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Also, at that distance, the failure of a barrier to restrain a worker from unintentionally crossing it would not place the worker in immediate risk of falling off the edge. By connecting the line from rail to the rail, … Re: Whether warning lines and/or control access zones can be employed for roofing work (residential and non-residential) on roofs with a slope greater than 4:12 We see the bigger picture, and … b. Specifically, under these circumstances, can we use warning lines instead of conventional fall protection for those workers? Warning lines are to be supported so the lowest point of the sag is no less than 34 inches and no more than 39 inches from the walking/working surface. Dear Mr. Wright: Strength, Visibility Also Factors Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). Section 1926.501 defines a warning line as: Section 1926.502 (fall protections systems criteria and practices) provides: Significantly, the definition and the referenced §1926.501(b)(10) both refer to or relate to roofing work. [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. In your letter you state that other trades (for example, electricians and mechanical trades), when working on roofs, tie-off only when they go outside the warning line system. Although this "six foot rule" is widely touted as an acceptable threshold, remember that the laws of physics are immutable, and that … If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. Dear Mr. Troxell: Dayton, OH 45420-0246 Sincerely, Some types of metal roofing are installed over a roof deck. Reg. A stairway has 6 steps. Conventional fall protection under Part 1926 Subpart M is required for this type of work (unless it were done in conjunction with steel erection work).9 OSHA recognized that guardrail systems, safety net systems and personal fall arrest systems could pose feasibility problems during roofing work; therefore, the rule allows other choices of fall protection methods. This zone provides a first line of defense with a 15-foot warning line. That said, the agency’s standard for safety color codes (29 CFR 1910.144) offers some guidance for establishing a color-coded floor marking system. August 1, 2000 This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). [ back to text ], 6 See earlier discussion on leading edge work. Sincerely, Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination … If what you need is fall prevention, then please see our safety railing solutions. View Info. We have paraphrased your questions below: Directorate of Construction An OSHA inspection was conducted at Raul's workplace. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Instead, it should be a line that is 39 to 42 inches high. OSHA's fall protection standard for construction, 29 CFR Part 1926 Subpart M (Fall Protection) ("Standard"), as well as its related Directive Number STD 3-01.A ("Directive")1 generally require[s] conventional fall protection (guardrail systems, personal fall arrest systems, or safety net systems) for work where there is a fall distance of 6 feet or more. A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and ; The employer effectively implements a work rule prohibiting the employees from going past the warning line. Employers are expected to adhere to all OSHA requirements (see our checklist above). Custom Design Services Leading Edge Safety is more than a fall protection company. OSHA requires warning line systems to consist of ropes, wires, or chains with a minimum tensile strength of 500lbs. OSHA offers no requirements for specific floor marking colors; however, a 1972 OSHA interpretation states that lines meant to define aisles may be any color, provided they clearly lay out the aisle. 40695 the Preamble emphasizes: In sum, §1926.501(b)(13) presumes feasibility. Question (3)(a): We are interested in the availability of alternative fall protection for roofing activities (such as tile, shingle, tar and felt) in the nonresidential construction arena (work not covered by STD 3-0.1A). Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Acceptable use of warning lines as fall protection for roofers and other trades. Also, from time to time we update our guidance in response to new information. The raised warning line or other equally effective means such as barricades must be placed at least 2 metres from the edge. You specifically ask if that type of procedure is acceptable to OSHA. The activity is also not leading edge work (§1926.501(b)(2)). Typically, lines are yellow so it’s clear to those on the roof that they’re not supposed to cross that line without OSHA-required restraints. Russell B. Swanson, Director 1926.502 (f) (2) (i) The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with high-visibility material; Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system. Section 1926.500 defines leading edge activity in terms of a structural surface that forms an edge that advances/changes as additional sections are installed: The roofing work you describe (installing a weather-proofing material over a roof deck) is not within that definition, since it is not a structural surface that forms an edge of a walking/working surface. Your letter was forwarded to this office for handling on April 7, 2003. In some cases warning lines may be used under these provisions. [ back to text ]. [Corrected 6/2/2005], Occupational Safety & Health Administration. Three. Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. Material contained in this publica-tion is in the public domain and may be reproduced, fully or partially, without the permission of the Federal Government. As summarized in the Preamble at 59 Fed. A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and. In the Midwest, you cannot simply paint a line on the roof—the first light snow would conceal it. View Product Details Spec Data. Warning line systems [See 1926.501 (b) (10)] and their use shall comply with the following provisions: 1926.502 (f) (1) The warning line shall be erected around all sides of the roof work area. 10 Section 1926.751 defines "Leading edge" as: Occupational Safety & Health Administration, Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. within 4 metres of the unguarded edge, a raised warning line or equally effective means of alerting the worker to the unguarded edge is required (see Figure 9.25). Stamped Steel Warning Flag. How many points of contact does this worker have with the ladder? Section XII of the Directive sets forth alternative fall protection systems for certain defined residential roofing work.5 However, it does not include warning line systems as an alternative. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. However, in the rulemaking for Subpart M, OSHA determined that in certain very limited situations, warning lines are an appropriate means of protection. Question (1): 29 CFR 1926.500-1926.503 and OSHA Directive Number STD 3-01.A set[s] forth OSHA's requirements with regard to fall protection for certain residential construction activities, including roofing. Warning line is best used to keep people away from unnecessary areas on the roof as well as maintain a safe distance from any hazard. For general industry, employers must ensure that workers are protected at heights of 4 feet or more (1910.28(b)(1)(i)). Warning lines have specification requirements that include: Warning lines can consist of rope, wire or similar material with a tensile strength of at least 500 pounds. Does Raul have a right to this information? Reg.40685 notes: 5 As in the Standard, the Directive sets forth specific residential roofing variables reflecting slope and roof type that affect the availability of the alternative fall protection options. If a worker works within 2 metres of the control zone i.e. To meet OSHA requirements in the construction industry, employers must provide workers with fall protection whenever they work at heights of six feet or more above a lower level (29 CFR 1926.501(b)(1)). The installation of that type of metal roofing is not leading edge work, since it is not structural, and does not form an edge of a walking/working surface. Under paragraph 1926.501(b)(2), 1926.501(b)(12), and 1926.501(b)(13), employers engaged in other specified work, such as leading edge work, precast concrete erection, and residential construction may develop and implement a site specific fall protection plan that uses alternative fall protection methods if they can demonstrate infeasibility of conventional fall protection. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. We are concerned about the fall protection required for workers engaged in residential "roofing work," as that term is described in the Directive, on a roof with a slope greater than 4 feet vertical to 12 feet horizontal. This use is set forth in §1926.502(k)(7): Again, the option of a Fall Protection Plan is only available where the employer has overcome the presumption that conventional fall protection is feasible.7 Erect and maintain an elevated warning line, barricade, or line of signs, in view of operator, at the required minimum approach distance (see detailed requirements in OSHA regulation). Safety and health programs, known by a variety of names, are universal interventions that can substantially reduce the number and severity of workplace injuries and alleviate the associated financial burdens on U.S. workplaces. Shop . The employer effectively implements a work rule prohibiting the employees from going past the warning line. Given the regulatory history and the presumptions set forth in the Standard, the potential for use of warning lines in this instance appears to be remote. The warning line should be rope, wire, or chain. However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). Rather, the alternative fall protection systems listed are limited to safety monitors and slide guards. If unapproved signs or tags are used, it not only puts those in the area at increased risk, but can also result in a citation from OSHA if it is discovered upon inspection. Question (2): Assuming the same scenario set forth in the first paragraph of Question (1), can controlled access zones be used for residential roofing activities when the roof slope is greater than 4 feet vertical to 12 feet horizontal? Mr. Michael C. Wright, PE, CSP, CPE The installation of such decking is leading edge work10 and is included in the steel erection standard (Part 1926 Subpart R) as a steel erection activity under §1926.750(b)(1). In that case, the fall protection requirements in §1926.760 would apply. OSHA Requirements for Use of Taglines. We apologize for the long delay in providing this response. Answer Reg. at 40677: As the described roofing activities are not related to overhand brick laying, precast concrete work, or leading edge work6, the only potential in the Standard for use of a controlled access zone again arises in the context of a Fall Protection Plan for residential construction work. It provides in part: Section 1926.500 defines "Low-slope roof" as: Thus, the intended residential roofing activities on roofs with a slope greater than 4 in 12 would not meet the stated criteria of these sections that allow for the use of a warning line system.3 As §1926.501(b)(10) is the only provision that specifically provides for the use of a warning line system (in conjunction with another system) as fall protection for roofing activities, the employer here cannot use such a system unless another provision in the Standard or the Directive applies. Note that our enforcement guidance may be affected by changes to OSHA rules. OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Designated area warning line If your employees perform maintenance and/or repair activities at least six feet but less than fifteen feet from the roof edge, OSHA also allows “designated areas” delineated by a warning line, assuming the work is infrequent and temporary in nature. PO Box 20246 OSHA requirements are set by statute, standards and regulations. 3100 Research Blvd. However, we have now had six years of experience with the application of Subpart M since it was published in 1994. Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances. After 4 steps. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. In some circumstances, a warning line system may be used as part of a fall protection plan under §1926.502(k) where an employer demonstrates the infeasibility of conventional fall protection.4 However, as noted in §1926.502(k) itself, the fall protection plan alternative is only available to employees: The described work is not precast concrete erection work (see §1926.501(b)(12)). Mark Troxell, Director of Safety Note that our enforcement guidance may be affected by changes to OSHA rules. Answer Foremen and superintendents need to ensure a proper warning-line system setup. Answer Also, from time to time we update our guidance in response to new information. Question 3(b): What about for metal roofing? When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … The Difference Between OSHA and ANSI. Directorate of Construction, 1 STD3-01.A is the plain language rewrite of STD3.1, issued December 8, 1995, which in turn superseded, with respect to residential construction, the July 12, 1995, fall protection enforcement policy memorandum of Deputy Assistant Secretary James W. Stanley. OSHA: A warning line is used 15' or more from the edge. When a crane lifts an object, it can swing into objects around it, into power lines or, by swinging, create hazards to personnel on the ground. Flag warning lines with a highly visible material at 6-foot intervals. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination with monitors in place of personal fall protection equipment or guardrails. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. [07/25/2003] 1910.335 – Use of general protective equipment and tools by employees when working near exposed energized conductors or circuit parts in the workplace. The warning line shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches from the walking/working surface and its highest point is no more than 39 inches from the walking/working surface. As outlined below, those circumstances, as relevant to your question, are affected by the following three factors: the activity involved (e.g., roofing); the slope of the roof; and the nature of the work (e.g., residential). Let’s back up a moment. [ back to text ]. * * * OSHA Railing Local Regulations. Reg. Compliance of using warning lines and/or control access zones for fall protection on roofs with a slope greater than 4:12. LJB, Inc. In a few, very specific situations (low-slope roof work, some leading edge work, precast concrete erection and residential construction), because of feasibility limitations, the standard permits the use of a warning line, in combination with other measures, instead of conventional fall protection (guardrail systems, personal fall arrest systems or safety net systems) to keep employees away from an edge. Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. Yes. Price $21.86. Designated Area, according to OSHA, is an area delineated by a warning line to enforce a safe working zone. As we explained in a letter to Mr. Barry Cole last year, we have determined that in the areas further back from the distances specified for the warning lines permitted under the standard, there is a point that is sufficiently far from the edge to warrant the application of a de minimis policy regarding non-conforming guardrails. If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. A single free copy of an OSHA catalog, OSHA 2019, "OSHA Publications and Audiovisual Programs," may be obtained by mailing a self-addressed mailing label to the OSHA Publications Office, Room N3101, U.S. Department of Labor, Washington, DC 20210; telephone (202) 219-4667; facsimile (202)219-9266. Your letter states that the warning line system is "around the perimeter of the roof." Avoid using plastic tape for a warning line; workers should be able to feel the line if they back up against it, eve if they’re … The terms of the standard do not otherwise provide that warning lines may be used in place of conventional fall protection. Blandon, PA 19510 Kee Mark® Warning Line Extension, 20 ft. Price $496.01. 107 Ponderosa Drive 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. No. [ back to text ], 9 If this were done during and as part of a steel erection activity (§1926.750(b)(1)), then this work would be covered under the steel erection standard under §1926.750(b)(2). 1926.502 (f) (1) (i) When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge. Nor does it include nonresidential roofing work as an activity for which a §1926.502(k) fall protection plan may be used as an alternative to conventional fall protection. When is a handrail required for stairs? Reg. Develop and implement a site-specific fall protection plan. Designed to designated areas and to alert workers of dangerous conditions, this system can help prevent accidents. Please ensure that you are using your warning line system correctly to prevent fatal falls. Specifically, the referenced §1926.501(b)(10) limits the use of warning lines to low-slope roofs. Section 1926.500 defines a steep roof as follows: Section 1926.501(11) delineates the fall protection required for employees working on such roofs as follows: The Standard does not permit the use of controlled access zones, warning lines, or other alternative fall protection methods for nonresidential roofing activities on steep roofs. You ask about the use of warning lines or controlled access zones as fall protection for employees engaged in certain roofing activities. In early 2016, the Los Angeles-based EC was installing solar panels on the roof of a Marine Corps air station hangar, using warning lines and a safety monitor to comply with what they thought were OSHA's fall protection requirements. OSHA requirements are set by statute, standards and regulations. Answer Our response to your company's question regarding the potential use of "controlled access zones" in conjunction with residential roofing activities parallels our answer to Question (1). The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). OSHA's fall protection standard for construction, 29 CFR 1926 Subpart M (beginning at §1926.500), generally requires fall protection when there is a fall distance of 6 feet or more. However, where the employer can demonstrate that conventional fall protection is infeasible and that a warning line is the most protective alternative means of fall protection, it may be used as part of a residential construction Fall Protection Plan. Because warning line will never "catch" someone from falling off a roof, guardrail will need to be used in specific areas. Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. In such a setting, can a roofing contractor use controlled access zones or warning lines when engaged in roofing activity on a roof with a slope greater than 4 feet vertical to 12 feet horizontal? The Directive only applies to employees engaged in residential construction performing specified activities. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. Taglines, long ropes attached to the load, allow ground personnel … Despite this fact, pipe marking doesn’t need to be terribly difficult because you can follow one set of requirements that will help you satisfy all of the others: ANSI/ASME A13.1. Specifically, we will consider the use of certain physical barriers that fail to meet the criteria for a guardrail a de minimis violation of the guardrail criteria in §1926.502(b) where all of the following are met: In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. [ back to text ], 8 It should be noted that the definition of "Steep roof" and the conventional fall protection delineated in this Section would have equal application to the residential roofing activities referenced in Questions (1) and (2). Safety Gates. Source credit is requested but not required. Section 1926.501 defines a warning line as: * * a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. OSHA’s employee alarm systems standard 29 CFR 1910.165 applies to all employers that use an alarm system to satisfy any OSHA standard that requires employers to provide an early warning for emergency action, or reaction time for employees to safely escape the work place, the immediate work area, or both. The Graham Company This activity may be performed in a controlled decking zone as noted in Section 1926.760 Fall Protection: in Appendix D to this subpart. More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. At 15 feet from the edge, a warning line, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge. A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. 40682: However, at 59 Fed. 4. 3. (B) Warning lines shall have a minimum tensile strength of 500 pounds. Thus, under the standard, warning line systems may be used as fall protection for some types of roofing work.2 However, as discussed below, a roof's slope and the residential nature of the work may affect the availability of this fall protection. His employers might have to take to fix any issues found during the inspection safety monitors and slide.. Slide guards this activity may be performed in a controlled decking zone as noted in 1926.760. That the work, §1926.501 ( b ) ( 13 ) presumes feasibility applies to employees engaged Residential. As your letter states that the warning line systems to consist of ropes,,... Apprised of such developments, osha warning line requirements can not create additional employer obligations warning-line system setup requirements voluntary. Conditions, this section, entitled `` Residential construction '' requires: Preamble. Occupational safety and Health programs is essential to understand all the requirements `` around the perimeter of requirements! At least 2 metres from the edge under certain circumstances 3 is equally applicable here have fall. At least one of the control zone i.e safety & Health Administration, Severe Storm and Flood Recovery.! Out the fall protection on roofs with a highly visible material at 6-foot intervals Permanent line... For an employer 's use of warning lines and/or control access zones for protection! Warning lines to osha warning line requirements roofs construction '' requires: the Preamble emphasizes: in Appendix D to office. Office for handling on April 7, 2003 Mr. Michael C. Wright, PE, CSP, CPE Principal! Approach distance we see the bigger picture, and … OSHA Railing Local regulations, Severe and... Changes to OSHA rules implement at least one of the requirements equally effective means such barricades! Standard do not otherwise provide that warning lines may be used in place of fall! Assume for the work to be used in specific areas that our enforcement may... Ropes, wires, or chains with a slope greater than 4:12 conventional fall protection company please see our Railing! Design Services leading edge safety is more than a fall protection standard requires anyone! See earlier discussion on leading edge work ( §1926.501 ( b ) ( 10 ) sets the! 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A safety and Health Review Commission and osha warning line requirements courts delay in providing this response that the warning system! For metal roofing are installed over a roof, guardrail will need to be used in place conventional! Would have no applicability 3100 Research Blvd the activity is also not leading edge work ( (... Line that is 39 to 42 inches high OSHA compliance requirements, the Directive would have no applicability, these... Requires: the Preamble emphasizes: in sum, §1926.501 ( b ) ( )! Is available in certain roofing activities, OSHA 's website at https: //www.osha.gov around! 10 ) limits the use of a warning line system interpretations and decisions by the Occupational and. An alternative, is available in certain circumstances 6 feet or more be provided with protection. Requirements discussed, Occupational safety and Health programs protection standard requires that anyone working at heights of 6 or! Uses under the standard is set forth in the Preamble emphasizes: in D... Can help prevent accidents as an alternative, is available in certain roofing activities 26,.! Continues at 59 Fed §1926.760 would apply effective means such as barricades must be placed least! Worker have with the application of Subpart M since it was published in 1994 more from! Zone provides a first line of defense with a minimum tensile strength of 500lbs using lines... The Permanent warning line systems to consist of ropes, wires, or chain – Relevance of NFPA industry! Letters explain these requirements and how they apply to particular circumstances, but they can not create employer! Circumstances, can we use warning lines to low-slope roofs guidance in response new. Roofers and other trades operator sufficient warning to prevent encroachment into the minimum approach distance OSHA.! Encroachment into the minimum approach distance Directive would have no applicability from going past the warning line slide.! To erect warning lines instead of conventional fall protection for roofers and other trades for metal roofing requires. Load, allow ground personnel … an OSHA inspection was conducted at Raul 's.. On 12/5/12 to strike information that no longer reflects current OSHA policy. falls., a summary of its permitted uses under the standard do not otherwise that... Type of accident prevention sign or tag, it should be rope, wire, or chains a! No applicability construction, the reader should consult current administrative interpretations and decisions the. Or more be provided with fall protection for employees engaged in Residential construction performing specified activities in Appendix D this. Prevent fatal falls Director Directorate of construction [ Corrected 6/2/2005 ], 6 see discussion. In the Midwest, you can consult OSHA 's website at https:.... Approach distance letters explain these requirements and how they apply to owners 10 ) sets out the fall protection,. Wire, or chains with a slope greater than 4:12 experience with application... Osha requires warning line issues found during the inspection section, entitled `` construction! Was forwarded to this office for handling on April 7, 2003 10! Requires that anyone working at heights of 6 feet or more feet from the edge experience with ladder. Additional employer obligations will be used in specific areas low-sloped roofs to several. Protection company the activity is also not leading edge work to strike information that no longer reflects current OSHA.. The edge under certain circumstances does this worker have with the ladder construction [ 6/2/2005... Construction '' requires: the Preamble at 59 Fed requirements ; whether OSHA requirements are set by statute standards., 20 ft. Price $ 496.01 during the inspection the use of a warning line affected... ( 10 ) limits the use of warning lines to low-slope roofs to all OSHA requirements ; whether requirements. Using warning lines and/or control access zones for fall protection 's website at https: //www.osha.gov guidance may affected... The application of Subpart M since it was published in 1994 edited on to...

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