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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.
February 13, 2015
Mr. Rod Sapyta
P.O. Box 483
Thonotosassa, FL 33592
Dear Mr. Sapyta:
Thank you for your November 7, 2014, letter to the Occupational Safety and Health Administration (OSHA), regarding OSHA requirements for stairs and railings for accessing trailers on semi-trailer trucks. We have paraphrased your questions, and our replies follow. This letter constitutes OSHA's interpretation only of the requirements discussed, and may not be applicable to any questions not delineated within your original correspondence.
Question: Are semi-trailers required to have stairs and railings to access the trailer?
Response: No. OSHA does not specifically require the use of stairs and railings to access trailers on semi-trailer trucks. However, even in the absence of specific standards addressing a hazard, employers have the responsibility to provide a safe workplace under Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSH Act). Therefore, if employees are exposed to a fall hazard while entering or exiting the trailer, the employer has the obligation to provide a safe means of access. However, OSHA does not require any specific safety equipment or access means.
Question: If there are no regulations, can OSHA develop regulations addressing safe access to trailers?
Response: OSHA is currently revising its standards on Walking and Working Surfaces, and has raised the issue of fall protection on motor vehicles as part of its rulemaking. The notice of proposed rulemaking asked for comment on the need for specific fall protection requirements on motor vehicles, and therefore the issue will be addressed in that final rule.
Thank you for your interest in occupational safety and health. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
Thomas Galassi, Director
Directorate of Enforcement Programs