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.

April 16, 1997

Mr. Dennis Lydon
Vice President
Baker Mechanical, Inc.
2911 Hubbell Avenue
Des Moines, Iowa 50317

Dear Mr. Lydon:

This is in response to your letter of September 6, 1996, in which you requested an interpretation of the Occupational Safety and Health Administration's (OSHA) standard on fall protection in a situation regarding floor/roofing openings.

Your specific Question is as follows:

Case in Point:

Where the roof curb is already set in place and the roof deck is not cut out. A man is sent to the roof to cut out the roof deck. He is to put a cover over the opening as soon as he has completed the work. Another man is placed below the opening to act as a spotter, so that no one walks below the hole and into the line of any loose material that may fall. As soon as the work is complete, the cover is nailed down over the opening so no one could fall down through the hole.

The practice you have described is acceptable in meeting the requirements in Section 1926.501(b)(4) to protect workers exposed to falling through holes, provided that the cover meets the criteria in Section 1926.502(i) Covers (enclosed).


Roy F. Gurnham, Manager
Office of Construction Standards
and Compliance Assistance