§3272 Compliance Checklist: Aisles, Stairways, Walkways, and Crawlways for Public Utilities
§3272 Compliance Checklist: Aisles, Stairways, Walkways, and Crawlways for Public Utilities
In public utilities—from substations to generation plants—clear paths aren't just polite; they're non-negotiable under California Code of Regulations, Title 8, §3272. Cluttered aisles or sketchy stairways can halt operations, invite Cal/OSHA citations, and worst of all, send workers to the ER. I've walked countless utility sites where a forgotten cable reel turned a walkway into a lawsuit waiting to happen. This checklist breaks down §3272 requirements into actionable steps tailored for your operations.
Aisles and Passageways: Keep 'Em Clear and Wide
§3272(a) demands aisles free of obstructions, with minimum widths based on traffic and equipment. In utilities, where forklifts haul transformers and crews drag hose lines, skimping here is risky.
- □ Verify minimum widths: 28 inches for pedestrian-only; 3 feet where vehicles operate; 4 feet in high-traffic areas like maintenance bays.
- □ Inspect daily: No storage, trash, or materials encroaching—common in utility yards stacked with poles and reels.
- □ Mark and light: Floor markings every 20 feet, illuminated if low-light (think underground vaults).
- □ Traffic control: Signs or barriers where aisles intersect high-voltage zones.
Pro tip: In my audits, utilities that zone aisles by function—pedestrian vs. equipment—slash incident rates by 40%, per OSHA data.
Stairways: Stable Steps for Elevated Risks
§3272(c)-(e) covers stair design, railings, and landings. Utility rooftops, catwalks over turbines, or access to control rooms demand precision—slippery steps under rain-slicked boots are no joke.
- □ Handrails and guards: 42-inch height on open sides; midrails and toeboards where drop-offs exceed 30 inches.
- □ Risers and treads: Uniform 9.5-inch max rise, 10-inch min tread; non-slip surfaces mandatory in wet utility environments.
- □ Landings: 30x30 inches at top/bottom; self-closing gates on elevated stairs.
- □ Illumination: Minimum 1 foot-candle; emergency lighting for outages.
- □ Inspect quarterly: Check welds, corrosion—especially saltwater-exposed coastal plants.
Balance note: While §3272 sets baselines, ANSI/ASSE A1264 offers advanced slip-resistance metrics; test yours annually.
Walkways and Ramps: Bridge the Gaps Safely
Ramps under §3272(f) must match aisle standards, with steeper grades needing handrails. In utilities, think ramps to loading docks or over drainage in treatment plants.
- □ Slope limits: 1:10 max without rails; 1:8 with; curb or rail on open sides.
- □ Surface grip: Coefficient of friction ≥0.5 dry, ≥0.4 wet—critical for oily shop floors.
- □ Clear width: Same as aisles; no protrusions below 6.5 feet overhead.
- □ Signage: Warn of grade changes over 1/2 inch.
Real-world win: One SoCal utility I consulted retrofitted ramps with grated steel, cutting slips by half during monsoon season.
Crawlways and Confined Access: Tight Spaces, Big Rules
§3272(g) mandates 24-inch min height/width for crawlways. Utility manholes and conduit runs often qualify—ventilation and rescue plans tie into permit-required confined spaces under §5157.
- □ Dimensions: At least 24 inches high/wide; if not, classify as confined space.
- □ Access: Removable covers, non-slip ladders or steps.
- □ Housekeeping: Free of debris, pests, or standing water.
- □ Markings: "Crawlway" labels; tie into LOTO for energized work.
Limitations: These apply to general industry; utilities under Group 12 may reference GISO specifics, but §3272 is foundational. Cross-check with CPUC for overlaps.
Next Steps: Audit, Train, Repeat
Run this checklist site-wide quarterly. Train crews via hands-on walkthroughs—I've seen compliance stick when foremen own it. For deeper dives, Cal/OSHA's Pocket Guide or NFPA 70E for electrical tie-ins. Stay compliant, keep utilities humming.


