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Marking aisles on dirt or dusty floors

Summary An OSHA office asked how to mark aisles when dirt, sand, or dust made painted lines impractical. OSHA said the rule allowed other visible methods, such as marked pillars, cones, flags, or barrels, when workers and vehicle operators were trained to recognize them; unmarked aisles could still be cited. The archived page notes a 2004 correction.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1977-02-14
Date issued
February 14, 1977
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The page notes an April 24, 2004 correction without describing the change.
Status last verified October 10, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The page notes an April 24, 2004 correction without describing the change. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

Date: February 14, 1977

MEMORANDUM FOR: Donald E. MacKenzie, Acting Director
Office of Field Coordination and Experimental Programs

SUBJECT: 29 CFR 1910.22(b)(2), Aisles and Passageways

ATTENTION: Maureen Kelleher

REFERENCES: Hal Bingham

This is in response to your inquiry concerning issuance of citations where there are no painted markings of permanent aisles and passageways for dirt floors or floors covered with sand or dust.

The wording of the standard, 29 CFR 1910.22(b)(2), that aisles and passageways be appropriately marked, does not require marking by painted yellow lines only. Painted yellow lines are usually recognized as the most convenient and inexpensive way to mark aisles and passageways since the lines normally last several years without maintenance or repainting. Dirt floors or floors having continuous concentrations of sand or dust would render the application of painted floor markings infeasible and impractical, especially in foundries. Other appropriate methods such as marking pillars, powder stripping, flags, traffic cones, barrels and many other devices are considered appropriate as long as recognition of such is included in the vehicle operator and employee training programs. However, where the need exists and there are no appropriate markings, citations will be issued.

Richard P. Wilson, Deputy Director
Federal Compliance and State Programs

[Corrected 4/24/2004]

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