- Standard Number:1926.500(f)(1)(vi)
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.
December 11, 1979
Joe A. Adam, Director
Department of Safety and Health
United Association of Journeyman and Apprentices
of the Plumbing and Pipe Fitting Industry
United Association Building
901 Massachusetts Avenue, N.W.
Washington, D.C. 20001
Dear Mr. Adam:
This is in response to your inquiry concerning the acceptability of steel bands for top rails and intermediate rails of a guardrail system.
29 CFR 1926.500(f)(1)(vi), for temporary or emergency conditions, states that other types, sizes, and arrangements of railing construction are acceptable, provided they meet the requirements contained in (a), (b), (c) and (d). The standard permits the use of any material meeting the above requirements.
The use of the word "normally" was included in the memorandum to clarify that the metal banding thickness usually requires the edges to be rolled, covered or otherwise shielded to protect employees that may make sudden contact with the edges.
In situations where the span between columns exceeds ten feet, it may be difficult to provide enough tension in a steel band to keep the level of deflection at a minimum while withstanding a two-hundred pound force.
On many construction projects when wire rope is used for the top and intermediate rails, employers are confronted with a similar difficulty in providing enough tension on the rope to minimize the deflection. The compliance officers making construction inspections are required to evaluate the wire rope and the metal banding systems during the course of an inspection. In this regard, plans are in progress to provide the field staff with force measurement equipment to evaluate such systems.
As indicated in your letter, Subpart R, 29 CFR 1926.750 allows the use of 1/2 inch wire rope or equal, to be installed around the periphery of temporary planked or metal decked floors during structural steel assembly. Steel bands providing equivalent strength could be used in lieu of the 1/2 wire rope, provided the metal banding edge is rolled, covered or otherwise protected.
I hope this information will be helpful to you in understanding our position in this matter. If I can be of any further assistance, please feel free to contact me.
Grove C. Wrenn Director
Federal Compliance and State Programs