Ironworker fall protection during beam and column connection

February 7, 1992

MEMORANDUM FOR: BYRON M. CHADWICK
REGIONAL ADMINISTRATOR

THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Fall Protection During Steel Erection

This is in response to your August 7 facsimile of an August 7 letter to you from Mr. Mitch B. Wisenor of MK-Environmental Services concerning fall protection for ironworkers. We apologize for the delay in responding to you.

We have been advised by the Office of the Solicitor that Review Commission cases have determined that, other than 29 CFR 1926.105(a), there are no specific fall protection provisions outside Subpart R that apply to steel erection connection related activities. Consequently, the general duty clause is the only provision that can be cited for steel erection fall hazards where the fall distance is less than 25 feet. To assist in establishing the existence of the necessary four elements of a (5)(a)(1) citation, the National Office is developing an information package for use by all regions. Although not complete at this time, the information that has been compiled may be obtained by contacting Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.

[Requester letter reproduced on OSHA page; omitted here.]