Standard Interpretations - Table of Contents
• Standard Number: 1910 Subpart D; 1910.132(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 http://www.osha.gov.


October 18, 1996

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

FROM: JOHN B. MILES, JR, DIRECTOR
[DIRECTORATE OF ENFORCEMENT PROGRAMS]

SUBJECT: Enforcement of Fall Protection on Moving Stock


The Directorate has been asked by the National Grain and Food Association (NGFA) to clarify the Agency's enforcement policy relating to fall hazards from the tops of "rolling stock," such as rail tank or hopper cars and tank or hopper trucks or trailers. The reason for this request is that the NGFA is concerned that the Agency may inappropriately issue citations for fall hazards from such equipment. Part of the NGFA's concern is that inspectors from the Federal Grain Inspection Service allegedly have indicated to grain handling companies that they are unwilling to place themselves in situations which potentially violat