Standard Interpretations - Table of Contents|
| Standard Number:||1926.502(k); 1926 Subpart M App E|
Mr. Philip Torchio V.P., Corporate Services
Atlanta Steel Erectors, Inc.
1285 Hawthorne Avenue
Smyrna, Georgia 30081
Dear Mr. Torchio:
Thank you for your letter dated January 20 concerning safety plans as set forth in Subpart M -- Fall Protection for the Construction Industry.
The sample pre-cast concrete erection safety plan listed in Appendix E of Subpart M is a generic type plan that has the potential of being applied to every worksite. However, it should never be used without the contractor first reviewing it in its entirety to confirm that it properly addresses the fall hazards at a given worksite. Although I did briefly review the plan used in Appendix E, I did so with an eye towards the concept of using such a plan to address fall hazards; I did not intend to "approve" the plan for use without further site specific concerns being addressed. As you recognize in your letter, plans will be evaluated, as appropriate, by OSHA field staff; I will not be reviewing plans personally.
The concept of "greater hazard" centers on whether or not compliance with a standard would result in greater hazards to employees than noncompliance. In addition, there must be no alternative means of employee protection and application of a variance would be inappropriate. The answers to these questions are often site dependent. With these concepts in mind, the sample plans in Subpart M have been evaluated and accepted as meeting the requirements of the greater hazard concept in a generic sense and specifically for those activities identified in the sample plans. They must still be reviewed by the contractor