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Maximum gap between adjacent tank-runway guardrails

Summary A company asked how large a gap could remain where guarded runways on adjacent tanks meet but cannot be connected. OSHA said a maximum opening of four inches would satisfy the cited general-industry guardrail rule for the described setup. OSHA now labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-12-10
Date issued
December 10, 1996
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Guardrails
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 10, 1996

Mr. Jerome Spear, CSP
Chicago Bridge & Iron Company
[Recipient address omitted]
Dear Mr. Spear:

This is in response to your letter of November 26, regarding an interpretation of the 29 CFR 1910.23 standards relating to guardrails.

You indicated in your conversation with Art Buchanan, as well as in your letter, that two tanks are located adjacent to each other. A runway with standard guardrails is located on top of each tank with the end of the two runways butted to each other, but not connected (a drawing was attached). You also indicated that the two runways cannot be attached to each other because of the independent movement of the tanks that occurs during operation; however, engineering modification can be incorporated to minimize the gap between the two guardrails. Based on the information that you have provided, a maximum opening of four inches between the two guardrails would ensure compliance with 29 CFR 1910.23.

Thank you for your inquiry. If you need further assistance, please contact [the Office of General Industry Enforcement at (202) 693-1850].

Sincerely,

Raymond E. Donnelly, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]

[Requester letter reproduced on OSHA page; omitted here.]

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