Standard Interpretations - Table of Contents
• Standard Number: 1926.502(d)

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

December 27, 1993

Mr. Bill Luther
Safety Director
RISI, Inc.
7501 Up River Road
P.O. Box 9634
Corpus Christi, Texas 78469

Dear Mr. Luther:

This is in response to your August 2 letter requesting an interpretation of Occupational Safety and Health Administration (OSHA) Standards addressing work performed from pipe racks. I apologize for the delay in responding to your inquiry.

With regard to an employee working while on an elevated pipe rack, please be advised that we would normally consider such a situation to be in compliance with OSHA fall protection regulations if 1) the employee is protected at all times by an adequate fall arrest system (body belt/ harness and lanyard), 2) a safe means of access and egress is provided, and 3) the work can be performed with reasonable ease without a platform.

[This document was edited on 10/22/2004 to strike information that no longer reflects current OSHA policy.]

If a platform is needed to safely perform the task, an adequately installed platform, as described in your letter (e.g. a board f