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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

Mr. Victor Walther, Jr.
Concrete Reinforcing Steel Institute
933 N. Plum Grove Road
Schaumburg, Illinois 60173-4758

Dear Mr. Walther, Jr.:

This is in response to your letter of December 14, 1994 to the Occupational Safety and Health Administration (OSHA) in which you asked us to clarify or modify 29 CFR 1926.501(b)(5), which states, "Each employee on the face of formwork or reinforcing steel shall be protected from falling 6 feet or more to lower levels by personal fall arrest systems, safety net systems, or positioning device systems." In addition, you requested that OSHA allow ironworkers to climb or move horizontally on wall and column assemblies without being tied off.

Paragraph .501(b)(5) applies only to formwork and reinforcing steel used in concrete structures. It does not apply to steel erection activities. Recently, the paragraph has been interpreted by OSHA to mean that on rebar assemblies (not formwork) that are built in place for concrete structures, employees of any trade can climb and move about up to the height of twenty-four (24) feet without being tied off. On formwork, however, employees must be protected at all times where the fall distance is six (6) feet or more, including when employees are moving from point to point.

Ironworkers involved in steel erection activities must be protected from falls in accordance with the enclosed July 10, 1995 memorandum.

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


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