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.

July 17, 2002

Mr. Barry A. Cole
Executive Vice President
Miller Safety Consulting, Inc.
5750 Pecos Street, Suite 6
Denver, CO 80221

Dear Mr. Cole:

By letter dated April 11, 2002, we responded to an inquiry that you sent us regarding perimeter guardrail requirements under the new steel erection standard. Since our letter, you have discussed this issue further with members of my staff. We have developed the question and answer below in order to address an aspect of your question that was not addressed in our April 11 letter.

Scenario: In a multi-story structure, prior to the installation of decking, an ironworker installs a perimeter cable to be used as a horizontal lifeline -- as an anchorage for personal fall protection equipment. The lifeline meets the criteria for a personal fall arrest anchorage. However, since it is a single cable, it does not meet the guardrail requirements under §§1926.760(d) and 1926.502. All ironworkers exposed to the perimeter edge will be protected with personal fall protection. In this scenario, is there a violation of the steel erection standard's perimeter guardrail requirements?

Answer: The key to the answer to this question lies in the fact that, in this scenario, the perimeter cable is erected before the decking on that floor has been installed. Under §1926.760(a)(2), in multi-story structures, a perimeter safety cable must be installed "as soon as the metal decking as been installed." Under §1926.760(d)(3) the required perimeter safety cable must meet the guardrail requirements in §1926.502. However, the standard does NOT require a perimeter guardrail to be installed prior to the installation of the decking. So, before the decking has been installed, a horizontal lifeline at the perimeter is not required to serve as a perimeter guardrail.

In this scenario no worker uses the lifeline as a guardrail -- all are protected by personal fall arrest equipment. Since there is no requirement that a perimeter guardrail be in place at that point and no employee uses the perimeter cable as a guardrail for fall protection, there is no violation of §1926.760(d)(3) prior to the installation of the decking.

Once the decking has been installed, the guardrail criteria is required to be met because at that point a perimeter guardrail meeting the criteria must be in place.

If you need additional information, please do not hesitate to 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