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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 14, 1985

Mr. Frank Wood
Franklin Plaza Development Company
The Hartford Building
Franklin Plaza
Tulsa, Oklahoma 74120-1801

Dear Mr. Wood:

This is in response to your letter of August 23, concerning your request for a variance from 29 CFR 1926.500(d)(1). Your letter was forwarded to this office for a clarification of our standard railing requirements.

29 CFR 1926.500(f)(1)(vi) provides the specification criteria for a standard railing exception as follows:

(vi) Other types, sizes, and arrangements of railing construction are acceptable, provided they meet the following conditions:

(a) A smooth-surfaced top rail at a height above floor, platform, runway, or ramp level of approximately 42 inches;

(b) A strength to withstand at least the minimum requirements of 200 pounds top rail pressure with a minimum of deflection;

(c) Protection between top rail and floor, platform, runway, ramp, or stair treads, equivalent at least to that afforded by a standard intermediate rail;

(d) Eliminations of overhang of rail ends unless such overhang does not constitute a hazard.

Your proposal to install a 9/16 inch standed steel cable attached to columns approximately 42 inches for the top rail and 21 inches for the intermediate rail, appears to meet the intent of our railing requirements. However, the wire ropes shall be secured to each support and taut at all times. In addition the maximum deflection of the top rail when a load of 200 pounds is applied in any direction at any point on the top rail shall not exceed 3 inches in one direction. The intermediate post may be omitted provided the above mentioned criteria for the steel cables is satisfied.

The vertical barrier (toeboard) at floor level erected along exposed edges of a floor opening must be installed to prevent falls of materials on employees working below the floor. Toeboards could be deleted only in situations where other type equivalent protection is provided. The ledge of 2 feet inside the perimeter does not provide equivalent protection.

Your enforcement of the requirement that employees must wear an approved safety belt and be attached to the cable or columns by means of an approved short safety lanyard (2 feet or less) when working between the cable an the perimeter of the building would be acceptable.

It appears based on the information you have provided, that your guardrail system with the inclusion of toeboards could comply with 29 CFR 1926.500(f)(1)(vi), if properly installed and maintained.

If we can be of further assistance, please let us know.


John B. Miles, Jr., Director
Directorate of Field Operations