- 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 http://www.osha.gov.
May 29, 1992
Mr. Patrick McCall
Department of Occupational
Health and Safety
International Association of Fire Fighters
1750 New York Avenue, NW
Washington, D. C. 20006
Dear Mr. McCall:
This is in response to your letter of February 26 requesting an interpretation of how the Occupational Safety and Health Administration (OSHA) standards apply to fire poles located in fire stations, and specifically how OSHA standards apply to guarding of the floor opening. We apologize for the delay in responding.
The Occupational Safety and Health Act (OSH Act) does not apply directly to state or local government employees; however, those workers may be covered under a state OSHA plan. Thus, OSHA standards may or may not be enforceable in a specific situation.
First, fire poles are not an approved means of egress. While some risks associated with them may be reduced, the use of a pole in lieu of stairs is inherently dangerous.
According to the standard, the fire pole opening in fire stations would fall under the definition of floor opening, at CFR 1910.21(a)(2). The opening must be guarded either by a railing or a cover to protect employees from accidently stepping into the unguarded opening; such falls might result from inadvertent backing into the opening or even sleepwalking, if the hole is located in a dormitory area.
We believe that in most situations, suitable guard rails will be feasible; they may be provided with gates to allow access. We suggest that, at the very minimum, an anti-skid floor mat be provided so as to avoid slipping hazards around the opening. Additionally, you may wish to hang a warning sign at or above the hole to alert workers of the danger. Please refer to CFR 1910.144, Safety Color Code for Marking Physical Hazards and CFR 1910.145, Specifications for Accident Prevention Signs and Tags. Where operations necessitate regular travel between levels a safe means of access must be provided. You should be aware that OSHA does not view fire poles as an approved means of access from one floor level to another.
I hope this information is helpful. If we can be of assistance in the future, please do not hesitate to contact us.
Raymond E. Donnelly, Director
Office of General Industry