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Guarding bus and rail repair pits

Summary A transit agency asked how OSHA's floor opening rule applied to bus and rail repair pits. OSHA said maintenance work over a pit covered by a vehicle was permissible, and employees could walk at least six feet from an uncovered pit if training, visible boundary lines, and caution signs were in place. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1982-08-09
Date issued
August 9, 1982
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The official sitemap also lists seven suffixed URLs for this date; all eight fetched pages have identical letter text, so this record uses the unsuffixed URL.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Floor Openings Vehicle Maintenance Fall Protection
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. The official sitemap also lists seven suffixed URLs for this date; all eight fetched pages have identical letter text, so this record uses the unsuffixed URL. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 9, 1982

Mr. Kevin D. Lyons
Safety Inspector
Safety and Systems Assurance Branch
Washington Metropolitan Area Transit Authority
[Recipient address omitted]

Dear Mr. Lyons:

This is in response to your letter of July 27, 1982, requesting a clarification of 29 CFR 1910.23(a)(5) as it would apply to repair pits.

Employees engaged in maintenance work at bus and rail car inspection and repair pits when the bus or rail car covers the pit are not in violation of 29 CFR 1910.23(a)(5). When the pit or pits are not covered, employees walking at least 6 feet from the pit would not be in violation of 29 CFR 1910.23(a)(5), provided the following actions are implemented by the employer:

  1. The employee's safety training program will instruct employees to maintain a 6 feet clear distance from uncovered pits.

  2. Highly visible contrasting lines will be installed 6 feet from the edge of pits.

  3. Employer will install caution signs and ensure compliance by employees.

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

Sincerely,
Patrick R. Tyson
Director,
Federal Compliance and State Programs

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