OSHA requirements for work platforms can be horribly complex. OSHA 1910.29 applies directly to work platforms, but you have to determine if the platform is a "mobile tubular welded frame scaffold," a "mobile work stand," a "mobile ladder stand," or something else entirely. On top of that, OSHA 1910.23 also applies to work platforms, and at times the standards say two entirely different things.
Did you build your own platform, or perhaps buy it from a company unfamiliar with the applicable OSHA standards? You may be at risk of violating OSHA requirements for manually propelled mobile ladder stands and scaffolds and/or floor and wall openings and holes without even knowing it.
To help you out, here is a list of five OSHA standards for work platforms that you may not be aware of:
1. Railing is required at working heights of 4’ or more
OSHA 1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides, persons can pass, there is moving machinery, or there is equipment with which falling materials could create a hazard.
This may be the quintessential OSHA requirement for work platforms. Any work area four feet or more above the next level lower MUST have guardrails. Period. The guardrails must be on every open side of the platform, excluding openings. The only time railing is not required is when the platform is up against another vertical surface (like the side of a helicopter). In that case, it is still critical to ensure railing covers any gaps.
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2. Guard railing must be 42” high and have a top rail, intermediate rail, and posts
OSHA 1910.23(e)(1) A standard railing shall consist of top rail, intermediate rail, and posts, and shall have a vertical height of 42 inches nominal from upper surface of top rail to floor, platform, runway, or ramp level. The top rail shall be smooth-surfaced throughout the length of the railing. The intermediate rail shall be approximately halfway between the top rail and the floor, platform, runway, or ramp. The ends of the rails shall not overhang the terminal posts except where such overhang does not constitute a projection hazard.
Different standards call out different height range requirements for handrails, but this one is explicit: The railing must be 42”, no taller, no shorter. An intermediate rail is also required to keep people or objects from falling through the gaps. Although OSHA doesn’t specify the exact placement of the intermediate rail, at Spika we also ensure compliance with AFOSH (Air Force Office of Safety and Health) standards and follow what is sometimes known as the “beach ball rule.” Imagine you are holding a beach ball that is 19” in diameter. The railing must be placed so that the ball cannot pass through any opening in the handrail.
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3. A 4” toeboard is required to keep material from falling off the platform
OSHA 1910.23(e)(4) A standard toeboard shall be 4 inches nominal in vertical height from its top edge to the level of the floor, platform, runway, or ramp. It shall be securely fastened in place and with not more than 1/4-inch clearance above floor level. It may be made of any substantial material either solid or with openings not over 1 inch in greatest dimension. Where material is piled to such height that a standard toeboard does not provide protection, paneling from floor to intermediate rail, or to top rail shall be provided.
When you are manufacturing a satellite or maintaining an aircraft, there is a good chance you will be setting tools, parts, and hardware on the floor beside you. In order to prevent a wrench from falling off the platform and smacking a coworker on the head, toeboards are required on all open sides of the platform (excluding openings).
Check out these case studies for the OSHA-compliant aerospace work platforms:
4. If a staircase has four or more steps, it requires handrails
OSHA 1910.23(d)(1) Every flight of stairs having four or more risers shall be equipped with standard stair railings or standard handrails as specified in paragraphs (d)(1)(i) through (v) of this section.
Four steps doesn’t seem very high, but it’s enough for OSHA to require railing. Even simple step stools may need handrails. These rails must be 30” – 34” in height.
5. Openings must be offset or guarded by a swing gate
OSHA 1910.23(a)(2) Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
When your work platform is accessed via a ladder, it’s pretty clear that a swing gate is needed to keep someone from accidently walking out the opening. With a staircase, the need may not be as obvious. But consider the image below. If you were working on equipment at the back side of the platform, and you were moving along from the left to the right intensely engaged in your work, there would not be much to indicate to you that you’re about to fall down a staircase. There either needs to be a gate to prevent a direct path down the stairs, or the staircase needs to be oriented perpendicular to the work platform.
The number of safety standards that apply to work stands can be overwhelming. If you are unsure whether your platform is in compliance, ask the experts. It's not worth risking injuries, fines, and decreased employee moral, and often one little fix can bring you into full compliance.
Are you interested in seeing what your OSHA-compliant work platform could look like?
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