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March 31, 1988
| MEMORANDUM FOR: |
LINDA R. ANKU |
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Regional Administrator |
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| THRU: |
LEO CAREY, Director |
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Office of Field Programs |
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| FROM: |
THOMAS J. SHEPICH, Director |
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Directorate of Compliance Programs |
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| SUBJECT: |
Failure of Wire Rope and Banding Steel Guardrails to |
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provide Protection as per 29 CFR 1926.500(f)(1)(iv) |
The studies performed by your safety engineer indicate that 1/2-inch and
1/4-inch wire rope, which are commonly used in lieu of standard railings,
will not provide protection equivalent to that provided by a standard railing
that conforms to the requirements of 29 CFR 1926.500(f)(1)(iv) at specific
spans. It is also stated that similar conclusions may be reached with the
regard to the strength of steel banding. The subject standard is a
performance standard which does not specify the span between posts.
Employers may decrease the span between posts to comply with our defection
requirements provided in STD 3-10.3. This practice may not be practical
solution but employers have the option of placing the posts as close as
necessary to comply with our deflection requirements or of being cited. In
regard to metal banding the strength varies according to the width and
thickness of the banding used by the employer for top and intermediate rails.
When the subpart M final rule is promulgated in the Federal Register
the prohibition will become enforceable and additional enforcement criteria
will be included to support the prohibition of steel banding. Employers not
in compliance with 29 CFR 1926.500(f)(1)(iv) shall be cited as indicated in
this memorandum and previous correspondence covering this matter. If you
have any questions concerning this matter, please contact Bill Simms on
523-8124.
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