October 28, 1993

Ms. Janet Fox

Director, Industrial Hygiene and
Safety Services Con Edison, Inc.
30 Flatbush Avenue
Brooklyn, New York 11217
Dear Ms. Fox:
Your letter of July 16 to Mr. Roger Clark requesting information and clarification of the
Occupational Safety and Health Administration (OSHA) soil classification requirements for
excavations has been referred to the Office of Construction and Maritime Compliance Assistance
for response. I apologize for the delay in responding to your inquiry.
The type A, B, and C soil classification system outlined in 29 CFR, Subpart P was developed to
be a simple, easy to use method for estimating soil type in the field. The soil classification
system takes into consideration that although the measurements provided by a thumb
penetration test, a penetrometer, or a sheer vane are only estimates, these manual tests are
meaningful and acceptable within the framework of the OSHA standards. With regard to your
question why OSHA compliance officers use the penetrometer and sheer vane for soil analysis,
please be advised that compliance officers normally prefer the penetrometer and/or sheer vane
over the thumb penetration test because those instruments provide a reading that can be
recorded.
With regard to your question whether the thumb penetration test is the only manual test
necessary or must one or more additional manual tests be performed to classify a soil type A, B,
or C, please be advised that Appendix A to Subpart P requires that the classification of soils be
based on the results of at least one visual and at least one manual analysis. The choice of
which visual and manual test is used is left up to the person responsible for making the test. If
a thumb penetration test is performed in accordance with Appendix A, then no other manual
test would be required. Please note that these tests are not necessary if type C soil is assumed
and protection is provided for type C soil conditions.
If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at
(202) 219-8136.
Sincerely,

Roy F. Gurnham, P.E., Esq.

Director
Office of Construction and Maritime
Compliance Assistance