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Toeboards & OSHA Requirements: When to Use Them

EDGE Fall Protection Industrial Removable Guardrail

What is a toe board: What is it used for?

A toe board is the most basic element of roof safety in use today. It is a horizontal piece of wood or metal (typically the size of a 2 x4) that is run horizontally near roof edges.

The purpose of toeboards is to prevent falling objects, tools, and equipment from going over an edge of a roof or platform. An unprotected edge poses a risk of falling material on those below. Toe boards also help protect workers from falling off elevated walking-working surfaces.

In general, OSHA toe board requirements are in place to ensure a vertical barrier whenever handrails are used with the potential of tools or objects falling from the edge.

Typical toeboards (such as 2×4’s) are in use all over the country in basic applications such as scaffold usage. They provide falling object protection and are basic yet key element in providing a safe working environment.

Consequently, toeboards are often used in conjunction with other pieces of safety equipment. This article is narrow in scope with regard to this specific OSHA standard. However, we do address related safety topics and standards elsewhere on our website.

Here are some quick links for more info on OSHA handrail, safety rail, and guardrail requirements, fixed ladder requirements, personal fall arrest system, swinging gate, standard roof guardrails, and enduring warning lines.

Which Job Sites Require Them?

Small job sites that are mobile or transient, or where construction is only temporarily present, are often treated with less concern for OSHA toe board requirements by project managers-despite the safety and compliance risks of overlooking such hazards. This should not be the case, and can be both an expensive and dangerous oversight.

Those who oversee commercial and industrial work settings fully understand and appreciate the risks an unprotected edge can present, and thus wish to mitigate every fall hazard possible for the safety of their workers.

This article is written for the purpose of clarifying the most commonly asked questions in light of published regulations by OSHA. However, it is no substitute for legal compliance counsel within your organization.

Let’s now discuss each OSHA toeboard requirement in more detail.

OSHA Toe Board Requirements & Usage

OSHA standard 1910.28 defines toe board requirements for “employers to provide protection for each employee exposed to fall and falling object hazards.”

This includes protecting employees from falling objects whether they are underneath a mezzanine, elevated walkway, raised platform, stair rail system, wall opening, ladderway floor hole, scaffold, or platform hole. There are many other working conditions one might overlook as a presenting a fall hazard for objects.

Notice 1910.28(b)(3)(iv) includes toeboards with guardrail system: “Each employee is protected from falling into a ladderway floor opening or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used.” (source)

Further, OSHA standard 1910.29(k) includes standards for “protection from falling objects”. In particular, toeboards used for falling object protection are as follows:

  • Toe Board Height Requirements: 29(k)(1)(ii): “have a vertical minimum height of 3.5 inches (9 cm) as measured from the top edge of the toeboard to the level of the walking-working surface”,
  • Clearance : 29(k)(1)(iii): “do not have more than a 0.25 inch (0.5 cm) clearance or opening above the walking-working surface”, and
  • Force: 29(k)(1)(vi): “should be capable of withstanding a force of at least 50 pounds (222 N) applied in any downward or outward direction at any point along the toeboard.”

Navigating each OSHA toeboard requirement can get a bit technical, and therefore confusing. If you have specific questions and wish to understand compliance for your ongoing working environment or special project, feel free to get in touch.

We commonly walk our customers through the legalize and red tape to help them obtain both safe working conditions and peace of mind from a compliance standpoint.

FAQ Section Regarding Toe Boards:

What is a Toe Board by OSHA Definition?

OSHA has offered a comprehensive definition in their Federal Register Volume 81. It reads:

“The final rule, similar to the proposal, defines this term as a low protective barrier that is designed to prevent materials, tools, and equipment from falling to a lower level, and protect workers from falling. Typically, employers erect toeboards on platforms, dockboards, catwalks, gridirons, and other elevated or exposed floor level edges. Toeboards, also are referred to as toeplates or kickplates, and may be part of a guardrail system.” (Source: Federal Register Volume 81, Number 223.)

Are Toe Boards Mandatory?

Yes, toe boards are an OSHA requirement in any setting where employees are exposed to the risk of something falling on them from above, or falling themselves. The most common risk is falling tools. This is classified within the industry as falling object protection, and it is mandated in a variety of work settings.

What Height Do You Need Toe Boards?

The minimum toe board height should be 3.5 vertical inches (9 cm) by height when measuring from the floor (or walking-working surface) to the top edge. Equally important is securing them in place so that they are capable of withstanding force, and doing so without a clearance of more than 1/4.” (Source Reference: 1910.29(k)(1)(ii))

The most common size in use is 4 inches. The minimum toe board height requirement is less in work settings involving vehicle repair or assembly pits, where it is 2.5 inches or 6 cm. (Source Reference: 1910.29(k)(1)(v))

What is the maximum size of opening around a Toeboard?

Toe boards must be solid and stable, and not have an opening that exceeds 1 inch (or 3 cm) at its greatest dimension. (Reference: 1910.29(k)(1)(iv))

Questions on when toeboards are required in addition to guardrails?

We know that keeping track of the OSHA toeboard requirements can be difficult and time consuming. We are here to help guide you with every consideration and detail from toe plate, guard height, and the minimum and maximum specs for your situation.

EDGE Fall Protection provides a wide range of OSHA compliant edge protection and safety products, and we can advise you on what your unique situation calls for.

Whether you have questions about toeboards or are solving for other edge fall protection needs, we’re eager to help.

Reach out to the EDGE Fall Protection team today.

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