June 27, 2012
Fenner Plumbing, Inc.
108 N. Main Street
P.O Box 216
Berrien Spring MI 49103
Dear Mr. Mann:
Thank you for your April 5, 2012 letter to the Occupational Safety and Health Administration (OSHA). Since it involves construction issues, it has been forwarded to the Directorate of Construction for response. You have a specific question regarding access to a semi-trailer used to store parts on a job site. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.
Question: Is it permissible to use a metal ramp to unload parts from a semi-trailer when needed?
Response: Yes, the OSHA standards do not have specific requirements for accessing a portable storage trailer on a job site. A ramp could be a suitable means of access. However, where the height of the trailer floor exceeds 6 feet, guard rails or other fall protection will be required.
29 CFR 1926.501(b)(6): requires that "Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8m) or more to the lower level by guardrail systems."
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction