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Fall protection on refrigerator roof used for storage

Summary A company asked whether a walk-in refrigerator roof used for occasional storage needed edge protection. OSHA said employees working near the edge required fall protection even if they visited only a few days a year, and described a tied-off belt and lanyard as one possible method. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1978-04-05
Date issued
April 5, 1978
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Fall Protection Guardrails Storage Platforms
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 5, 1978

Mr. John R. Reilly
Corporate Director
Fisher Scientific Company
[Recipient address omitted]
Dear Mr. Reilly:

This is in response to your letter dated February 20, 1978, requesting a clarification of 29 CFR 1910.23(c)(1) and confirms your telephone conversation with Mr. William Simms of my staff.

The aforementioned General Industry Safety Standard requires that every open-sided floor or platform more than four feet above the adjacent level shall be provided with a standard railing. This requirement is applied to areas where employees are required to work or walk as part of fulfilling conditions of their employment. If the roof platform on top of a walk-in refrigerator is visited even a few days each year to store materials, employees required to work adjacent to or near the edge shall be provided with some means of protection. Such protection could be a life belt and lanyard tied off of a structural member so as to prevent the employee from walking off or falling from the exposed edges of the refrigerator roof top used as a storage platform.

If I may be of any further assistance, please feel free to contact me.

Sincerely,

Janet H. Sprickman,
Acting Chief
Division of Occupational Safety Programming

Enclosures

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