11/17/1998
- Clarification of fall protection requirements for open
holes on a construction site.
Standard Interpretations - Table of Contents Standard Interpretations
- Table of Contents
• Standard Number: 1926.500(b); 1926.501(b)(4)(ii)
November 17, 1998
Mr. Ivan Russell
President
Occupational Safety & Health Advisors, Inc.
27899 Jackson Drive NE
Isanti, MN 55040
RE: 1926.500(b), 1926.501(b)(4)(ii)
Dear Mr. Russell:
This is in response to your September 4 and October 12 faxed
letters to the Occupational Safety and Health Administration
(OSHA). You asked for clarification of the fall protection
requirements when working in the vicinity of an open concrete
elevator pit, which measures 6' X 8' and 4 feet deep. You
further describe its location as "an open area of a construction
site."
The fall protection standard, at 29 CFR §1926.500(b), defines
a hole as "a gap or void 2 inches...or more in its least
dimension, in a floor, roof, or other walking/working surface."
The standard has two requirements with respect to holes.
First, §1926.501(b)(4)(i) requires that employees be protected
from falling through holes more than 6 feet by fall arrest
systems, guardrails or covers. So, if a hole is more than
6 feet deep, one of these protection systems must be used.
Second, §1926.501(b)(4)(ii) requires that employees be protected
from tripping or stepping into holes by placing covers over
them. This provision does not specify a minimum depth for
the requirement to apply.
The first issue is whether the pit is a "hole." The pit
that you describe is located in and surrounded by a floor,
roof or other walking/working surface of a significantly
larger dimension than the pit. This pit would be considered
a hole under the standard. Since the fall distance is less
than 6 feet, the applicable requirement is .501(b)(4)(ii),
which requires a cover to protect against the tripping/stepping
into hazard. Alternatively, a guardrail could be used to
prevent employee exposure to the tripping/stepping into
hazard.
If you should have additional questions, please do not hesitate
to write to: Department of Labor (OSHA), Directorate of
Construction, Office of Construction Standards and Compliance
Assistance, Room N3621, 200 Constitution Ave., N.W., Washington,
D.C. 20210.
Sincerely,
Russell B. Swanson,
Director Directorate of Construction
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