Standard Interpretations - Table of Contents|
| Standard Number:||1926.501(b)(4); 1926.501(b)(4)(i); 1926.501(b)(4)(ii); 1926.501(b)(4)(iii); 1926.502(i); 1926.501; 1926.502(i)(2); 1926.502(i)(3); 1926.502(i)(4)|
|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.|
Holes.These requirements must be met at the work site described in your scenario. Under OSHA's Multi-Employer Citation Policy, CPL 02-00-124, responsibility for covering the holes depends on what role each employer is serving at the work site. An employer has OSHA obligations under the policy if it serves in one or more of the following roles: creating, exposing, correcting, or controlling employer.1 Note, however, that matters involving contract law, such as who must bear the cost of the covers, for example, are beyond the purview of this office. The responsibilities of the various employers on this work site in fulfilling OSHA requirements are discussed below.
(i) Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.
(ii) Each employee on a walking/working surface shall be protected from tripping in or stepping into or through holes (including skylights) by covers.
(iii) Each employee on a walking/working surface shall be protected from objects falling through holes (including skylights) by covers.
[C]overs shall be capable of supporting without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.The engineering report provided with your letter states that the test unit used in that report has a failure pressure of 1,300 pounds when the cover is mounted over a 12-inch cylindrical opening and a failure pressure of 2,900 pounds when mounted over a 6-inch cylindrical opening.3 If the cover were to be used over a 12-inch cylindrical opening, the total weight that would potentially be imposed on the cover must be 650 pounds or less to fall within this requirement. If the cover were used over a 6-inch cylindrical opening, the total weight must be 1,450 pounds or less. Given these results, it seems likely that the cover would fulfill the strength requirements in §1926.502(i)(2) in most situations.
All covers shall be secured when installed so as to prevent accidental displacement by the wind, equipment, or employees.The installation instructions for the "Hole in One" cover provided with your letter show that the cover has adjustable securing wedges that must be adjusted to fit the hole. So long as the adjustments are completed as specified in the manufacturer's instructions, the cover is likely to fulfill the requirement in §1926.502(i)(3).
All covers shall be color-coded or they shall be marked with the word "HOLE" or "COVER" to provide warning of the hazard.The Features page for the "Hole in One" cover provided with your letter shows that these covers are a "safety orange color for easy recognition." Because orange is a color typically used by the construction industry to signal a potential hazard, the cover color meets the color-coding requirement in §1926.502(i)(4).
|Standard Interpretations - Table of Contents|
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