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.

March 31, 1988

MEMORANDUM FOR: LINDA R. ANKU
  Regional Administrator
 
THRU: LEO CAREY, Director
  Office of Field Programs
 
FROM: THOMAS J. SHEPICH, Director
  Directorate of Compliance Programs
 
SUBJECT: Failure of Wire Rope and Banding Steel Guardrails to
  provide Protection as per 29 CFR 1926.500(f)(1)(iv)

The studies performed by your safety engineer indicate that 1/2-inch and 1/4-inch wire rope, which are commonly used in lieu of standard railings, will not provide protection equivalent to that provided by a standard railing that conforms to the requirements of 29 CFR 1926.500(f)(1)(iv) at specific spans. It is also stated that similar conclusions may be reached with the regard to the strength of steel banding. The subject standard is a performance standard which does not specify the span between posts. Employers may decrease the span between posts to comply with our defection requirements provided in STD 3-10.3. This practice may not be practical solution but employers have the option of placing the posts as close as necessary to comply with our deflection requirements or of being cited. In regard to metal banding the strength varies according to the width and thickness of the banding used by the employer for top and intermediate rails. When the subpart M final rule is promulgated in the Federal Register the prohibition will become enforceable and additional enforcement criteria will be included to support the prohibition of steel banding. Employers not in compliance with 29 CFR 1926.500(f)(1)(iv) shall be cited as indicated in this memorandum and previous correspondence covering this matter. If you have any questions concerning this matter, please contact Bill Simms on 523-8124.