Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

December 23, 1976

Mr. Stephen Salup
Assistant Counsel
National Kinney Corporation
10 East 53rd Street
New York, New York 10022

Dear Mr. Salup:

Assistant Secretary Morton Corn has asked me to respond to your letter of October 18, 1976, regarding a clarification of 29 CFR 1926.500(b)(1), as it relates to 29 CFR 1926.750(b)(1)(iii).

While your letter specifically refers to the interrelationship of 29 CFR 1926.500(b)(1) and 29 CFR 1926.750(b)(1)(iii), your conversation with a member of my staff on November 15, 1976, suggests that the focus of your concern is on the interrelationship of the latter standard with 29 CFR 1926.500(d)(1). Accordingly, this response will be similarly focused upon the requirements of the above. Noted steel erection standard as it relates to 29 CFR 1926.500(d)(1).

1. 29 CFR 1926.500(d)(1) Guardrails, Handrails, and Covers, Guarding of open-sided floors, platforms, and runways.

Every open-sided floor or platform 6 feet or more above adjacent floor or ground level shall be guarded by a standard railing, or the equivalent, as specified in paragraph (f)(1) of this section, on all open sides, except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a standard toeboard wherever, beneath the open sides, persons can pass, or there is moving machinery, or there is equipment with which falling material could create a hazard.

2. 29 CFR 1926.750(b)(1)(iii) Steel Erection, Flooring Requirements, Temporary Flooring-Skeleton Steel Construction in Tiered Buildings states:

Floor periphery—safety railing. A safety railing of ½-inch wire rope or equal shall be installed, approximately 42 inches high, around the periphery of all temporary-planked or temporary metal-decked floors of tier buildings and other multifloored structures during structural steel assembly.

The intent of 29 CFR 1926.750(b)(1)(iii) is to protect steel erectors during structural steel assembly. Under this standard, a ½-inch wire rope or equal is required for that purpose. However, whenever any other trades use the same temporary flooring, railings which meet the requirements of 29 CFR 1926.500(d)(1) are required. Thus, it is the nature of the work being performed or the temporary-planked or temporary metal-decked floors, rather than the precise stage of construction, which, in our view, governs the applicability of 29 CFR 1926.500(d)(1) versus 29 CFR 1926.750(b)(1)(iii).

If I may be of any further assistance, please feel free to contact me.


Richard P. Wilson, Acting Director,
Federal Compliance and State Programs

[Correction 6/20/2005. See OSHA Directive CPL 02-01-034 "
Inspection policy and procedures for OSHA's steel erection standards for construction" published on 3/22/2002 for the current policy on OSHA's steel erection standards (1926 Subpart R) for construction.]