I read the October issue Q&A entitled "Are Guardrails Needed if Workers Wear Harnesses?" The provided answer needs to be supplemented with additional OSHA requirements for holes that have fall heights of less than 6 feet. Specifically, 29 CFR 1926.501(b)(4)(ii) requires all holes regardless of depth to be protected such that employees cannot trip or stumble into them. A personal fall arrest system (PFAS) does not meet OSHA's requirements for such holes. In such cases, holes must be either covered or guarded. If the question involved a deck with a fall exposure of less than 6 feet, a PFAS is not permitted and the hole must be either guarded or covered.
OSHA clarified this in an 11/17/98 letter of interpretation regarding an elevator pit, as follows:
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