Guarding ladderway floor openings

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 12, 1992

Ms. Jane Obaggy
Arthur D. Little, Inc.
[Recipient address omitted]
Dear Ms. Obaggy:

Thank you for your inquiry of April 10, requesting interpretation of the Occupational Safety and Health Administration (OSHA) standard at 29 CFR 1910.23(a)(2) as it pertains to protection for ladderway floor openings.

You specifically request clarification of the following items:

1. Does the phrase "except at entrance to opening" refer exclusively to standard toeboard or to both standard railing and standard toeboard?

2. Can a single vertically rising bar which must be pivoted approximately 80 degrees from the horizontal comply with the OSHA standard at 1910.23(a)(2)?

In response to item 1., the OSHA standard at 29 CFR 1910.23(a)(2) requires that every ladderway floor opening be guarded by a standard railing with standard toeboards on all exposed sides. This means both standard railing and standard toeboard are required to satisfy the standard.

In response to item 2., a single vertically rising bar which must be pivoted approximately 80 degrees from the horizontal does not comply with the OSHA standard at 29 CFR 1910.23(a)(2). This standard requires a passage through the railing with a swinging gate, or so offset that a person cannot walk directly into the opening.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,

Raymond Donnelly, Director
Office of General Industry
Compliance Assistance