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 http://www.osha.gov.

April 5, 1978

Mr. John R. Reilly
Corporate Director
Fisher Scientific Company
711 Forbes Avenue
Pittsburgh, Pennsylvania 15219

Dear Mr. Reilly:

This is in response to your letter dated February 20, 1978, requesting a clarification of 29 CFR 1910.23(c)(1) and confirms your telephone conversation with Mr. William Simms of my staff.

The aforementioned General Industry Safety Standard requires that every open-sided floor or platform more than four feet above the adjacent level shall be provided with a standard railing. This requirement is applied to areas where employees are required to work or walk as part of fulfilling conditions of their employment. If the roof platform on top of a walk-in refrigerator is visited even a few days each year to store materials, employees required to work adjacent to or near the edge shall be provided with some means of protection. Such protection could be a life belt and lanyard tied off of a structural member so as to prevent the employee from walking off or falling from the exposed edges of the refrigerator roof top used as a storage platform.

If I may be of any further assistance, please feel free to contact me.

Sincerely,



Janet H. Sprickman,
Acting Chief
Division of Occupational Safety Programming

Enclosures