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.
February 25, 1994
MEMORANDUM FOR: JOHN B. MILES, JR. REGIONAL ADMINISTRATOR THROUGH: H. BERRIEN ZETTLER, DEPUTY DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS FROM: ROY F. GURNHAM, DIRECTOR OFFICE OF CONSTRUCTION AND MARITIME COMPLIANCE ASSISTANCE SUBJECT: Capping of Rebar to Prevent Impalement (OSHA 2202)
This is in response to your memorandum concerning the statement in the Construction Industry Digest (OSHA publication 2202) addressing the use of plastic caps on protruding reinforcing steel to eliminate the hazard of impalement.
The little plastic caps refered to in the Construction Industry Digest as not preventing impalement are the type used to cap pipe or conduit and not the larger mushroom type caps commonly accepted by OSHA as impalement protection. The small caps have never been recognized as appropriate impalement protection and this policy has not changed.
We agree that the admonition in the Digest is confusing and we will work to correct the statement in future publications. For your information, the California Occupational Safety and Health Standards Board recently published standards addressing reinforcing steel guarding (copy enclosed). Rebar guarded in accordance with Section 1712 of the California Code of Regulations should be deemed to be in compliance with 1926.701(b).
If you have any further questions please contact me or Dale Cavanaugh of my staff at (202) 219-8136.