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| Occupational Safety & Health Administration | ||||||
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Standard Interpretations
06/24/2002 - Clarification concerning fall protection and vertical walled trenches with depth of 6 feet or greater and use of controlled access zones. |
Standard Interpretations - Table of Contents |
| • Standard Number: | 1926.501(b)(7); 1926.501(b)(7)(i); 1926.501(b)(7)(ii); 1926.501(b)(2); 1926.501(b)(9); 1926.502(k); 1926.651(f) |
June 24, 2002 Ned McDougald 4170 W. Menlo Fresno, CA 93722 Dear Mr. McDougald: This is in response to your letter of April 22, 2002, requesting an interpretation of fall protection requirements when working around trenches. Specifically, you ask if fall protection is required around vertical walled trenches that have a depth 6 feet or greater; if there are any exceptions to fall protection around trenches implied or stated; and whether a controlled access zone be used in lieu of fall protection. 29 CFR 1926.501(b)(7) provides: (i) Each employee at the edge of an excavation 6 feet (1.8m) or more in depth shall be protected from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barrier;1 (ii) Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8m) or more in depth shall be protected from falling by guardrail systems, fences, barricades, or covers. Under these provisions, if the trench is not readily visible because of plant growth or other visual barrier, fall protection is required.2 Thus, unless the trench you are describing is obscured from view, there is no requirement for fall protection to be provided. When fall protection is required around trenches, a controlled access zone is not an acceptable means of providing fall protection. Controlled access zones may only be used where employees are performing overhand bricklaying and related work; or as part of a fall protection plan for leading edge work, precast concrete erection or residential construction. See §1926.501(b)(2) (leading edge work); (b)(9) (overhand bricklaying and related work); §1926.502(k) (fall protection plan option); compliance directive CPL 3-0.1A (residential construction); Appendix E (precast erection plan). If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Compliance Assistance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. Sincerely, Russell B. Swanson, Director Directorate of Construction 1Note also that §1926.651(f) of the Excavations standard requires that: when mobile equipment is operated adjacent to an excavation, or when such equipment is required to approach the edge of an excavation, and the operator does not have a clear and direct view of the edge of the excavation, a warning system shall be utilized such as barricades, hand or mechanical signals, or stop logs. If possible, the grade should be away from the excavation.[back to text] 2The fall protection requirements in paragraph (b)(7)(ii) would not normally apply, since trenches usually are narrow and long, and so are not normally similar to "a well, pit, or shaft." [back to text] |
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Standard Interpretations - Table of Contents |
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