Communication 

Tower Best Practices

OSHA 3877-062017
This document is advisory in nature 

and informational in content. It is not 

a standard or regulation, and it neither 

creates new legal obligations nor alters 

existing obligations created by OSHA 

standards or the Occupational Safety 

and Health Act. Pursuant to the OSH Act, 

employers must comply with safety and 

health standards and regulations issued 

and enforced either by OSHA or by an 

OSHA-approved state plan. In addition, 

the Act’s General Duty Clause, Section 5(a)

(1), requires employers to provide their 

employees with a workplace free from 

recognized hazards likely to cause death 

or serious physical harm.

Material contained in this publication is in 

the public domain and may be reproduced, 

fully or partially, without permission. 

Source credit is requested but not required.

This information will be made available to 

sensory-impaired individuals upon request. 

Voice phone: (202) 693-1999; teletypewriter 

(TTY) number: 1-877-889-5627. 

Cover photo: Vertical Limit
Communication Tower 

Best Practices

U.S. Department of Labor

Occupational Safety and Health Administration

and

The Federal Communications Commission

OSHA 3877-06 2017

Best practices in Communication Tower Safety, gathered from 

industry stakeholders and participants in the DOL/FCC Joint 

Workshops on Tower Climber Safety on October 14, 2014 and 

February 11, 2016.
Table of Contents

Introduction and Background . . . . . . . . . . . . 1

General Topics . . . . . . . . . . . . . . . . . . . . . . . . . 3

Tower Climbers and 

Ground Crew Employees . . . . . . . . . . . . . . . . 6

Carriers and Tower Owners . . . . . . . . . . . . . . 7

Turfing Vendors . . . . . . . . . . . . . . . . . . . . . . . 14

Tower Construction and 

Maintenance Contractors . . . . . . . . . . . . . . . 16

For More Information................... 22
FEDERAL COMMUNICATIONS COMMISSION

1

Introduction and Background

The Occupational Safety and Health 

Administration and the Federal 

Communications Commission are concerned 

about the risks faced by employees in the 

communication tower industry. Employees 

climb communication towers to perform 

construction and maintenance activities 

and face numerous hazards, including fall 

hazards, hazards associated with structural 

collapses and improper rigging and hoisting 

practices, and “struck-by” hazards. 

The business structure of the communication 

tower industry presents additional challenges 

to ensuring employee safety. When carriers 

own their own towers and directly employ 

the employees who build and maintain the 

towers and the equipment on them, the 

carriers have the ability and incentive to 

ensure safe practices. Typically, however, 

the relationship between carriers and tower 

employees is more complicated. For example:

■ Towers are often owned by separate 

corporations (not carriers, generally), and 

are built by contractors;

■ Carriers often contract with “turfing 

vendors” for the installation and 

maintenance of equipment on towers;

■ Turfing vendors, in turn, may hire other 

contractors to perform work; and

■ These contractors may sub-contract tower 

work to still smaller employers. 

As a result, carriers and tower owners 

may not know who is performing work for 

them, or when work is being performed. 

Thus, responsibility for employee safety 

is fractured into many layers. Instead 

of a single company having control and 

responsibility for employee safety and tower 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

2

integrity, employer responsibilities can be 

spread over numerous small employers. 

Additionally, the amount of communication 

tower work being performed waxes and 

wanes with waves of new technology. The 

work is physically demanding and requires 

employees to spend long periods of time 

away from home; hence, job tenure tends 

to be short and turnover tends to be high. 

In light of these circumstances, ensuring 

employee safety requires accountability and 

diligence throughout the contracting process, 

all the way from the carrier to the individual 

employee performing the work. 

Recognizing the risks that tower employees 

face, OSHA and the FCC held a workshop 

on communication tower employee safety 

on October 14, 2014. During this workshop, 

industry stakeholders, along with employee 

safety advocates and the families of 

communication tower employees who had 

been killed on the job, gathered to discuss 

issues affecting the safety of communication 

tower employees. A follow-up workshop was 

held on February 11, 2016, during which a 

panel of industry stakeholders and advocates 

discussed best practices that could reduce 

injuries and fatalities among tower employees.

This document is a collection of the best 

practices gathered from those workshops 

and from the discussions that continued 

beyond those events. These best practices are 

focused on the ways in which each level in the 

contracting chain can build a positive culture 

of safety and accountability. This cultural 

change is a critical first step in creating a safer 

environment for all employees in the industry. 

Some industry stakeholders have already 

begun to take major steps towards instituting 

this shift in policies, practices, and attitudes, 

and OSHA and the FCC are committed to 

supporting these efforts.
FEDERAL COMMUNICATIONS COMMISSION

3

General Topics

Safety and health programs

All entities should establish a comprehensive 

safety and health program. This program 

should address all of the hazards associated 

with communication tower work, and all 

companies should ensure that their safety 

and health programs are compatible with 

the safety requirements imposed by other 

companies in the contract chain.

The core elements of a comprehensive safety 

and health program include1:

■ Management leadership: Managers at 

all levels continually demonstrate their 

commitment to improved safety and health. 

Accountability and diligence is maintained 

at every level of the organization.

■ Employee participation: Employees are 

involved in all aspects of the program and 

understand their roles and responsibilities 

under the program and what they need to 

do to carry them out effectively.

■ Hazard identification and assessment:

Procedures are put in place to continually 

identify workplace hazards and evaluate 

risks, both job-specific and systemic. 

■ Hazard prevention and control: A plan is 

developed to ensure that hazard controls 

are implemented, to track progress, and to 

verify the effectiveness of controls once 

they are implemented.

■ Education and training: All supervisors 

and employees are trained to understand 

how the program works and how to carry 

out the responsibilities assigned to them 

under the program.

1. For more information on safety and health programs, 

see OSHA’s Recommended Practices for Safety and Health 

Programs at www.osha.gov/shpguidelines.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

4

■ Program evaluation and improvement:

Processes are established to monitor 

program performance, to verify 

program implementation, to identify 

program deficiencies and opportunities 

for improvement, and to take actions 

necessary to improve the program and 

overall safety and health performance.

■ Communication on multiemployer 

workplaces: Host and contract employers 

coordinate on work planning and 

scheduling to identify and resolve any 

conflicts that could impact safety or health. 

Safety and health programs and 

contracting practices

■ To maximize effectiveness, coordination 

of safety and health programs along the 

contracting chain should be managed by 

a designated person (for example, a Chief 

Safety Officer) to ensure clear lines of 

responsibility and accountability. 

■ This designated person will ideally have 

some personal experience climbing and 

working on towers or have a close advisor 

who has such experience.

■ The program should clearly delineate the 

roles and responsibilities of each party 

in the contracting chain in regards to 

employee safety and health. 

■ Abiding by these roles and responsibilities 

should be a condition of awarding contracts. 

■ The safety and health program should 

establish concrete consequences 

for contractors that do not take 

appropriate steps to ensure the safety 

of their employees. In some instances, 

termination of the contract may be an 

appropriate consequence.
FEDERAL COMMUNICATIONS COMMISSION

5

■ All lower-tiered contractors should 

be required to have written safety 

and health programs of their own. 

■ It is strongly recommended that contractor 

safety and health programs be reviewed 

on at least an annual basis to ensure that 

they are functioning as designed and to 

identify areas for improvement. 

Verification of subcontractors

Every entity in the contract chain should 

require lower-level contractors to have 

comprehensive safety and health programs 

in place that identify a Chief Safety Officer, 

and written verification procedures that can 

be adopted to ensure that contractors are 

implementing such programs. The verification 

process should include:

■ Clear criteria for vetting and approving 

all contractors (including subcontractors), 

and verification that all contractors are 

subject to the same vetting criteria;

■ Procedures for obtaining (or requiring 

contractors to maintain) certification and 

training records for each climber on site;

■ Procedures for obtaining written approval 

for any subcontracting; 

■ Procedures providing for the ongoing 

monitoring and evaluation of contractor 

safety records (including OSHA records);

■ Criteria for considering a contractor’s 

safety record in the awarding of future 

contracts; and

■ Provisions for independent (third-party) 

audits of job sites to ensure that the 

contractors performing work are vetted 

contractors and that they are performing 

work using appropriate safety measures.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

6

■ Stop work authority: Safety and health 

programs should authorize and instruct all 

employees, at all levels in the contracting 

chain, to stop work on a project if unsafe 

conditions are discovered and provide 

assurance to those employees that there 

will be no repercussions or reprisals for 

doing so. 

Tower Climbers and Ground 

Crew Employees

■ Tower climbers 

and ground crew 

employees should 

know how to report 

unsafe conditions 

and should follow the 

applicable reporting 

process whenever 

they discover unsafe 

conditions. 

■ All work crews need to have and use proper 

safety equipment at all times. No work 

should be done if proper safety equipment 

is unavailable or the safety equipment 

available is not functioning properly.

■ All employees should certify their 

commitment to “100 percent tie-off” at least 

once each year. Job site supervisors need 

to have a firm commitment to enforcing 

100 percent tie-off at every worksite at all 

times when employees are climbing. 

■ All climbing work should include 

comprehensive safety planning, including 

a Job Hazard Analysis (JHA) and an 

Emergency Action Plan (EAP) for every 

job site.

■ Work crews should not work at heights 

when weather conditions raise safety risks. 

Photo: ACTA Safety
FEDERAL COMMUNICATIONS COMMISSION

7

■ No member of a work crew should work at 

heights if their physical or mental health 

is impaired. For example, if a member of a 

work crew is taking medication that affects 

his or her physical abilities (such as overthe-counter cold and flu medication that 

can cause drowsiness), he or she should 

not climb or work at elevations.

■ Work crews should promptly report issues 

with any safety device and cease operations 

if the safety device is compromised.

■ Work crews should continually seek to 

enhance their safety skills and awareness 

through regular trainings and stand-downs. 

■ Particular attention should be paid 

to inspections, including equipment 

inspections (such as inspections of tools, 

hoisting and rigging equipment, and other 

machinery) and inspections of personal 

protective equipment. 

■ Contractors need to ensure that there is a 

competent person on site at all times. This 

person should monitor the mental and 

physical well-being of climbers on his or 

her team. The competent person should 

have authority to stop an unfit employee 

from climbing and should be expected to 

exercise that authority whenever necessary 

to ensure the safety of employees at the site. 

Carriers and Tower Owners

Carrier and tower owner 

general topics

Contractor selection and vetting

Carriers and tower owners should have 

clear criteria for selecting and vetting all 

contractors. For additional information on 

contractor vetting, please see the “Verification 

of subcontractors” section in General Topics.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

8

Reporting

■ Carriers and tower owners should establish 

an incident reporting system with a 

clearly defined, streamlined process for 

responding to incidents in a timely manner. 

■ Carriers and tower owners should create a 

standard protocol to ensure that all employees 

(including employees of contractors) report 

unsafe conditions on tower worksites to the 

carrier and tower owner. 

 Carriers and tower owners can foster a 

culture where everyone is encouraged 

to report safety issues by making it 

easy to anonymously report unsafe 

towers to a telephone hotline, or via a 

mobile phone application. 

 A crucial part of building this culture 

includes removing any fears of 

retaliation or negative consequences 

for reporting.

■ All reports of unsafe conditions should be 

managed from a central location where 

a repair/maintenance request would be 

generated, prioritized and tracked until the 

condition is corrected. 

■ Carriers and tower owners should stop 

work immediately whenever any serious 

safety issue is reported on a work project. 

 Work should not be restarted until the 

carrier or tower owner has received 

proof that the unsafe condition has 

been eliminated. 

■ Carriers and tower owners should 

automatically launch an investigation 

into all serious injuries and fatalities to 

establish the cause of the incident. 

 Any findings that indicate a contractor’s 

inadequate compliance with safe work 

practices should be flagged for action. 
FEDERAL COMMUNICATIONS COMMISSION

9

 The findings of these investigations 

should become part of a contractor’s 

safety record with the carrier and tower 

owner, and should be factored into 

annual reviews and future contracting 

opportunities.

Auditing

■ Carriers and tower owners should perform 

random audits on projects to ensure the 

use of safe work practices. 

 Among other things, carriers and 

tower owners should enforce the 

consequences called for in applicable 

contract language when contractors fail 

to ensure that work is performed safely 

and track and audit the application of 

those consequences. 

 Independent third parties should 

perform these audits to ensure neutrality. 

 Findings of significant safety issues may 

be grounds for contract termination. 

■ In addition to random on-site audits, 

carriers and tower owners should perform 

regular, scheduled reviews of contractors 

and their safety records. 

 These reviews should focus in particular 

on past reports of safety issues and the 

measures taken to address them. 

Training

■ Carriers and tower owners should support 

the development of industry-wide, 

recognized training standards and then 

may require their contractors to comply 

with those training standards.

■ When vetting contractor training 

programs, carriers and tower owners 

should ensure that contractors are 

providing sufficient oversight of “train 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1 0

the trainer” programs to confirm that 

employees at all levels are receiving 

quality training. 

■ It is strongly recommended that carriers 

and tower owners verify the training and 

certifications carried by the employees 

of contractors. 

 This is primarily to ensure that all 

contractors working on a carrier or 

tower owner’s project have obtained 

a minimum level of training and 

certification. 

Recordkeeping and communication

■ Carriers and tower owners should know 

the identities of the contractors performing 

work on their projects at all times. 

 Maintaining records of projects and 

the contractors working on them will 

prevent unvetted contractors from 

entering worksites. 

 If a contractor is found on site without 

prior approval (or if their approval has 

been revoked), they should be removed 

from the site immediately. 

■ Carriers and tower owners should maintain 

a comprehensive electronic inventory 

system of all towers and antennas. 

 This system should include detailed 

information on each of the company’s 

assets, including antennas, equipment, 

and towers. This information should 

include as-built drawings, project/

work history, and a listing of reported 

unsafe conditions along with 

confirmation of repairs. 

 This information should be available 

to all parties working on a particular 

project because it is critically important 

to ensuring that work can be completed 

in an effective, timely, and safe manner. 
FEDERAL COMMUNICATIONS COMMISSION

1 1

 The information contained in these 

systems should be audited and updated 

on a regular basis to ensure accuracy.

■ All information pertaining to work on 

communication towers, including structural 

information, work history, needed repairs, 

etc., should be freely shared. 

 Carriers and tower owners should 

ensure that any critical information 

they have is shared down the contract 

chain, and they should also ensure that 

important information is being shared 

up the contracting chain. 

 Carriers and tower owners should 

make every effort to ensure that they 

receive timely information about 

safety-related issues on their projects 

from the work crews on site.

Carriers

Project timelines

■ Currently, many carriers calculate project 

schedules based on historical data, which, 

due to factors associated with a particular 

job, may not allow enough time for a 

contractor to complete the work. 

 Carriers should ensure that they take 

into account all of the factors of each 

individual project when creating 

project schedules. 

 These factors can include tower 

worksite location, tower type, 

scope and complexity of work to 

be completed, environmental and 

weather-related factors, travel time, 

and equipment delivery schedules. 

 This will ensure that contractors 

have enough time to complete work 

in a safe manner. 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1 2

 Additionally, it is typical to have delays 

or unanticipated conditions on every 

work site. 

 Planning for flexibility in project 

deadlines can help protect against safety 

lapses that result from hasty work.

■ Carriers should take proactive steps to 

guard against employee fatigue. 

 The hazards presented by employee 

fatigue can be greatly reduced by, 

among other measures, minimizing 

long drives to and from work sites. 

 Due to the remote location of 

many communication tower work 

sites, carriers should give special 

consideration to travel time when 

setting project schedules. 

 Setting limits on drive times and 

“high time” (or, time spent on the 

tower) can promote climber safety 

and also demonstrate to contractors 

that minimizing employee fatigue is a 

high priority. 

Tower owners

Tower inspection and maintenance

■ Tower owners should ensure that their 

towers are maintained properly, and that 

structural inspections are conducted on 

a regular basis. All towers should have a 

means for safe access (including having 

unobstructed ladders that are in good 

repair) and methods for managing radio 

frequency hazards, and should be inspected 

regularly for structural soundness. Tower 

owners are strongly encouraged to have 

a properly installed, maintained and 

functioning safety climb system.

■ Towers that do not currently have 

engineered anchorage points should be 
FEDERAL COMMUNICATIONS COMMISSION

1 3

designated for retrofitting with engineered 

anchorage points wherever possible. 

Towers that cannot be retrofitted with 

engineered anchorage points should be 

designated for replacement with a tower 

that can provide engineered anchorage 

points and work platforms.

■ Tower leases should mandate that no 

equipment may be installed in such a 

way that it prevents access to engineered 

anchorage points, and that any lessee 

who installs equipment that compromises 

an engineered anchorage point or safety 

climb system is responsible for replacing 

that system or installing a new engineered 

anchorage point. 

■ Tower owners should meet or exceed 

the standards established in recognized 

consensus standards governing the 

construction and maintenance of 

communication towers, including TIA222-G, Structural Standard for Antenna 

Supporting Structures and Antennas. 

■ Tower owners should establish a clear 

procedure for reporting unsafe conditions 

on towers and ensure that all reported 

conditions are tracked until the hazardous 

conditions have been fixed.

■ A number of companies have begun 

using drones for tower inspection. This 

technology has the potential to reduce 

unnecessary climbing and can avoid 

putting employees at risk. 

■ Tower owners are strongly encouraged 

to require contractors to send photos of 

completed work to their central command 

centers. The command centers can then 

assess and approve the work before the 

employee even descends the tower. This 

can reduce unnecessary climbing for 

redoing completed work.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1 4

Turfing Vendors

Training

■ Turfing vendors should require all field 

supervisors and crew members (including 

those working for contractors) to be 

adequately trained for their assigned work 

activities and require that all training be 

documented.

■ In addition to job-specific training, turfing 

vendors should require all supervisors and 

crew members to complete an orientation 

prior to beginning work. This orientation 

should cover all relevant safety and health 

requirements, including appropriate 

procedures for performing the crew 

members’ work tasks, the safety and health 

hazards associated with those tasks, and 

the appropriate measures that need to be 

taken to mitigate those hazards. 

■ When vetting contractor training programs, 

turfing vendors should ensure that there 

is adequate oversight of “train the trainer” 

programs in order to confirm that employees 

at all levels are receiving adequate training.

■ One purpose of training is to set 

expectations. Turfing vendors should set 

the expectation with all contractors that 

they place the highest priority on safe 

work practices and that there is no reason 

for a contractor to ever take shortcuts on 

safe practices. Establishing an expectation 

of zero tolerance towards unsafe practices 

is critical to changing the safety culture.

Communication, reporting and 

incident investigation

■ Turfing vendors should establish a 

command center staffed with subject 

matter experts who are equipped to 

immediately respond to inquiries and 

to assist with troubleshooting issues 
FEDERAL COMMUNICATIONS COMMISSION

1 5

from the field. This can facilitate safe 

work practices — for example, when the 

turfing vendor is responsible for assessing 

and approving work procedures and 

products, a tower crew can take photos 

of a tower’s rigging and an expert in the 

command center can approve the rigging 

plans and the actual set-up before lifting 

commences. Crews can also send photos 

of completed work to the command 

center so that work can be assessed 

and approved immediately. This type of 

quality control can minimize unnecessary 

climbing for redoing completed work. 

■ Turfing vendors should ensure an open 

flow of communication between carriers, 

tower owners and contractors. It is 

vital that contractors have all relevant 

information to safely complete work 

activities. Often contractors encounter 

safety issues on sites that tower owners 

and carriers are not aware of, and the 

responsible parties need to be made 

aware of these situations. Turfing vendors 

can ensure that the relevant parties in 

the contracting chain are exchanging 

necessary information.

■ Turfing vendors should ensure that 

procedures are in place for reporting 

unsafe conditions on tower worksites. 

These procedures should be as 

straightforward and simple as possible 

to encourage timely reporting of unsafe 

conditions. When the reporting procedure 

is not transparent or responsive, it 

discourages reporting.

■ Turfing vendors should have a company 

representative on site while work 

activities are being performed to ensure 

that safe practices are followed. At a 

minimum, if a representative cannot visit 

every site, turfing vendors should have 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1 6

representatives perform periodic, random 

safety audits to ensure that work is being 

done in a safe manner. There should 

be specific consequences when unsafe 

conduct is discovered.

■ When a near miss, injury or fatality is 

reported on a work site, the turfing vendor 

should immediately stop all work and 

begin an investigation into the causes of 

the incident. 

Work site safety practice

■ Turfing vendors should require a Job 

Hazard Analysis (JHA) to be completed by 

all contractors working on site. The JHA 

should be required on-site documentation 

for all work activities. 

■ For a description of critical elements in a 

Job Hazard Analysis, please see the “Work 

site safety practices” section in Tower 

Construction and Maintenance Contractors. 

■ Turfing vendors should establish a strict, 

zero-tolerance policy on free climbing. 

Tower Construction and 

Maintenance Contractors

Auditing and incident 

investigations

■ Whenever an injury or fatality occurs on 

a work site, contractors need to notify 

all appropriate authorities, including, as 

necessary, local emergency services and 

OSHA2. Then contractors should follow 

their own internal policies as well as the 

policies of the turfing vendor, tower owner 

and carrier for reporting incidents. 

2. For more information on OSHA’s mandatory reporting 

requirements for employers, see www.osha.gov/report
FEDERAL COMMUNICATIONS COMMISSION

1 7

■ Contractors should have internal policies 

for investigating incidents that take place 

on work sites in order to determine the 

root cause of the incident. They should 

also have policies on what to do with the 

results of these investigations, to ensure 

that lessons learned from the root causes 

are applied to work practices in order to 

make them safer. 

■ If the incident is due to the actions 

of an individual employee, then the 

contractor should re-examine internal 

policies for employee training and retrain the individual (and all employees if 

needed). If the cause of the incident is a 

deficiency in the contractor’s safety and 

health program, the contractor should 

immediately audit its safety and health 

program and correct any deficiencies that 

are found. 

Work site safety practices

■ All contractors should require supervisors 

to conduct a tailgate meeting at the 

beginning of each work day. The purpose 

of these meetings is to highlight the 

most important safety issues for the 

day. These meetings should cover the 

location of rescue equipment, possible 

hazards specific to the jobsite, the need for 

personal protective equipment (such as 

hard hats and eye protection), the need to 

be aware of overhead hazards (especially 

during lifts), and the importance of 

keeping clear of the load. Other critical 

topics include the location of the nearest 

hospital, and how to direct someone to 

call 911 in an emergency. 

■ Before any employee sets foot on a job 

site, the contractor should complete a 

comprehensive Job Hazard Analysis 

(JHA). The JHA should be required on-site 
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1 8

documentation for all work activities. The 

JHA should provide an overview of the 

location of the work site, the type of tower, 

and the work to be done. It should include 

the precise location of the work site and 

the location of (and contact information 

for) all local emergency services (including 

the nearest hospital or medical center). 

It should provide a detailed analysis of 

each individual job task to be completed, 

as well as information about the hazards 

associated with that task and the preventive 

measures necessary to avoid those 

hazards (including applicable personal 

protective equipment). The JHA should 

include a list of all personnel working on 

site, along with information regarding the 

training and certifications held by each 

individual. Finally, the JHA review should 

include a mental and physical check-in 

with climbers. Do they feel mentally and 

physically ready to climb safely that day? If 

there are any situations or conditions that 

may prevent them from being focused on 

climbing safely, the foreman should have 

and exercise the authority to relieve that 

climber from climbing duties.

■ For work sites where personnel will 

be working at heights and/or where 

hoisting of personnel or materials will be 

performed, a more detailed JHA should be 

used, and should include specific hazard 

control measures unique to the work 

activities being performed on that job site.

■ Contractors should institute work policies 

and procedures designed to ensure that 

safe work practices will always be followed 

on site. For example, when contractors 

begin every single work day with a tailgate 

meeting discussing the day’s work, and 

then immediately follow the meeting with 

daily equipment inspections, critical safety 

practices are less likely to be overlooked. 
FEDERAL COMMUNICATIONS COMMISSION

1 9

■ Contractors should ensure that all 

employees are aware of existing 

consensus standards governing 

communication tower work and are 

familiar with the provisions of those 

standards that apply to their work 

activities. They should make compliance 

with applicable provisions of consensus 

standards an element of the safety and 

health program. 

■ Contractors should ensure there is 

adequate supervision of employees during 

work activities and make sure that all 

employees follow safe work practices (like 

100 percent tie-off). 

■ Contractors should keep track of employee 

work schedules, including travel and 

driving time, to ensure that employees are 

not climbing while fatigued. 

■ It is quickly becoming a recognized best 

practice in the industry to institute a 

zero-tolerance policy regarding unsafe 

practices, and free climbing in particular. 

Contractors with exceptional safety 

programs institute policies that mandate 

100 percent tie off. When an employee is 

found to be violating company policy by 

free climbing, employers should initiate 

appropriate corrective actions, which 

can range from mandated re-training to 

other actions, depending on the individual 

circumstances. Contractors can take a 

similar approach to other unsafe practices, 

including drug use and unsafe driving. 

Recordkeeping and 

Communication

■ Contractors should keep comprehensive 

records of all employee training and 

certifications, and should make those 

records available to carriers, tower owners, 

and turfing vendors on an as-needed basis.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

2 0

■ Contractors should obtain necessary 

technical and engineering specifications 

from tower owners and turfing vendors. 

It is critical to obtain recent and accurate 

information as part of the contracting 

process to enable work to be completed in 

a timely and safe manner. 

Training

■ Contractors should 

ensure that all 

employees who 

climb communication 

towers are trained for 

the tasks they will be 

expected to perform.3

■ Contractors should ensure that employees 

new to tower climbing undergo 

comprehensive training as authorized 

climbers. After training, new climbers 

should be paired with an experienced 

climber as an apprentice until they have 

enough experience and climbing hours to 

undertake the competent climber training. 

New employees who have climbing 

experience should be closely monitored 

until their skill levels are known.

■ Employees who will be expected to 

perform rigging or hoisting activities 

should have specialized training to 

ensure they can safely perform these 

tasks. Contractors should not expect “on 

the job training” to adequately prepare 

employees to perform these tasks.

3. Telecommunications companies, industry associations, 

and the Department of Labor have established the 

Telecommunications Industry Registered Apprenticeship 

Program (TIRAP). TIRAP partners with stakeholders to 

promote safety, enhance quality, and enable education and 

advancement opportunities in the telecommunications 

workforce that will meet network infrastructure build out 

needs. TIRAP apprenticeships are now available to interested 

telecommunications companies. For more information see 

www.tirap.org/employer-involvement.

Photo: iStock
FEDERAL COMMUNICATIONS COMMISSION

2 1

■ Contractors should ensure that employees 

are re-trained at appropriate intervals, as 

well as on an as-needed basis. Failure to 

comply with safe climbing practices is one 

indication that re-training is needed. 

■ When making use of “train the trainer” 

programs, contractors should ensure that 

the employee who attends that training and 

then trains other employees is adequately 

prepared to train all employees. Additionally, 

contractors should perform regular audits of 

internal training programs to ensure that the 

training is sufficiently rigorous. 

For additional information, please see 

OSHA’s Communication Tower web site: 

www.osha.gov/communicationtower, or 

contact OSHA’s Directorate of Construction at 

(202) 693-2020. 

Additional Resources

Recommended Practices for Safety and 

Health Programs

OSHA has developed materials to help 

employers establish comprehensive safety 

and health programs. The following link 

provides valuable information to anyone 

wishing to develop a safety and health 

program, which can contribute to a culture of 

safety for communication tower employers 

and employees.

www.osha.gov/shpguidelines

In addition to the above resource, the 

National Safety Council’s “Journey to Safety 

Excellence” webpage has information about 

safety and health programs and how they can 

work for a wide variety of industries.

www.nsc.org/measure/pages/journey-tosafety-excellence.aspx
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

2 2

For More Information

Contacting OSHA 

To ask questions or to get more information 

about OSHA regulations, or to file a 

confidential complaint, contact OSHA at 

1-800-321-OSHA (6742) or TTY: 1-877-889-

5627 or go to www.osha.gov.

Contacting FCC

To ask questions regarding the content of 

this document or for more information about 

communications towers, please contact FCC: 

1-888-CALL FCC (225-5322); TTY: 1-888-TELL 

FCC (835-5322) or visit the FCC website at 

www.fcc.gov.

Photo: OSHA

U.S. Department of Labor