• Employees must be protected from falls while working on communication towers.
• The typical business structure of the communication tower industry means that responsibility for ensuring worker safety is fractured into many layers.
• Employers at all levels (from carriers to subcontractors) must play a role in ensuring the safety of their workers.

The business structure of the communication tower industry presents additional challenges to ensuring employee safety. When carriers own the towers and directly employ the workers 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 subcontract 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 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; this leads to short job tenure and turnover tends to be high. Considering 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.