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.

January 15, 1993

Mr. Erich E. Bredl
President
Intrepid Industries, Inc.
P.O. Box 5460
Pasadena, Texas 77508-5460

Dear Mr. Bredl:

Thank you for your letter of December 29, 1992, concerning protective devices for ladderway openings.

Over the years there have been numerous discussions and interpretations as to what type of fall protection, if any, is required by OSHA's subpart D, Walking and Working Surfaces, for access openings in guardrail systems for fixed ladders. The following is a list of typical situations where the use of a single bar gate may or may not be accepted at access openings.

 

 

  1. Offset platforms between fixed ladders used only for passing through (not a work area) may use a single bar gate.
     
  2. Caged fixed ladders to a pass through area (not a work area) may use a single bar gate.
     
  3. A work platform that is accessed by a fixed ladder without a cage may not use a single bar gate at the access opening and must be guarded by a gate equivalent to a guardrail system or a guardrail system so offset that a person cannot walk directly into the opening.
     
  4. A work platform that is accessed by a floor opening ladderway must be protected by a standard guardrail system on all sides except that a gate equivalent to a guardrail system may be provided at the access opening or a guardrail system around the floor opening ladderway may be so offset that a person cannot walk directly into the opening. Single bar gates may not be used in this situation.
     
  5. An open-sided work platform that is accessed by a caged fixed ladder on the side of the platform, where the ladder's cage is at least as high as the guardrail system protecting the work platform, should have the access opening protected by a gate equivalent to a guardrail system. When only a single bar gate is used, compliance officers will evaluate the situation in terms of employee exposure, frequency of use, cage diameter, width of opening, height of bar, the type of work usually performed on the platform and any other relevant factors to determine whether a citable hazard exists.


The intent of the proposed revision to subpart D is to eliminate any differences in thoughts and interpretations of the existing standard as to what is appropriate to protect employees from fall hazards at access openings in guardrail systems. The proposed requirement simply states that the employee protection at access openings be equivalent to that of the guardrail system with the exception of the toeboard. This would include situation number five, above.

We hope that this answers your questions as to when a single bar gate may be used at access openings in guardrail systems.

Sincerely,


James W. Stanley
Acting Deputy Assistant Secretary

[Corrected 4/4/2005.

Note: On April 10, 1990 OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls; Trips in
Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003 OSHA reopened the rulemaking record on the proposed revisions to Walking and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirety in Federal Register 68:23527-23568 and is available electronically.]