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The Guardian Fall Team Blog

In day-to-day usage outside of the construction industry, we often use the words “hole” and “opening” interchangeably, that is we simply consider them to be some sort of void - be it round or square, on the floor, on a wall, or even in the ceiling. But for the purposes of understanding OSHA regulations (specifically 1926.501 (b)(4)), it’s necessary to think about holes and openings as distinctly different entities, each with their own regulations in the context of fall protection.

What is a Hole?

According to OSHA regulation 1926.500 (b), a “hole” is:

“…a gap or void 2 inches (5.1 cm) or more in its least dimension, in a floor, roof, or other walking/working surface.”

Example of a Hole - Guardian Fall Protection

What is an Opening?

And according to OSHA regulation 1926.500 (b), an “opening” is:

“…a gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide, in a wall or partition, through which employees can fall to a lower level.”

Example of An Opening - Guardian Fall Protection

Two problems, two solutions

So according to OSHA, not only is the location of a hole different than an opening (walking surface vs. wall), but so is the physical size of the void into which - or through - a worker may fall. There are obvious reasons for this, for example a 6-inch void on a walking surface presents a much greater hazard than a 6-inch void in a wall, so it makes sense that instead of trying to cover all instances of voids with a single dimension, OHSA differentiates between the two.

As to how to address fall prevention for holes and openings, OHSA provides the following regulations:

For holes...

OSHA 1926.501(b)(4)(ii)

“Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.”

For openings...

OSHA 1926.501(b)(14)

“Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking/working surface, shall be protected from falling by the use of a guardrail system, a safety net system, or a personal fall arrest system.”

Hey, something sounds familiar!

If you are wondering where that seemingly arbitrary number of 39 inches came from, think of a guardrail. OSHA requires that guardrails be installed at a height of 42 inches plus or minus 3 inches. 42” – 3” = 39”. Essentially, OSHA wants an unrestricted opening no lower than the minimum guardrail height – makes sense, no?

A hole is a hole of course, of course, unless, of course, the hole, of course – is covered…

Also, keep in mind that a hole or an opening must be addressed in regards to fall protection as soon as it is created – there is NO grace period as to when fall protection must be in place. This question was addressed specifically in a standard interpretation by OSHA in which it stated:

“Case law has established that brevity of exposure to a hazard is not a defense to a failure to protect against a hazard. Where the duty under 1926.501(b)(4) applies, it must be complied with immediately.”

In other words, you may not create a series of holes or openings and then go back and cover or restrict access to them and be in compliance. According to OSHA, the holes or openings must be covered or access restricted as soon as the hazard exists. So, feel free to create holes or openings as your jobsite requires, but stay in OSHA compliance by covering/restricting access to them immediately.