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 https://www.osha.gov.

July 1, 1981

Lawrence R. Stafford, P.E.
Consulting Engineer
8 Gracemore Street
Albany, New York 12203

Dear Mr. Stafford:

This is in response to the questions raised in your letter of June 22, 1981, concerning proposed Powered Platform installations.

The Occupational Safety and Health Administration will accept a 3' guardrail for employee protection on roof locations where workers are exposed to falls in gaining access to equipment. Exposed employees are also required to be protected against the possibility of falling at each roof level in accordance with 29 CFR 1910.23(c). A permanently installed stainless steel wire rope, adequately anchored at the roof level to provide the equivalent guardrail protection when attached to the lanyard from a worker's safety belt is an acceptable method of providing employee protection at exposed locations.

If I may be of further assistance, please feel free to call or write.

Sincerely,



John K. Barto Chief,
Division of Occupational Safety Programming