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.

March 18, 1993

Mr. Marvin J. Ford II
Special Programs Manager
Industrial Enterprises, Inc.
P.O. Box 5593
Pocatello, Idaho 83202

Dear Mr. Ford:

This is in response to your January 25 letter requesting an interpretation of the Occupational Safety and Health Administration standard that addresses guarding against the hazard of impalement by protruding reinforcing steel (29 CFR 1926.701(b)).

With regard to the distance reinforcing steel can protrude before guarding is required, please be advised that rebar of any length must be guarded when there is the hazard that an employee could fall onto the bar and be impaled (skin pierced).

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


Roy F. Gurnham, Esq., P.E.
Office of Construction and Maritime
Compliance Assistance

January 25, 1993

U. S. Department of Labor
Directorate of Compliance Programs
Washington, D. C. 20210

Subject: Letter of Interpretation for 29 CFR 1920.701(b), request for

In Subpart Q, Concrete and Masonry Construction, of 29 CFR 1926.701, reinforcing steel (b), states that "All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement."

The basic inquiry is how high must the reinforcing steel be protruding before the necessity for protective devices is mandatory. Realizing that common sense must prevail, and that the safety and well being of the employee is of paramount concern.

Industrial Enterprises, Inc., is a safety management services organization which instructs the construction safety course and provides safety consulting to local firms. This question has arisen during the course discussions. Employers and employees alike are receptive to the information and wish to comply, however it is felt that as written, this is vague.

Your assistance is sincerely appreciated.


Marvin J. Ford II
Special Programs Manager