OSHA recently responded with a letter of interpretation on the use of toeboards on scaffolds.  The question:  Are toeboards required at access openings?

OSHA’s answer:

Where there is a danger of tools, materials, or equipment falling from a scaffold and striking employees below, the following provisions apply:

(i) The area below the scaffold to which objects can fall shall be barricaded, and employees shall not be permitted to enter the hazard area; or

(ii) A toeboard shall be erected along the edge of platforms more than 10 feet (3.1 m) above lower levels for a distance sufficient to protect employees below, except on float (ship) scaffolds where an edging of (¾ x 1 ½ inch (2 x 4 cm) wood or equivalent may be used in lieu of toeboards.

We note that, in some instances, such as when a stair tower is used for access, a toeboard across the access point would pose a tripping hazard that would be as great a safety concern as the potential for falling objects. In that case the employer would have to use the barricade option unless there was no danger of tools, materials or equipment falling from the scaffold at that point (in which case there would be no falling object hazard at that point, and therefore no need for a toeboard).

Real World:

Audits show that toeboards are not used anywhere on the scaffold, not just at access points.  Toeboards are part of the guardrail system.  Guardrail systems consist of toprail, midrail and toeboards.