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Standard Interpretations - Table of Contents
• Standard Number: 1910.23


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.


December 10, 1996

Mr. Jerome Spear, CSP
Chicago Bridge & Iron Company
1501 North Division Street
Plainfield, Illinois 60544-8929

Dear Mr. Spear:

This is in response to your letter of November 26, regarding an interpretation of the 29 CFR 1910.23 standards relating to guardrails.

You indicated in your conversation with Art Buchanan, as well as in your letter, that two tanks are located adjacent to each other. A runway with standard guardrails is located on top of each tank with the end of the two runways butted to each other, but not connected (a drawing was attached). You also indicated that the two runways cannot be attached to each other because of the independent movement of the tanks that occurs during operation; however, engineering modification can be incorporated to minimize the gap between the two guardrails. Based on the information that you have provided, a maximum opening of four inches between the two guardrails would ensure compliance with 29 CFR 1910.23.

Thank you for your inquiry. If you need further assistance, please contact [the Office of General Industry Enforcement at (202) 693-1850].

Sincerely,


Raymond E. Donnelly, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]


November 26, 1996

US Dept of Labor - OSHA
Attn: Art Buchanon
200 Constitution Ave. NW
Rm. N3107
Washington, DC 20210

Dear Mr. Buchanon:

Last week, I spoke with you on the phone regarding an interpretation of the 1910.23 standards relating to guardrails. The situation that was discussed involved two tanks that are located adjacent to each other. A runway with standard guardrails is located on top of each tank with the end of the two runways butted to each other but not connected (see enclosed drawing). The two runways cannot be attached to each other because of the independent movement of the tanks that occur during operation; however, engineering modifications can be incorporated to minimize the gap between the two handrails. In order to ensure compliance, the maximum allowable opening between the two handrails needs to be determined.

You indicated from our phone conversation that 1910.23(e)(11), which details the maximum openings for wall opening screens, would apply in the above situation. As a result, four inches would be the maximum allowable opening between the two handrails.

Please confirm in writing that the maximum allowable opening between two adjacent handrails as described above is four inches.

Sincerely,


Jerome Spear, CSP



Standard Interpretations - Table of Contents

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