- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements 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 https://www.osha.gov.
October 5, 1978
Mr. Russell E. Jones
P.O. Box 2268
Tucson, Arizona 85702
Dear Mr. Jones:
This is in response to your letters of August 10, and September 7, 1978. In your letter you posed the question: "Is an iron worker connector required to tie off when performing work as a connector and when going to and from such work?"
An iron worker may be exposed to many unique hazards among which is the severe hazard of falling. Due to the nature of the work, a fall often results in serious physical harm and/or death. The problems associated with safety protection for iron workers, within a constantly changing environment, are complex. To specifically direct any one form of protection is not OSHA's intent nor do the regulations so require. The employer is required, however, under the law, to provide safeguards for his employees. Tie offs may, under some circumstances, offer hazard to iron workers operating as connectors. Safeguards such as safety nets may be rigged beneath the workers in lieu of tie offs. In either events, the iron worker's safety must be provided for.
Regarding the access and egress of the iron worker while proceeding to and from work locations upon the structure being erected, the iron worker shall be protected from injurious falls by some safety precautionary measures determined appropriate and implemented by the employer.
Coordination with the Lubbock Area Office revealed that the citation issued under 29 CFR 1926.28(a) also referenced 29 CFR 1926.105(a), and various alternates providing worker protection from injurious falls. The files indicate no protection of any sort had been afforded by the employer.
In conclusion, a requirement for the tie off or iron workers while performing connector operations is not always required and indeed such procedure may be more hazardous. However, an alternative form of protection must be provided by the employer. Protection from falls must also be provided during access and egress. Reference 29 CFR 1926.750(b)(1)(ii); 29 CFR 1926.28(a) and (b); and 29 CFR 1926.105.
If I may be of further assistance, please do not hesitate to contact me.
Sincerely,
John K. Barto, Chief
Division of Occupational
Safety Programming