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 https://www.osha.gov.



December 27, 1993

Mr. Bill Luther
Safety Director
RISI, Inc.
7501 Up River Road
P.O. Box 9634
Corpus Christi, Texas 78469

Dear Mr. Luther:

This is in response to your August 2 letter requesting an interpretation of Occupational Safety and Health Administration (OSHA) Standards addressing work performed from pipe racks. I apologize for the delay in responding to your inquiry.

With regard to an employee working while on an elevated pipe rack, please be advised that we would normally consider such a situation to be in compliance with OSHA fall protection regulations if 1) the employee is protected at all times by an adequate fall arrest system (body belt/ harness and lanyard), 2) a safe means of access and egress is provided, and 3) the work can be performed with reasonable ease without a platform.

[This document was edited on 10/22/2004 to strike information that no longer reflects current OSHA policy.]

If a platform is needed to safely perform the task, an adequately installed platform, as described in your letter (e.g. a board firmly secured to the top of the pipe or a one inch thick sheet of plywood secured to a layer of pipes), would be acceptable provided 100% fall protection is maintained and proper access and egress are maintained.

Please be aware, however, that the effectiveness your system can only be determined by a health and safety professional observing it in actual use under specific circumstances.

[If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax (202) 693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.]


Roy F. Gurnham, P.E., J.D., Director
[Directorate of Construction,
Office of Construction Standards and Guidance]

[Corrected 10/22/2004]



August 2, 1993

United States Department of Labor
Occupational Safety and Health Administration
Office of Construction and Engineering
200 Constitution Avenue, N.W. Room N 3468
Washington, D.C. 20210

Re: Request for an interpretation on fall protection and Scaffolding


We respectfully request an interpretation/clarification regarding two issues dealing with fall protection and scaffolding.

#1. Would it be permissible for a worker to be on an elevated pipe rack, (above six feet) standing on a pipe, and work on an intermediate level of pipe, without the use of a scaffold or platform, if said worker is utilizing fall protection and remains 100% tied off at all times while elevated?

It would appear, the main emphasis would be whether or not the person could fall. If 100% tie off was utilized at all times while elevated, would this not suffice?

#2. Would it be permissible for a board to be placed and firmly secured on top of the pipe, or a one inch thick, 4 x 8 sheet of plywood be firmly secured to a layer of pipes, to give the worker a flat surface to temporarily stand on, as opposed to the curved surface of the pipe? Inclusive of using the board or sheet of plywood, would be ensuring fall protection is used and maintaining 100% tie off.

The intent is not to make a platform or scaffold, but to provide fall protection and give the worker a flat surface to temporarily stand on while performing his/her work.

Additionally, the area beneath where the work would be conducted would be barricaded off so as not to allow entrance to the area beneath the overhead work.

Thank you in advance for your cooperation and efforts with this interpretation/clarification.

Sincerely, RISI, INC.

Bill Luther
Safety Director