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
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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
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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
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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
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 ? 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.
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 ? 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.

FEDERAL COMMUNICATIONS COMMISSION
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 ? 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 over-
the-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
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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
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 ? 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
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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
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 ? 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
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 ? 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
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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 TIA-
222-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
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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
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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
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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
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 ? 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 re-
train 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
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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
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 ? 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.
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 ? 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.
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 ? 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-to-
safety-excellence.aspx 
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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.
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