February 25, 1994
MEMORANDUM FOR: JOHN B. MILES, JR.
THROUGH: H. BERRIEN ZETTLER, DEPUTY DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
FROM: ROY F. GURNHAM, DIRECTOR
OFFICE OF CONSTRUCTION AND
MARITIME COMPLIANCE ASSISTANCE
SUBJECT: Capping of Rebar to Prevent Impalement (OSHA 2202)
This is in response to your memorandum concerning the statement in the
Construction Industry Digest (OSHA publication 2202) addressing the use of
plastic caps on protruding reinforcing steel to eliminate the hazard of
The little plastic caps refered to in the Construction Industry Digest as
not preventing impalement are the type used to cap pipe or conduit and not
the larger mushroom type caps commonly accepted by OSHA as impalement
protection. The small caps have never been recognized as appropriate
impalement protection and this policy has not changed.
We agree that the admonition in the Digest is confusing and we will work to
correct the statement in future publications. For your information, the
California Occupational Safety and Health Standards Board recently published
standards addressing reinforcing steel guarding (copy enclosed). Rebar
guarded in accordance with Section 1712 of the California Code of Regulations
should be deemed to be in compliance with 1926.701(b).
If you have any further questions please contact me or Dale Cavanaugh of my
staff at (202) 219-8136.