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 http://www.osha.gov.

January 9, 1979

MEMORANDUM FOR: ALFRED BARDEN

REGIONAL ADMINISTRATOR REGION II

THRU: DONALD E. MACKENZIE Field Coordinator

FROM: IRVING WEISBLATT Acting Director, Federal Compliance and State Programs

SUBJECT: Use of Steel Banding as Guardrails

Normally steel bands are not acceptable as top rails or intermediate rails of a guardrail system because the edges of the bands constitute a potential hazard to hands and other portions of the body exposed to the bands. However, steel bands with sufficient strength to meet design criteria and with the edges protected are acceptable as rails.