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 23, 1994

Mr. Rich Krohn
Corporate Safety Director
P.O. Box 710
Minneapolis, Minnesota 55440-0710

Dear Mr. Krohn:

Your June 4 letter to Mr. Gerald Cunningham, Area Director, Milwaukee Area Office, requesting an interpretation of 29 CFR 1926.701(b) has been forwarded to the Office of Construction and Maritime Compliance Assistance for a response. We apologize for the delay in responding to your inquiry.

With regard to the applicability of the above mentioned standard to large diameter (1 inch and greater) reinforcing steel which protrude vertically 24 - 72 inches from the concrete floor under construction, please be advised that reinforcing steel of any diameter and any length must be guarded when there is the hazard that an employee could fall onto the rebar and be impaled (skin pierced).

Accordingly, the intent of the standard is to provide employee protection by guarding all protruding reinforcing steel which creates an impalement hazard.

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, P.E., J.D.
Director Office of Construction and
Maritime Compliance Assistance