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.

August 10, 2004

Dear Mr. Johnson:

This is in response to your e-mail inquiry of May 28, 2004. We have paraphrased your question as follows:

Question: Does our personnel platform design, which incorporates a panel that has 1" x ¼" slots, meet the OSHA personnel platform design requirements in §1926.1431(e)(6)?

Answer
The relevant provision, §1926.1431(e)(6), states:

[E]ach personnel platform... shall be enclosed at least from the toeboard to mid-rail with either solid construction or expanded metal having openings no greater than ½-inch.

 

 

The design in question is a panel that is solid metal with slots cut out in some places to form a logo (see picture below):

 

 

panel that is solid metal with slots cut out in some places to form a logo

 


The largest of the slots are 1" x ¼", which is .25 square inch. That is the same in square inches as ½" expanded metal.

This panel design meets the requirement. First, it is mostly solid metal, which provides more protection than a panel made entirely of ½-inch mesh. Also, the largest slot opening in the panel has the same amount of open area as ½-inch expanded metal openings.

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.

Sincerely,


Russell B. Swanson, Director
Directorate of Construction

[Corrected 12/15/2013]