So there are differences between holes and openings. A "hole" is talking about any
opening in a horizontal surface. An "opening" is always going to be in a vertical surface,
such as a window opening. So a hole means a gap or open space in a floor, roof,
horizontal walking-working surface, or similar surface that is at least two inches (5cm) in
its least dimension. So a couple examples of holes that we would see in horizontal
walking-working surfaces are going to be the skylights that you'll find on roofs,
unless that skylight is designed to meet a certain capacity we'll consider it a hole.
And a skylight is not designed to keep people from falling through it. When I was an inspector,
I have actually seen skylights with handprints on the dusty part of the plastic where somebody
was sitting up there and put their hands on it to stand up. If you're sitting on a skylight,
you may have a 25-foot fall to the floor below, and they are not designed to keep you from falling
through. So, it is important that employers know number one, if they allow their employees to go
on a roof to do maintenance, it's not just the edge of the roof that is the hazard, it's also
those multiple skylights. And so, there are things that an employer can do, which is you buy guards
and you guard those skylights so that a person cannot get to the skylight and fall through.
Another example would be a trap door. So, you may have a basement or a cellar that
has a stairway that goes down to it and there's a trap door that will hinge up. Another example
of a hole would be a manhole cover or a utility vault cover so when that cover is
opened or removed, you have introduced a hole into a walking-working surface.
So an opening in the walking-working surface rules means a gap or open space in a wall,
partition, vertical walking-working surface,
or a similar surface that is at least 30 inches (76cm) high and at least 18 inches (46cm) wide,
through which an employee can fall to a lower level. So an opening is going to always be in a
vertical surface such as a window opening if the glass is actually removed. It could be a opening
in the wall if there is a debris shoot, a trash chute, where there is the potential
where an employee could fall into that opening and to a lower level. Generally the best way
to prevent a fall hazard through an opening is going to be with a standard guardrail system.
So basically what you'll see is they'll have the window cut out, right, your first board
has to be 42, give or take three, and then you go down to 21 and then a toe board. But if you have
the window seal, then you don't need a toe board at the bottom rail, you just got to protect it.
But that's not always possible. So you may have to use a travel
restraint system that prevents an employee from physically being able
to get into the wall opening and in limited situations a personal fall arrest system.