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Steel erection fall protection and OSHA rulemaking

Summary A steel erection company asked about OSHA policies concerning fall protection, citations and the industry's concerns with the standard. OSHA declined to discuss the company's citations outside the litigation process, said they were based on alleged violations rather than politics, and declined to intervene in a separate Christmas-treeing matter. It said the steel erection standard was under review and invited the company to participate in the rulemaking process.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-07-08-0
Date issued
July 8, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 8, 1994

Ms. Mary E. Sharp
Secretary/Treasurer
L.R. William & Sons, Inc.
[Recipient address omitted]
Dear Ms. Sharp:

Thank you for your letter of May 17, in which you express your concerns about the Occupational safety and Health Administration (OSHA) policies in regard to fall protection during steel erection activities at your worksites.

As you know, in regard to the citations issued for your Orlando, Florida project, it is not appropriate to discuss this matter outside the proper litigation channels. However, I can state categorically that the citations were not issued for any political purposes. They were issued for observed alleged violations of OSHA's standards.

With regard to the Christmas-Treeing issue, there has already been substantial communication with your company on this subject conducted at appropriate lower levels. It is not necessary for me to intervene at this point in time.

In closing, let me assure you that the objectives stated in "ABC Today" remain my objectives. With the steel erection standard now being reviewed, we are moving in the direction necessary for resolving many of the concerns of the steel erection industry. Although Mr. Willson was not selected to participate on the requested rulemaking committee, the proper selection process was followed and was in no way politically manipulated. I look forward to your company's full participation in other portions of this rulemaking process.

Sincerely,
Joseph A. Dear
Assistant Secretary

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