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Fall protection on extendable gangways

Summary A gangway seller asked OSHA to assess its extendable design. OSHA said the missing midrail appeared to violate its then-current platform rule, but could be treated as de minimis if users had alternative fall protection, and it flagged a possible projecting handrail hazard. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-07-24-0
Date issued
July 24, 1995
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 9, 2026
Topics
Workplace Safety OSHA 1910 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 24, 1995

Ronald W. Bennett
Chief Engineer
Carbis Sales, Inc.
[Recipient address omitted]
Dear Mr. Bennett:

This is in response to your January 25 letter requesting a compliance determination from the Occupational Safety and Health Administration (OSHA) for your extendable gangway. I apologize for the delay in responding to your inquiry.

We have reviewed the product information enclosed with your letter for your extendable gangway. Your product appears to be in violation of section 29 CFR 1910.23(c), which covers protection of open-sided floors, platforms, and runways, because the extendable gangway lacks a required midrail employee fall protection. However, the lack of midrail at the extension area would be considered a de minimis violation when employees using the extendable gangway are provided With alternative fall protection such as a safety belt and lanyard. De minimis violations are violations of standards which have no direct or immediate relationship to safety and health and shall not be included in citations.

In addition, it appears that employees using the extendable gangway may be exposed to a potential projection hazard from the telescoping handrail.

If we can be of any further assistance, please contact Mr. Wil Epps. of my staff at (202) 219-8041.

Sincerely,

Raymond E. Donnelly
Director
Office of General Industry
Compliance Assistance

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