Standard Interpretations - Table of Contents
• Standard Number: 1910.23(e)(6)

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

May 26, 1995

Mr. Scott Stratton
Vice President
Stratton, Inc.
2513 Deaton Street
Lake Charles, LA 70601

Dear Mr. Stratton:

This is in response to your September 8, 1994 letter requesting interpretation of the Walking-Working Surfaces Standard, 29 CFR 1910 Subpart D, as it may apply to the catwalks described in the workplace scenario below. Your questions and our reply follow. Please accept our apology for the delay in responding.

Scenario: An aircraft maintenance hanger has catwalks at approximately 38 feet (11.58m) and 58 feet (17.68 m) above the floor below. The lighting for the hangar which is suspended from the catwalk guard/handrails is well grounded and meets the National Electrical Code. The rails consist of 2 inches (5.08 cm) by 3 inches (7.62 cm) angle at the top and intermediate rails. The mounting bracket for each of the lighting fixture is attached directly to the top rail of the catwalk as depicted on the sketches: Detai