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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.
August 28, 2000
Mr. Mark Troxell
Construction Team Leader
The PMA Insurance Group
107 Ponderosa Drive
Blandon, PA 19510
Re: 1926.501(b)(3) and 1926.502(b)
Dear Mr. Troxell:
This responds to your June 1, 1999, letter to the Occupational Safety and Health Administration (OSHA), requesting information on wire rope and Crosby clips used around the perimeter of buildings as a guardrail. You also requested clarification on when employees must tie-off when a guardrail system is removed to facilitate hoisting operations. We apologize for the long delay in providing this response.
Question 1: How many Crosby clips are required to be used when setting up a wire rope guardrail? Is it permissible to splice two wire ropes by overlapping or must the connections be turned back into eyelets and properly secured?
Answer: For construction work covered by 29 CFR 1926 Subpart M, §1926.502(b) sets forth the criteria that must be met when using wire rope as a guardrail. The standard requires guardrails to meet several specific criteria. For example, 1926.502(b)(3) states that the guardrail shall be capable of withstanding, without failure, a force of at least 200 pounds applied within 2 inches of the top edge, in any outward or downward direction, at any point along the top edge. Section 1926.502(b)(4) states that when the 200 pound test load noted in §1926.502(b)(3) is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches above the walking/working level. Section 1926.502(b)(9) states that the top rail and mid-rails shall be at least ¼-inch nominal diameter or thickness to prevent cuts and lacerations. These and other criteria must be met when using wire rope as a guardrail around the perimeter of a building.
The OSHA standard does not specify a minimum number of clips when using wire rope as a guardrail. However, as a practical matter, it is unlikely you could meet the specific requirements under §1926.502(b) unless you follow the manufacturer's recommendations for the number of clips to be used on wire ropes of different diameters (for example, the Crosby Group Inc. general catalog, 2000 edition has tables showing their recommendations for their clips). Also, note that OSHA's standard for rigging equipment used for material handling, 29 CFR §1926.251, has a table for the number of clips required for wire rope ½-inch and greater. Although that standard does not apply to wire rope used for guardrails, when you design a rope system to meet the §1926.502 requirements, following those tables will normally ensure that you have enough clips.
Question 2: What are the requirements for tying-off employees when a guardrail system is removed to facilitate hoisting operations? 29 CFR §1926.501(b)(3) states that, when guardrails are removed to facilitate hoisting operations, employees who have to lean out over the edge must be tied off. What about other employees, who do not have to lean out—do they have to be tied-off also?
Answer: Section 1926.501(b)(3) states that each employee in a hoist area shall be protected from falls of 6 feet or more by guardrail systems or personal fall arrest systems. It also states that, "If guardrail systems ... are removed to facilitate the hoisting operation (e.g., during landing of materials), and an employee must lean through the access opening or out over the edge of the access opening (to receive or guide equipment and materials, for example), that employee shall be protected from fall hazards by a personal fall arrest system." (59 FR 40710).
You ask if this means that the only employees who must use fall protection when the guardrails are removed are those who must lean out. The answer is no; the first sentence of §1926.501(d)(3) requires that all employees in the hoist area be protected by either a guardrail or personal fall arrest system. So, when all or part of a guardrail has been removed, all employees must be protected by a personal fall arrest system.
The last sentence of §1926.501(d)(3), which states that employees who must lean out must be protected with personal fall arrest equipment, did not create an exception for employees with no need to lean out. The requirement that these employees also be protected is reflected in §1926.502(d)(24). It specifically provides that fall arrest systems in hoist areas be rigged to prevent employees from leaning past the edge: "when a personal fall arrest system is used at hoist areas, it shall be rigged to allow the movement of the employee only as far as the edge of the walking/working surface." The Agency explained in the preamble to subpart M that this provision was promulgated to eliminate the tendency for employees to lean out over the edge at hoist areas (see volume 59, No.152 of the Federal Register, page 40,685, August 9, 1994). Although inartfully drafted, the purpose of the last sentence of §1926.501(b)(3) is to require that personal fall arrest equipment be used even when the necessity of leaning out makes compliance with §1926.502(d)(24) infeasible.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction