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Applicability of underground-construction standards to sewer tunnel rehabilitation

Summary An OSHA regional office asked whether underground-construction rules applied to rehabilitation of a sewer tunnel built decades earlier. OSHA said the work created underground-construction conditions and hazards, so 29 CFR 1926.800 applied. This guidance matters to contractors restoring existing tunnels.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-01-29-1
Date issued
January 29, 1991
Status
Active
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1926 Underground Construction Tunnels
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

JAN 29 1991

MEMORANDUM FOR: MICHAEL G. CONNORS
Regional Administrator

THROUGH: LEO CAREY, Director
Office of Field Programs

FROM: PAT CLARK, Director
Directorate of Compliance Programs

SUBJECT: Applicability of 1926.800

This is in response to your memo on the above subject, concerning working on rehabilitation of a sewer tunnel that had been constructed in the years between 1926 to 1932.

During this type of underground work an employer would create conditions and hazards associated with underground construction that would be addressed and controlled by the applicable 1926.800 Underground Construction Standards. Therefore, the 1926.800 standards would apply.

If you have any other questions please feel free to contact Frank C. Memmott, Safety Engineer, of my staff on 523-8124.

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