Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

June 15, 1977

Mr. Robert E. Collins
Executive Vice President
Southern Cotton Ginners Association
847 Arkansas Street
Memphis, Tennessee 38106

Dear Mr. Collins:

This is in response to your letter of May 12, 1977, addressed to James B. Brown, Area Director, Occupational Safety and Health Administration (OSHA), regarding OSHA inspection of cotton gins.

As you indicated there are no walking-working surfaces standards applicable to cotton gins in 29 CFR 1928, Occupational Safety and Health standards for Agriculture. In addition, 29 CFR 1928.21 exempts Part 1910, Subpart D-Walking-Working Surfaces from agricultural operations.

Your ginners are concerned that they will have to install railings and guards on the walkways and platforms high in the gin, which are used only for maintenance or upset conditions.

In areas of the cotton gin where 29 CFR 1928.57, Guarding of Farm Field Equipment, Farmstead Equipment, and Cotton Gins, does not apply, the employer has the option of choosing a method of protection the employee(s) from the danger of falling from the walkways and platforms. Your suggestion of protecting the employee from the danger of falling by the wearing of a safety lifebelt attached to a lifeline is one of several options. Of course, the lifeline is required to be securely attached to substantial members of the structure, which will safely suspend the employee in case of a fall.

It would be inappropriate for OSHA to limit the employer to just one method of protection, when there is no standard covering the hazard. Thank you for your concern and continued interest in occupational safety and health.


John K. Barto,
Division of Occupational Safety Programming