OSHA Interpretations Flowing Again

The latest two are dated Sept. 30 and Oct. 1. Both concern interpretations of construction standards.

Watchers of OSHA's letters of interpretation online page know the glacial pace of updates to the page sometimes becomes fully frozen. But two new letters dated Sept. 30 and Oct. 1 are posted, both concerning construction standards. They're the first new letters since early August.

The Sept. 30 letter from Ben Bare, acting director of OSHA's Directorate of Construction, answers a query asking whether OSHA will rely on the Z369.1-2007 standard for snaphook compressive strength requirements when it enforces the general duty clause for personal fall arrest systems used in construction. Bare answered no and said OSHA is rescinding letter #20070920-8088, which relied on Z369.1-2007 as to snaphooks on personal fall arrest systems used in construction.

He explains that Z369.1-2007 sets forth a 3,600-pound, gate compressive strength test but does not apply to construction. However, ANSI A10.32-2004, Fall Protection Systems - American National Standard for Construction and Demolition Operations, does in section 4.5.3, which Bare said should be followed to determine the sufficiency of construction fall protection snaphooks. The section says: "The snaphook or carabiner shall be capable of withstanding a minimum load of 220 pounds without the gate separating from the nose of the snaphook or carabiner body by more than 0.125 inch when tested in accordance with Section The gate of the snaphook or carabiner shall be capable of withstanding a minimum side load of 350 pounds when tested in accordance with Section Failure shall be defined as permanent deformation of the gate more than 0.125 inch, or separation of the gate from the body of the snaphook or carabiner body by more than 0.125 inch."

The Oct. 1 letter explains that the underground construction standard, 29 CFR 1926.800, applies to an underground pipejacking operation. (For some reason, this answer came almost four years after the question was posed.)

Bare's letter says 29 CFR 1926.800 applies because an employee who enters the pipe casing in such an operation does so when the tunnel or shaft is still under construction, and 29 CFR 1926.800 (a)(1) states: "This section applies to the construction of underground tunnels, shafts, chambers, and passageways...."

The regulation applies when a manhole connects to an active underground construction operation and conditions expose an employee within the manhole to hazards typical of underground construction, Bare explained.

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