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.

July 21, 2003

Mr. Jerry Breneman
16001 Park Ten Place
Houston, TX 77084

Re: In steel erection, may a guardrail system other than a safety cable be used to meet the requirement for a perimeter safety cable under Part 1926 Subpart R?

Dear Mr. Breneman:

This is in response to your E-correspondence of September 17, 2002, to the Occupational Safety and Health Administration (OSHA). We apologize for the delay in providing a response.

We have paraphrased your question as follows:

Question: The steel erection standard requires perimeter safety cables on multi-story structures. Is it permissible to use other types of guardrail systems (such as wooden guardrails) to meet this requirement?

Answer: Section 1926.760(a)(1) states:

Except as provided in paragraph (a)(3) of this section, each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6m) above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems or fall restraint systems.

Section 1926.760(a)(2) further requires that:

On multi-story structures, perimeter safety cables shall be installed at the final interior and exterior perimeters of the floors as soon as the metal decking has been installed.

 

 

Section 1926.760(a)(2) was promulgated in conjunction with the requirement that perimeter columns have holes or attachments to facilitate the speedy erection of an effective and durable fall protection system. In the preamble to the Final Rule, OSHA explained that the Steel Erection Negotiated Rulemaking Advisory Committee (SENRAC) believed that the relative ease with which safety cables can be erected, especially where columns have pre-installed holes or attachments, presents several safety advantages (66 FR 5228-5229 and 5245, Jan. 18, 2001). Specifically, this system:

 

 

  1. Minimizes the exposure of the workers during its erection;
  2. Can be erected as soon as the steel decking has been installed;
  3. Can be engineered to comply with Subpart M; and
  4. Does not create a greater hazard during initial steel erection connection activities.
     

 

 

The use of other types of guardrail systems, such as wooden guardrails, will be considered to meet this requirement where all of the following conditions are met:

 

 

  1. the workers installing the system are protected with personal fall arrest equipment or other forms of conventional fall protection;
  2. the system meets the guardrail requirements of §1926.502;
  3. it is durable with respect to exposure to the conditions at the site (such as weather and steel erection activities near to or that may affect the guardrails); and
  4. it does not create a greater hazard during initial steel erection connection activities.
     

 

 

If you would like additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Compliance Assistance, 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.

Sincerely,


Russell B. Swanson, Director
Directorate of Construction