OSHA Instruction STD 1-1.5 October 30, 1978
JAN 31, 1978
OSHA PROGRAM DIRECTIVE #100-76
TO: REGIONAL ADMINISTRATORS/OSHA
THRU: DONALD E. MACKENZIE Field Coordinator
Subject: 29 CFR 1910.23(c)(1) , Protection of Open-sided Floors, Platforms
and Runways; Guardrails--Loading Rack Platforms
The purpose of this directive is to clarify 29 CFR 1910.23(c)(1) as
it relates to guardrails on loading rack platforms.
2. Documentation Affected
This directive supersedes Field Information Memorandum #74-84 dated
October 22, 1974.
a. Strict interpretation of 29 CFR 1910.23(c)(1) would result in
having all petroleum loading racks (and similar installations) protected with
guardrails on the outside edge of the loading platform above the top of the
tank truck. Several citations have been issued for failure to have such
guardrails and the Review Commission has ruled against OSHA in contested
b. The standard does not provide that there may be a surface other
than "adjacent floor or ground level" which might be within 4 feet of the
platform floor. When loading petroleum product tank trucks, the top of the
tank is adjacent to and within 4 feet from the floor of the
OSHA Instruction STD 1-1.5 October 30, 1978 -2-
c. The principal reason why guardrails are impractical is that
truck tanks are of different configurations and the several loading hatches
make it necessary for employees to be able to step from the platform (or use
a runway from the platform onto the tank) at any place in order to go onto
the tank. It is necessary to go onto the tank to open and close hatches and
to place and remove filler spouts. Safety belts and lanyards should not be
used when loading flammable liquids because the employee should be able to
move freely in case of a fire.
d. Some clarification of the referenced standard was included in
the proposed standards changes on Walking-Working Surfaces published in the
Federal Register on April 23, 1976. It is intended that the final changes to
the section will provide clarification that such platforms will not have
guardrails on platform sides adjacent to the top of tank trucks.
If it is necessary to cite an employer for an alleged violation of
29 CFR 1910.23(c)(1) involving loading platforms where there is an adjacent
truck surface which could be considered as an "adjacent floor", the violation
is to be considered de minimis.
5. Effective Date
This directive is effective immediately and will remain in effect
until canceled or superseded.
Richard P. Wilson Deputy Director, Federal Compliance and State Programs