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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.
November 3, 2003
Mr. David Thelen
1325 Western Avenue
Baltimore, MD 21230
Re: Does the "Super Brace," manufactured by Fiber-Lam, meet OSHA construction fall protection requirements for dimensions and strength for guarding openings in the frames and walls of a structure during its construction?
Dear Mr. Thelen:
We are in receipt of your request of March 18, 2003, for guidance on certain Federal OSHA construction requirements applicable to the use of a product called "Super Brace," manufactured by Fiber-Lam, for fall protection. We apologize for the delay in providing a response.
We have paraphrased your question as follows:
Question: Does the "Super Brace," manufactured by Fiber-Lam, meet Federal OSHA construction fall protection requirements for the dimensions and strength of guardrails for guarding openings in the frames and walls of a structure during its construction?
OSHA is generally precluded from approving or endorsing specific products. The variable working conditions at job sites and possible alteration or misapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the equipment manufacturer. However, where appropriate, we try to give some guidance to help employers assess whether products are appropriate to use in light of OSHA requirements.
You submitted information and testing data on the Super Brace fall protection system, which you state you would like to use as fall protection for rough openings in exterior walls during construction. Your description of the product is paraphrased as follows:
Super Brace is structural sheathing that is 1/8" thick and commonly used to sheath the entire exterior of a house prior to applying the finished siding. For rough exterior wall openings up to 75" wide, you intend to apply the Super Brace from the bottom of the wall panel to 48" above the bottom of rough exterior wall openings (before the wall is erected). The Super Brace will be stapled every 3" on center to the left and right sides of the rough opening framing. The rest of the wall panel will be sheathed as usual with additional Super Brace material and will overlap the previously stapled sheathing along the rough wall opening's edges. At widths greater than 75" wide, a vertical stud will be installed as an additional structural member to reduce the rough opening's size by 50%. Afterwards, the reduced rough openings will be sheathed as previously described.
OSHA defines an opening as a gap or void 30" (76 cm) or more high and 18" (48 cm) or more wide in a wall or partition, through which employees can fall to a lower level. The openings you describe would require guarding in light of this definition.
Section 1926.501(b)(14) states:
Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking working surface, shall be protected from falling by the use of a guardrail system, a safety net system, or a personal fall arrest system.
Section 1926.502(b)(3) states:
Guardrail systems 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) sets out maximum deflection criteria.
Assuming the reliability of the test data you cited,1 it appears to indicate that 75-inch spans of Super Brace meet or exceed the 200-pound minimum strength capacity and deflection limits required for guardrails in §1926.502(b)(3) and (4) under the test conditions you describe.
With respect to the height requirement, §1926.502(b)(1) requires the top rail of a guardrail system to be:
42 inches, plus or minus 3 inches above the walking/working level. When conditions warrant, the height of the top edge may exceed the 45 inch height, provided the guardrail system meets all other criteria of this paragraph. [Emphasis added.]
As described, the Super Brace extends 48 inches above the walking/working surface. Since this system provides a solid barrier from the floor up to the top of the system, (eliminating gaps such as exist when using toprails and midrails), "conditions warrant" a top height exceeding 45 inches. It therefore meets the requirements of §1926.502(b)(1).
If you need any further clarification on this subject, 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
1 We did not receive the original report of the independent testing lab, PFS Corporation, or documentation indicating that the test results were signed by a registered professional engineer. [ back to text ]