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.

July 9, 1979


FROM:               Jerry L. Purswell

SUBJECT:            Interpretation of 1926.500(d)(1)--Use of Steel Band in

In response to your request, the conditions under which metal banding would suffice as material for constructing guardrails in compliance with 1926.500(d)(1) are as follows [Paragraph 1926.500(f)(vi)]:

(a) The metal banding must be smooth enough to prevent injury while performing its intended function. Therefore, the edges must be rolled with a sufficient radius to prevent injury, wrapped with a suitable material to protect the edge, or otherwise shielded.

(b) The band must meet the criterion of "minimum" deflection. This has been stated in an existing Program Directive as being no more than 3 inches over a span of 8 feet with a 200 pound load applied.

(c) The band must withstand a 200 pound static load in any direction.

Combining requirements (b) and (c), the Compliance Officer should reject any system, whether it be metal or wood rails, cables or metal bands, if it deflects more than 3 inches in a span of 8 feet with a 200 pound load applied in any direction.

I suspect that we have the metal banding problem now because we have not enforced the requirements adequately in the past when systems employing cables were introduced. I seriously doubt that any of the cable systems I have seen used around the District would meet the strength-deflection requirement.