OSHA standards applicable to overhead doors at fire departments

September 10, 2002

Mr. Paul R. Nielsen

SDS, Inc.

[Recipient address omitted]

Dear Mr. Nielsen:

Thank you for your December 18, 2001 letter to the U.S. Department of Labor, Occupational Safety and Health Administration's (OSHA's). This letter constitutes OSHA's interpretation only of the requirements discussed herein, and may not be applicable to any question or scenario not delineated within your original correspondence. You had specific questions regarding OSHA requirements for overhead doors. Please accept our apology for the delay in responding to your letter.

Question: Are there any OSHA standards or requirements on overhead doors which are located in local city and county fire departments?

Response: There are no specific OSHA standards or requirements for overhead doors, regardless of their location. Since you did not state in your letter whether you are providing service, maintenance, and/or installation on automatic or manually operated doors, we will assume that your business would be classified in General Industry. Therefore, the General Industry Standards, 29 CFR 1910, may apply. However, if you are repairing or installing overhead doors, you may be covered under the Construction Standards, 29 CFR 1926. Please review 29 CFR 1910.12, Construction Work, for additional guidance and to determine the applicability of these standards.

As you may know, the State of North Carolina administers its own occupational safety and health program under provisions of the Occupational Safety and Health Act of 1970. While the state must promulgate safety and health regulations that are "at least as effective" as the federal standards, they may also be more stringent. North Carolina also offers free on-site consultation services to those employers who request guidance on compliance with occupational safety and health standards. In order to obtain North Carolina's position on this issue or access the consultation services, you should contact:

North Carolina Department of Labor

4 West Edenton Street

Raleigh, NC 27601-1092

Phone: (919) 733-0359

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirement and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director

Directorate of Enforcement Programs