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OSHA 1917.125

Guarding temporary hazards

Subpart F

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.125, which specific hazards must be guarded at marine terminals?

Yes — 1917.125 requires guarding of ditches, pits, excavations, and surfaces in poor repair. See 1917.125 which explicitly lists those conditions that must be protected by readily visible barricades, rails, or other equally effective means.

Under 1917.125, when must a temporary hazard be guarded?

You must guard a temporary hazard whenever it exists and could expose employees to harm — guarding must be in place while the ditch, pit, excavation or surface in poor repair is present and until the hazard is eliminated or appropriately repaired. The obligation to guard these conditions is stated in 1917.125.

Under 1917.125, what types of guarding meet the standard’s requirement?

Acceptable guarding includes readily visible barricades, rails, or other equally effective means that prevent entry or falls into the hazard. The standard names barricades and rails but allows any alternative that is equally effective at protecting employees from the specific hazard. When choosing an alternative, ensure it physically prevents access or fall and is obvious to workers (high visibility, stable, and secure).

Under 1917.125, what does “readily visible” mean for barricades and rails?

"Readily visible" means guards must be obvious to workers under normal working conditions — for example, painted a high‑visibility color, fitted with reflective tape, illuminated, or otherwise made conspicuous so employees will notice and avoid the hazard. This visibility requirement flows directly from 1917.125, which specifies that guards be readily visible. Consider supplemental lighting or reflective markings if work occurs at night or in low light.

Under 1917.125, can cones or warning tape alone satisfy the guarding requirement?

Maybe — cones or warning tape can meet the requirement only if they are readily visible and effectively prevent access or falls for the specific hazard; otherwise they are not sufficient. 1917.125 allows "other equally effective means," so choose cones or tape only when they demonstrably stop employees from entering the hazard or falling into it (for example, combined with lighting, signage, and a controlled work zone).

Under 1917.125, who is responsible for installing and maintaining guards for temporary hazards?

The employer is responsible for ensuring temporary hazards are guarded — employers must provide the required barricades, rails, or other equally effective means and keep them maintained while the hazard exists. See the marine terminals part generally at 1917 and the specific requirement in 1917.125. Employers should assign someone to inspect and repair guards as needed so visibility and effectiveness are not compromised.

Under 1917.125, do these guarding rules apply at a designated waterfront facility used only for bulk storage and transfer of liquids or gases?

Not necessarily — Part 1917’s specific requirements, including 1917.125, do not apply to facilities that meet the definition of a designated waterfront facility used solely for bulk storage, handling, and transfer of liquids or gases. OSHA explained this scope limitation in the letter of interpretation "Applicability to waterfront facilities" (May 31, 2017). Employers at those facilities should determine which OSHA standards, if any, apply and follow applicable requirements.

Under 1917.125, may a secure cover be used instead of a rail around a pit or ditch?

Yes — a secure cover can be used if it is equally effective at preventing falls or entry into the hazard. 1917.125 allows "other equally effective means," so a cover that is strong, secured, and readily visible may satisfy the requirement. Ensure the cover is rated for any expected loads and clearly marked so workers know it is not an opening.

Under 1917.125, how far from an excavation should a barricade or rail be placed?

There is no fixed distance in 1917.125; the barricade or rail must be located so it effectively prevents employees from falling into or entering the hazard. Rely on the job conditions to set spacing — place guards at a distance that accounts for equipment swing, expected foot traffic, and the slope of the ground. The performance requirement is in 1917.125, so document the rationale for your placement based on preventing access or falls.

Under 1917.125, does poor lighting affect whether a guard is “readily visible”?

Yes — if lighting conditions make a barricade or rail hard to see, the guard is not "readily visible" and must be improved by adding lights, reflective markings, or other measures. 1917.125 requires guards to be readily visible, so employers should add illumination or reflective enhancements when work is done in low light or at night.

Under 1917.125, are warning signs alone enough to comply when a surface is in poor repair?

No — warning signs alone are generally not enough where there is a physical risk of falling or stepping into a hazard; 1917.125 requires readily visible barricades, rails, or other equally effective means. Signs can supplement physical guards but should not be the only control when a physical barrier is needed to prevent access or injury.

Under 1917.125, how long must temporary guarding remain in place after a repair is started?

Keep guarding in place until the hazard is effectively removed or the surface is fully repaired and returned to safe condition. 1917.125 requires guarding of surfaces in poor repair, so remove the guards only when the employer can document that the repair restores the surface to a safe state and no residual hazard remains.

Under 1917.125, if a temporary platform or work bridge is used, do other standards for fall protection apply?

Possibly — while 1917.125 requires guarding for temporary hazards, other standards that address scaffolds, platforms, and fall protection may also apply depending on the activity. OSHA has discussed overlap between marine and construction standards in guidance such as the letter of interpretation about fall protection for bridge work Feb. 9, 2004. Employers must evaluate all applicable standards and provide any additional fall protection required by those standards.

Under 1917.125, what records or documentation should an employer keep about temporary guards?

Keep documentation showing the hazard assessment, the type of guard used, placement rationale, inspections, and repairs or removal justification. While 1917.125 does not list paperwork requirements, maintaining records demonstrates compliance and helps show that barricades, rails, or other means were provided, inspected, and left in place until the hazard was abated as required by the standard.

Under 1917.125, how should employers handle employee access when a surface is in poor repair but operations must continue?

Control access with physical guards and administrative controls: install readily visible barricades or rails to isolate the damaged area, post trained attendants or spotters if needed, reroute pedestrian traffic, and repair the surface promptly. These steps meet the performance requirement in 1917.125 by preventing exposure until the hazard is fixed.