- Standard Number:
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 https://www.osha.gov.
July 28, 1981
Mr. A. J. Weaver
Miller & Long Co., Inc.
4824 Rugby Avenue
Bethesda, Maryland 20014
Dear Mr. Weaver:
This is in response to your letter of July 15, 1981, concerning perimeter protection at building slab edges. Your letter addressed to Mr. James Concannon was forwarded to this office for response.
Normally steel bands are not acceptable as top rails or intermediate rails of a guardrail system because the edges of the band constitute a potential hazard to hands and other portions of the body exposed to the bands. However, steel bands well flagged for easy identification with sufficient strength to meet design criteria in 29 CFR 1926.500(f)(1)(vi)(a)(b)(c) and (d) and with the edges protected could be used as guardrails. In addition, your system will be maintained by regularly inspecting the metal banding and replacing any that exhibit rust, corrosion, or deflects more than three inches when two hundred pounds pressure or less is applied to it.
Your request for a variance for the above method of perimeter protection is unnecessary because your guardrail system, as described, using steel banding would comply with the 29 CFR 1926.500(f)(1)(vi).
If I may be of further assistance, please feel free to call or write.
John K. Barto Chief,
Division of Occupational Safety Programming