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.

April 12, 2010

Letter # 20071021-8079

Re: Minimum distance required between guardrails on an industrial truck work platform.

Question: Under 1926.451(g)(4)(vi), how many balusters are required on an industrial truck work platform that is 96" x 48" with a 30" entry gate on one end?

Answer: The scaffold you describe falls under the catchall scaffold fall protection provision, 29 CFR 1926.451(g)(1)(vii), which requires each employee working on the scaffold to be:

[P]rotected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraph (g)(4) of this section.

Paragraph 1926.451(g)(4)(vi) specifies that balusters used as part of a guardrail system under 1926.451(g)(1)(vii) "shall not be more than 19 inches (48 cm) apart." OSHA is unable to precisely answer how many balusters are required here because it is unclear exactly where the entry gate is located and whether the gate is equipped with balusters (or some other form of protection from falls). This information is necessary before OSHA could conclude the exact number of balusters required here. However, your guardrail system will comply with §1926.451(g)(1)(vii) provided there is no distance greater than 19" between any two balusters within the guardrail system. Furthermore, if your employees are wearing fall protection - as the platform and guardrail were designed for - then you will be in compliance with §1926.451(g)(1)(vii) while working on your guardrails systems, as they are described in your letter.


Bill Parsons, Acting Director
Directorate of Construction