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Administrative stay of fall protection requirements for steel erection

Summary An industry association asked about fall protection requirements for steel erection. OSHA said Subpart M was administratively stayed as applied to steel erection on nonbuilding structures and that it was developing a memorandum to clarify the stay's scope. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-03-01
Date issued
March 1, 1995
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OSHA labels this an archive document and warns that it may no longer represent current policy.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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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent current policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 1, 1995

Mr. William Shuzman
Executive Director
Allied Building Metal Industries, Inc.
[Recipient address omitted]
Dear Mr. Shuzman:

Thank you for your letter of January 12 in which you request clarification of the Occupational Safety and Health Administration (OSHA) policy on steel erection fall protection requirements. I apologize for the delay of this response.

As you may know, Subpart M -- Safety Standards for Fall Protection in the Construction Industry has been stayed administratively as to its application to steel erection activities on non-building structures. To further define the scope of the stay action, we are in the process of developing a memorandum to clarify various terms such as "building," "non-building structure," "steel erection activities" and "tiered." As soon as that effort is completed, we will forward a copy to you.

In the meantime, if you have additional questions, please do not hesitate to contact Mr. Roy F. Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 219-8136.

Sincerely,
James W. Stanley,
Deputy Assistant Secretary

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