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Do You Need Toeboards on Guardrails

Our short answer is: “No on low slope edges, Yes everywhere else.”

It is our interpretation of the OSHA regulations that the Toeboard is not an integral part of a guardrail for fall protection purposes on Low Slope Edges but is required for Openings and Steep Slope Edges. We believe Toeboards are essential for protection of falling material if the area where potential falling material is not access limited. Please see the cited specs below and please let us know if you have heard of it interpreted differently.

Every floor hole into which persons can accidentally walk shall be guarded by … A standard railing with standard toeboard on all exposed sides,

Every wall opening from which there is a drop of more than 4 feet shall be guarded by… Rail, roller, picket fence, half door, or equivalent barrier. Where there is exposure below to falling materials, a removable toe board or the equivalent shall also be provided.

Every open-sided floor or platform … shall be guarded by a standard railing … on all open sides… The railing shall be provided with a toeboard wherever, beneath the open sides,
  • 1910.23(c)(1)(i) Persons can pass,
  • 1910.23(c)(1)(ii) There is moving machinery, or
  • 1910.23(c)(1)(iii) There is equipment with which falling materials could create a hazard.
“Railing, toe boards, and cover specifications.”

1910.23(e)(4)
A standard toeboard shall be 4 inches nominal in vertical height from its top edge to the level of the floor, platform, runway, or ramp. It shall be securely fastened in place and with not more than 1/4-inch clearance above floor level. It may be made of any substantial material either solid or with openings not over 1 inch in greatest dimension.

“Steep roofs.” Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.

So, we would interpret this to mean that if the work area underneath the guardrail is roped off and does not contain operating equipment Toeboards would not be necessary on Low Slope Edges. These are only the Federal OSHA regulations and we would love to hear about other interpretations or State Safety Organizations that have different regulations. That being said, all of our Guardrail Systems have fasteners for toeboards; and we encourage their usage when needed.


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