• Standard Number:

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.

February 9, 1983

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

Dear Mr. Stafford:

This is in response to your letter of January 28, 1983, concerning perimeter protection at setback roof levels.

A parapet height of 29 inches, where employees are exposed to falls from a roof, does not comply with the height requirement in 29 CFR 1910.23(e)(1) and can not be considered acceptable by OSHA. The employer may install a temporary portable section of guardrail which will comply with 29 CFR 1910.23(e)(3)(v) and provide a minimum height of 36 inches at the exposure locations. Employers may also use a safety belt and rope tie-off system in this type of exposure.

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


John K. Barto
Chief, Division of Occupational
Safety Programming