and provide a determination in accord with our guidelines. I have enclosed for your information a copy of OSHA Instruction STD 3-17.1, formerly OSHA Program Directive 100-55, which permits gas welding and cutting underground under carefully prescribed conditions.

It is noted that the construction standards are minimum safety and health requirements. Employers may enforce more stringent controls for the protection of their employees on their job sites.

I hope this information will we helpful. If we may be of further assistance, please feel free to call or write.

Sincerely,
Bruce Hillenbrand
Acting Director,
Federal Compliance and State Programs