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 https://www.osha.gov.
May 25, 1994
Mr. Mark H. Sousa
Rytheon Engineering and Constructors, Inc.
Ebaso Division
145 Technology Park
Norcross, Georgia 30092-2978
Dear Mr. Sousa:
This is in response to your April 1 fax transmission to the Occupational Safety and Health Administration's (OSHA) Atlanta Regional Office. Your inquiry concerning chimney platform was forwarded to this office for response. I apologize for the delay in responding to your inquiry.
As you may know, OSHA's regulations for general industry operations (Part 1910) and those for construction operations (Part 1926) do not contain provisions specifically addressing chimney platforms. However, both sets of rules do contain general provisions for scaffolds and those provisions have been interpreted to allow up to 14 inches of space between the scaffold working edge and the structure. Distances of more than 14 inches would have to be filled in or fall protection would have to be used. Your design of a two inch opening is, obviously, well within the allowable range.
Toeboards are required only when there are employees below the platform who would be struck if something was dropped from the platform. In lieu of toeboards, the area on the ground may be barricaded to prevent employee access and exposure to the hazard. Of course, as the height of the scaffold increases, the barricaded area needs to increase in size and this can often be infeasible.
If we may be of further assistance, please contact either Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136 if you have a construction question, or Mr. Rolland Stroup at (202) 219-8031, ext. 115 if you have a general industry question.
Sincerely,
John B. Miles, Jr. Director
Directorate of Compliance Programs
April 8, 1994
MEMORANDUM FOR: ROGER CLARK, Director
Directorate of Compliance Programs
THROUGH: LEO CAREY, Director
Office of Field Operations
ATTENTION: RAYMOND DONNELLY
Office of General Industry
Compliance Assistance
FROM: SVEN J. RUNDMAN III
Acting Assistant
Regional Administrator for Technical Support
SUBJECT: Concrete or Steel Chimney Platforms
Enclosed is a copy of a letter from Mr. Mark H. Sousa of Raytheon Engineers and Constructors, Inc., Ebasco Division. Mr. Sousa is requesting information on what standards would apply to the design of chimney platforms that vary in height of up to 200 feet above ground. Specifically, is there any standard that establishes a maximum horizontal clearance between the outside edge of the chimney and the inside edge of the circumferential platform:
(A) with a 4 inch toeplate? or (B) without a 4 inch toeplate?
Also, at what horizontal distance would a standard guardrail system be required around the inside edge of the circular platform?
Ebasco Division is planning to design platforms for various chimneys located throughout the United States and, therefore, we are requesting that you please respond directly to Mr. Sousa at the address listed below with a copy of your interpretation forwarded to this office.
Rytheon Engineering and Constructors, Inc.
Ebasco Division
145 Technology Park
Norcross, GA 30092-2978
Telephone # (404)662-2222
If you have any questions, please contact me or Mike Shea of my staff at (404)347-2281.
Attachments
RECOMMENDED DETAILS FOR CLEARANCE BETWEEN CHIMNEY SHAFT
AND INSIDE EDGE OF PLATFORM GRATING
PROBLEM: What OSHA Regulation and paragraph applies for establishing the maximum clearance to be provided between the outside edge of concrete or steel chimneys and the inside edge of the circumferential flatform grating (with or without tow plate). We assume that 29 CFR PART 1910 (OSHA) would be the Regulation.
The following is provided as background information, what we are recommending and why. We consider this to be a safe design, but are unable to point to a specific OSHA paragraph to confirm our recommendation.
1. See attached sketches - Plan and Sections
2. Hand sketch to indicate the recommended clearances without attaching a toe plate. Our intent here is to have a maximum gap of two inches only at the support bracket locations. The gap will only be 1/2 inch at the midpoint between brackets.
3. Our recommendation is based upon providing a design that is economical, easy to fabricate, easy to install, and takes into account that the chimneys are not perfectly round.