Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

September 26, 1995



Administrator Seattle Regional Office
Directorate of Compliance Programs
Office of Construction and Maritime Compliance Assistance
SUBJECT: Fall Protection Standards


This is in response to a December 19, 1994 letter from former regional administrator James Lake, who transmitted correspondence from Van Howell, a compliance officer in the Boise area office. Mr. Howell has several suggestions and concerns about the new fall protection standards for construction.

We have noted his suggestions and concerns and thank him for them. In addition, we would like to address one issue raised by Mr. Howell. Mr. Howell felt that employees working on reinforcing steel should be required to be tied off when moving point to point, since reinforced steel structures do not require uniform spacing, allow employees to move horizontally rather than vertically as ladders do, and can expose employees to falls of fifty feet or more. Mr. Howell enclosed an accident report concerning a fatality which occurred when an employee fell approximately thirty feet from a concrete form while climbing down the formwork.

We have limited our interpretation to allow moving point to point without fall protection to rebar assemblies that are built in place and only up to twenty-four feet above the lower level. We agree that employees do not normally move horizontally on fixed ladders, but we do not currently have sufficient accident data on falls from rebar to support applying more rigid standards to this situation. Our interpretation does not apply to formwork. On formwork, employees must be protected from falls at all times where the fall distance is six feet or more, including when movement is from point to point.

Policy discussions are currently ongoing on whether to allow employees to move point to point without fall protection up to twenty-four feet above the lower level on prefabricated rebar cages. No decision on this issue has been reached yet.

If you have any questions, please call me or Dale Cavanaugh of my staff at (202)219-8136.