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.

August 26, 2003

Mr. Troy Russell
Safety Director
Superior Steel, Inc.
5225 North National Drive
Knoxville, Tennessee 37914

Dear Mr. Russell:

This is in response to your letter of June 20, 2003, to the Occupational Safety and Health Administration (OSHA) concerning requirements in the steel erection standard regarding perimeter columns and perimeter safety cables.

We have paraphrased your question below:

Question: Under §1926.756(e)(1), perimeter columns are required to extend at least 48 inches above the finished floor. Do the perimeter columns have to extend beyond the roof level when the building has topped out? Are perimeter safety cables required in this situation under §1926.760(a)(2)?

Answer: Section 1926.756(e) states:

Perimeter columns shall not be erected unless:
(1) The perimeter columns extend a minimum of 48 inches above the finished floor to permit installation of perimeter safety cables prior to the erection of the next tier, except where constructibility does not allow...

The standard requires perimeter columns to extend 48 inches above the finished floor "to permit installation of perimeter safety cables prior to erection of the next tier..." Since there is no "next tier" once the final tier has been erected, the language of the provision indicates that the requirement does not apply to the final tier's columns. Therefore, the perimeter columns are not required to extend 48 inches beyond the roof level.

Section 1926.760(a)(2) states:

Perimeter safety cables. 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. [Emphasis added.]



This provision applies to the perimeters of "floors," not roofs. Therefore, it does not require perimeter safety cables on the roof level. However, fall protection, whether accomplished by guardrails, nets, personal fall arrest systems, etc., is nonetheless required on the roof level at fall heights over 15 feet (with certain exceptions) pursuant to the requirements of §1926.760(a)(1).

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