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Current OSHA Regulation
Final paragraph (b)(13), similar to the proposed rule and construction fall protection standard (§ 1926.502(b)(13)), requires that employers using guardrail systems around holes that are points of access, such as ladderway openings, protect workers from walking or falling into the hole by installing gates at the opening in the guardrail system (final paragraph (b)(13)(i)), or offsetting the opening from the hole so workers cannot walk or fall into the hole (final paragraph (b)(13)(ii)). The final rule also revises the proposed criteria for such gates by specifying that they:
- Must be self-closing;
- Must either slide or swing away from the hole; and
- Be equipped with top rails and midrails or equivalent intermediate members that meet the requirements in final paragraph (b) (final paragraph (b)(13)(i)).
OSHA 1910.29 (b)(13)(i) “Fall protection systems and falling object protection – criteria and practices.”
(13) When guardrail systems are used around holes that serve as points of access (such as ladderways), the guardrail system opening: (i) Has a self-closing gate that slides or swings away from the hole, and is equipped with a top rail and midrail or equivalent intermediate member that meets the requirements in paragraph (b) of this section. Click HERE for the complete OSHA standard.
Previous OSHA Regulation
(2) Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
OSHA 1910.23(c) “Protection of open-sided floors, platforms, and runways.”
(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides.
NOTE: The problem is that the configuration of a “swinging gate” is not defined or specified. There have been many interpretations over the years.
OSHA Proposed Criteria
OSHA has attempted to clarify and eliminate any differences in interpreting the regulations as part of their overall revision of 29 CFR 1910 Subpart D. This Notice of Proposed Rulemaking (NPR) for revision of the Walking and Working Surfaces standard was published in the Federal Register, Vol. 55, No. 69, on Tuesday, April 10, 1990.
In regards to access openings, the proposal basically states that the protection be equivalent to that of the guardrail system with the exception of the toeboard.
– Gates should have both a top rail and a midrail.
– Top rail height of 42″ above the walking or working surface.
– Maximum opening size of 19″ in the least dimension.
– Able to withstand 200 lb load (top rail) and 150 lb load (midrail).
– There is some distinction allowed in the protection requirements between “working” platforms and “pass-through” platforms.
On an interpretation letter (HERE) written to Intrepid Industries on January 15, 1993, the following note was added. It may provide you with some further understanding of this discussion.
Note: On April 10, 1990, OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls; Trips in Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003, OSHA reopened the rulemaking record on the proposed revisions to Wakling and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirely in Federal Register 68:23527-23568 and is available electronically.]
Quoted below is a pertinent section from this re-publication of the proposed revisions.
1910.28 Fall Protection Systems
(b) Guardrail systems and toeboards. Requirements for suspension scaffold fall protection systems are contained in 1910.30. All other guardrail systems and their components shall meet the following criteria:
(1) Top rails. …
(2) Midrails. …
(3) Height criteria. …
(4) Surfaces of guardrails. …
(5) Size criteria. …
(6) Access openings. Employers may use movable guardrail sections using such materials as gates, non-rigid members and chains to provide access when opened and guardrail protection when closed, provided the criteria in paragraphs (b)(1) through (b)(5) of this section. Toeboards are not required in access openings.
(7) Toeboard requirements. …
If you would like to read the complete document, click HERE.
Latest OSHA Developments
On June 7, 2012, Great Lakes Chemical Corporation in El Dorado, Arkansas, was cited (Inspection #315973859) for the following “Serious” violation on page 6 of 25.
“The employer does not ensure that ladderway opening of work platforms are provided with swinging gates or are so offset that a person can not walk directly into the opening…”
“Ladderway opening to a work platform was protected by a single swinging bar.”
According to the citation, these openings which were protected by a single swinging bar were interpreted to not meet the OSHA requirement 29 CFR 1910.23(a)(2). If you have any information you would like to share regarding this topic, please give