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Fall-protection criteria for power-distribution maintenance

Summary A power-distribution employer asked whether revised construction fall-protection rules changed the general-industry rules for maintenance crews. OSHA said the maintenance duties remained the same; only the cross-reference for equipment criteria had moved to the new construction subpart. OSHA now labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-09-01-0
Date issued
September 1, 1995
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 1, 1995

Mr. Lance Murray
Safety Representative
General Atomics
[Recipient address omitted]
Dear Mr. Murray:

Your letter addressed to Mr. James Foster, dated October 14, 1994, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing fall protection in the power distribution industry, (29 CFR 1910.269 and 29 CFR 1926.502) was forwarded to the Office of Construction and Maritime Compliance Assistance for response.

With regard to how the construction fall protection standard relates to maintenance operations, please be advised that the fall protection requirements contained in paragraph 1910.269 for maintenance activities are unaffected. The only change to 1910 was to paragraph 1910.269(g)(2). When the fall protection equipment criteria in 1926, Subpart E was revised and moved to Subpart M, the reference to 1926, Subpart E in paragraph 269(g)(2) was amended to reference the new fall protection equipment criteria in 1926, Subpart M. With this exception, all standards related to your maintenance operations remain the same.

If you have any further questions on this matter, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Thank you for your interest in occupational safety and health.

Sincerely,
Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Compliance Assistance

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