September 14, 1990
| MEMORANDUM FOR: |
Charles Culver
|
| THRU: |
Roger Clark
|
| FROM: |
Roy Gurnham
|
| SUBJECT: |
Perimeter Guarding Utilizing Wire Rope |
Thank you for sending me a copy of your September 7 memo to Pat Clark,
subject as above--the acceptance of 1/4 and 1/2-inch wire rope for perimeter
guardrails.
In the last paragraph of your memo, you noted your willingness to help if
Ms. Clark decides that national office direction is warranted to eliminate
inconsistencies and to clarify the standard. In this regard, I thought you
might want to know that in the November 25, 1986, NPRM on Subpart M--Fall
Protection (1926) the agency proposed several requirements for the criteria
for guardrail systems. One of these requirements is that the toprail be at
least 1/4-inch diameter or thickness. The 1/4-inch requirement addresses
hazards of cuts and lacerations that may occur when an employee grabs the
rope. The rulemaking record supports the proposed provision of 1/4" toprails
provided they are flagged for visibility. Thus, you can anticipate that the
final rule will be clear as to the agency's position.
In addition, in the NPRM for steel erection, we raised an issue regarding
perimeter protection. Currently, our position is that the safety railing
system required in .750 must be a minimum 1/2-inch wire rope because of the
impact load the railing may have to withstand if struck by hoisted steel
members. In the NPRM, we are specifically asking for comments on whether we
should keep this requirement and whether we should require a conventional
two-rail guardrail system for steel work. We have also proposed to remove
the words "or equal" which appear in the existing standard after the words
"1/2 inch." The "or equal" was a reference to the materials used and not to
their strength. This appears to have been misunderstood. The final rule on
steel will clearly set forth the requirements for wire rope used as a fall
prevention measure.
Please let me know if further clarification of the proposed rules is needed.
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