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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 14, 1990

Mr. Anil Desai
Project Engineer
B.L. Montague Co., Inc.
Post Office Box 5428,
Greenville, South Carolina 29606

Dear Mr. Desai:

Thank you for your letter of July 12, in which you requested an Occupational Safety and Health Administration (OSHA) interpretation of whether additional handrails are required on the grated walkways provided on one side of the 13 belt conveyors at your Courtland, Alabama, paper mill project.

The drawings provided with your letter have been reviewed. Our review revealed several departures from the requirements of applicable OSHA standards. Each noted departure would create a violation if employees are exposed before corrections are made.

The elevated platforms located beside the moving conveyors are required to be guarded on both sides of each platform or runway (ref. 29 CFR 1910.23(c)(2), copy enclosed). 29 CFR 1910.23(c)(2) requires that, "every runway shall be guarded by a standard railing on all open sides 4 feet or more above floor or ground level." It further discusses the possible need for additional safeguarding as may be required if employees are exposed to hazardous machinery.

29 CFR 1910.212(a)(1), copy enclosed, requires that on any machine, nip points and hazards, such as the rollers and the edge of the moving conveyor, must be guarded. Since the moving belt must be guarded, a standard railing or some sort of an effective barrier guard must be provided on the inside of the platform between the employee and the belt edge. In any event, an emergency stop pull cord along the length of the conveyor is also required.

It was noted that all guard railings specified by the drawings do not provide a standard railing of 42 inches in height. (Note: Dwg. No. C-30410-E3, Sec. E/E2) 29 CFR 1910.23(e)(1), copy enclosed, requires that a standard railing have the top rail at 42 inches and be equipped with a. mid-rail. Railings taller than 42 inches are acceptable provided the open spaces between the top rail, and mid-rail or the mid-rail and floor, are not greater than 19 inches.

Thank you for the opportunity to review your design before employees are exposed. If we may be of further assistance, please contact the Office of General Industry Compliance Assistance on 202-523-8031.



Gerard F. Scannell
Assistant Secretary


cc: Clark, Donnelly, Stroup, Bode, Kanth, Atlanta R.A., Jackson, Mississippi AD; file

M/R: This response was coordinated with Safety Standards, Chap Pierce