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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 9, 1982

Mr. Kevin D. Lyons
Safety Inspector
Safety and Systems Assurance Branch
Washington Metropolitan Area Transit Authority
600 Fifth Street, N.W.
Washington, D.C. 20001

Dear Mr. Lyons:

This is in response to your letter of July 27, 1982, requesting a clarification of 29 CFR 1910.23(a)(5) as it would apply to repair pits.

Employees engaged in maintenance work at bus and rail car inspection and repair pits when the bus or rail car covers the pit are not in violation of 29 CFR 1910.23(a)(5). When the pit or pits are not covered, employees walking ar least 6 feet from the pit would not be in violation of 29 CFR 1910.23(a)(5), provided the following actions are implemented by the employer:

1. The employee's safety training program will instruct employees to maintain a 6 feet clear distance from uncovered pits.

2. Highly visible contrasting lines will be installed 6 feet from the edge of pits.

3. Employer will install caution signs and ensure compliance by employees.

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


Patrick R. Tyson
Federal Compliance and State Programs