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.

June 3, 1983

James Oliver, P.E.
Vice President
SatCom Technologies, Inc.
2912 Pacific Drive
Norcross, Georgia 30071

Dear Mr. Oliver

This is in response to your letter of May 10, 1983, addressed to OSHA's Regional Office in Atlanta, which was forwarded to this office for response. This also confirms your telephone conversation with Mr. Simms of my staff.

You requested review and approval of the construction of your 9 meter mount platform, which will be located on large commercial earth station antennas, with specific regard to guardrail and toeboard heights. The platform will be used by trained technicians approximately every six months, without any employee exposure below the platform.

Your illustration shows that the platform will be elevated approximately 13 feet above the supporting structure and protected with a guardrail system of 36" posts, with a top and midrails of chain and a 3" toeboard. This appears to meet the intent of 29 CFR 1910.23(c)(1). As specified in the standard, the anchoring of posts and installation of chains for railings must be of such construction that the completed structure shall be capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail.

OSHA standards do not prohibit the use of diamond-back grating for platforms if it is requested by your customers.

I hope this information is helpful to you. If I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Barto
Chief, Division of Occupational
Safety Planning