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2023-05-21 21:22:12

This responds to your June 1, 1999, letter to the Occupational Safety and Health Administration (OSHA), requesting information on wire rope and Crosby clips used around the perimeter of buildings as a guardrail. You also requested clarification on when employees must tie-off when a guardrail system is removed to facilitate hoisting operations. We apologize for the long delay in providing this response.

Question 1: How many Crosby clips are required to be used when setting up a wire rope guardrail? Is it permissible to splice two wire ropes by overlapping or must the connections be turned back into eyelets and properly secured?

Answer: For construction work covered by 29 CFR 1926 Subpart M, §1926.502(b) sets forth the criteria that must be met when using wire rope as a guardrail. The standard requires guardrails to meet several specific criteria. For example, 1926.502(b)(3) states that the guardrail 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) states that when the 200 pound test load noted in §1926.502(b)(3) is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches above the walking/working level. Section 1926.502(b)(9) states that the top rail and mid-rails shall be at least ¼-inch nominal diameter or thickness to prevent cuts and lacerations. These and other criteria must be met when using wire rope as a guardrail around the perimeter of a building.

The OSHA standard does not specify a minimum number of clips when using wire rope as a guardrail. However, as a practical matter, it is unlikely you could meet the specific requirements under §1926.502(b) unless you follow the manufacturer"s recommendations for the number of clips to be used on wire ropes of different diameters (for example, the Crosby Group Inc. general catalog, 2000 edition has tables showing their recommendations for their clips). Also, note that OSHA"s standard for rigging equipment used for material handling, 29 CFR §1926.251, has a table for the number of clips required for wire rope ½-inch and greater. Although that standard does not apply to wire rope used for guardrails, when you design a rope system to meet the §1926.502 requirements, following those tables will normally ensure that you have enough clips.

Question 2: What are the requirements for tying-off employees when a guardrail system is removed to facilitate hoisting operations? 29 CFR §1926.501(b)(3) states that, when guardrails are removed to facilitate hoisting operations, employees who have to lean out over the edge must be tied off. What about other employees, who do not have to lean out—do they have to be tied-off also?

Answer: Section 1926.501(b)(3) states that each employee in a hoist area shall be protected from falls of 6 feet or more by guardrail systems or personal fall arrest systems. It also states that, "If guardrail systems ... are removed to facilitate the hoisting operation (e.g., during landing of materials), and an employee must lean through the access opening or out over the edge of the access opening (to receive or guide equipment and materials, for example), that employee shall be protected from fall hazards by a personal fall arrest system." (59 FR 40710).

You ask if this means that the only employees who must use fall protection when the guardrails are removed are those who must lean out. The answer is no; the first sentence of §1926.501(d)(3) requires that all employees in the hoist area be protected by either a guardrail or personal fall arrest system. So, when all or part of a guardrail has been removed, all employees must be protected by a personal fall arrest system.

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.

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Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) 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 (§ 1926.502(b)).

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural members shall be installed between the top edge of the guardrail system and the walking/working surface when there is no wall or parapet wall at least 21 inches (53 cm) high.

Other structural members (such as additional midrails and architectural panels) shall be installed such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge.

When the 200 pound (890 N) test load specified in paragraph (b)(3) of this section (§ 1926.502) is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the walking/working level. Guardrail system components selected and constructed in accordance with the appendix B to subpart M of this part will be deemed to meet this requirement.

Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-foot intervals with high-visibility material.

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall be placed across the access opening between guardrail sections when hoisting operations are not taking place.

When guardrail systems are used around holes used for the passage of materials, the hole shall have not more than two sides provided with removable guardrail sections to allow the passage of materials. When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall be provided along all unprotected sides or edges.

When guardrail systems are used around holes which are used as points of access (such as ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into the hole.

Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this section (§ 1926.502).

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor be longer than 6 inches (15 cm) on any side, and the opening, measured center-to-center of mesh ropes or webbing, shall not be longer than 6 inches (15 cm). All mesh crossings shall be secured to prevent enlargement of the mesh opening.

During the construction of elevator shafts, two employees may be attached to the same lifeline in the hoistway, provided both employees are working atop a false car that is equipped with guardrails; the strength of the lifeline is 10,000 pounds [5,000 pounds per employee attached] (44.4 kN); and all other criteria specified in this paragraph for lifelines have been met.

Note: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to subpart M, and if the system is being used by an employee having a combined person and tool weight of less than 310 pounds (140 kg), the system will be considered to be in compliance with the provisions of paragraph (d)(16) of this section [§ 1926.502]. If the system is used by an employee having a combined tool and body weight of 310 pounds (140 kg) or more, then the employer must appropriately modify the criteria and protocols of the Appendix to provide proper protection for such heavier weights, or the system will not be deemed to be in compliance with the requirements of paragraph (d)(16) of this section (§ 1926.502).

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists except as specified in other subparts of this Part.

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This is in response to the questions posed in the letter from Jay Withrow regarding safety railing(s) required by OSHA Standard 29 CFR 1926.750(b)(1)(iii). The standard reads as follows:

"Floor periphery - safety railing. A safety railing of ½-inch wire rope or equal shall be installed, approximately 42 inches high, around the periphery of all temporary - planked or temporary metal-decked floors of tier buildings and other multifloored structures during structural steel assembly." (emphasis added).

Question 1: Is orange plastic-coated 3/16-inch aircraft wire "equal" to ½-inch wire rope? (Note: This product is seeing extensive use in Northern Virginia).

Answer: The response is a qualified yes. The key to whether the 3/16 aircraft wire is equal to ½-inch wire rope is whether a the 3/16 aircraft wire is equal in strength to ½-inch wire rope.

The standard does not set forth any specifications for the design and construction of the ½-inch wire rope. Thus any wire rope ½-inch in diameter of any design or construction could be used to comply with this standard.

There is at least one 3/16-inch aircraft cable (Galvanized and tinned aircraft cord and strand Construction 1x19 - Nominal Breaking Strength 4700 pounds) that has a greater nominal breaking strength than does at least one type of ½-inch wire rope (Iron Galvanized Running Rope - Construction 6x12 - Nominal Breaking Strength 4560 pounds). Therefore, the previously referenced aircraft cable would have to be considered equal to ½-inch wire rope.

Question 3: Although it is not stated anywhere, must the wire rope used to comply with 1926.750(b)(1)(iii) (½-inch wire rope; or 3/16-inch aircraft wire if you find that to be equivalent) have a maximum permissible deflection of 3-inches in one direction when a load of 200 pounds is applied in any direction at any point?

Answer: The response to this question is a qualified yes. OSHA Standard 29 CFR 1926.750(b)(1)(iii) does not address the issue of deflection. The standard, as written, could be enforced so that no deflection is permitted. However that would be contrary to guidance relating to wire rope used for guardrails contained in directives (STD 3-10.3), memoranda and proposed standards (Fall Protection In Construction.)

Therefore in Region III, for the purpose of complying with OSHA Standard 29 CFR 1926.750(b)(1)(iii), a safety railing that meets the following criteria would be considered to be equal to a ½-inch wire rope:

[Correction 6/20/2005. See OSHA Directive CPL 02-01-034 "Inspection policy and procedures for OSHA"s steel erection standards for construction" published on 3/22/2002 for the current policy on OSHA"s steel erection standards (1926 Subpart R) for construction.]

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Other structural members (such as additional midrails and architectural panels) shall be installed such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

When the 200 pound (890 N) test load specified in paragraph (b)(3) of this section is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the walking/working level. Guardrail system components selected and constructed in accordance with the Appendix B to subpart M of this part will be deemed to meet this requirement.

Note: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to subpart M, and if the system is being used by an employee having a combined person and tool weight of less than 310 pounds (140 kg), the system will be considered to be in compliance with the provisions of paragraph (d)(16) of this section. If the system is used by an employee having a combined tool and body weight of 310 pounds (140 kg) or more, then the employer must appropriately modify the criteria and protocols of the Appendix to provide proper protection for such heavier weights, or the system will not be deemed to be in compliance with the requirements of paragraph (d)(16) of this section.

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists except as specified in other subparts of this Part.

When the path to a point of access is not in use, a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line, shall be placed across the path at the point where the path intersects the warning line erected around the work area, or the path shall be offset such that a person cannot walk directly into the work area.

The rope, wire, or chain shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches (.9 m) from the walking/working surface and its highest point is no more than 39 inches (1.0 m) from the walking/working surface;

After being erected, with the rope, wire, or chain attached, stanchions shall be capable of resisting, without tipping over, a force of at least 16 pounds (71 N) applied horizontally against the stanchion, 30 inches (.8 m) above the walking/working surface, perpendicular to the warning line, and in the direction of the floor, roof, or platform edge;

The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and after being attached to the stanchions, shall be capable of supporting, without breaking, the loads applied to the stanchions as prescribed in paragraph (f)(2)(iii) of this section; and

Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system.

On floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, controlled access zones shall be enlarged, as necessary, to enclose all points of access, material handling areas, and storage areas.

On floors and roofs where guardrail systems are in place, but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day"s work shall be removed.

Where tools, equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall be erected from the walking/working surface or toeboard to the top of a guardrail system"s top rail or midrail, for a distance sufficient to protect employees below.

The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.

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The May 22, 1984, clarification of 29 CFR 1926.750(b)(1)(iii) provides our most current position on the use of synthetic or fiber ropes as a safety railing. Our past experience with synthetic or fiber rope used as a guardrail system disclosed that the sag between the vertical supports was excessive and did not provide adequate employee protection against falls. However, we have forwarded a copy of your letter to OSHA"s [Directorate of Standards and Guidance] for their consideration when the applicable subparts are revised.

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Your February 23 letter requesting an interpretation of an Occupational Safety and Health Administration (OSHA) standard addressing the materials used for constructing guardrails has been forwarded to the Office of Construction and Maritime Compliance Assistance for response. I apologize for the delay in responding to your inquiry.

OSHA"s standards do not prohibit the use of wire rope or metal dry wall studs for the construction of guardrails at construction sites. If guardrails made with these materials meet the required criteria such as strength, deflection and smooth surface, OSHA will accept them.

We share your concern, however, that guardrails made of these materials are difficult to maintain or replace in effective condition. Let me assure your that OSHA is focusing its attention on fall hazards and will issue citations for ineffective guardrails to all responsible employers according to our multi-employer worksite citation policy. I have enclosed a copy of OSHA"s multi-employer worksite policy for your reference.

NEII is concerned with the safety of all persons on a job site as our own employees. There is an escalating problem in the protection of floor and wall openings by the use of wire rope barricades and the use of metal dry wall studs for barricade material.

This problem is seen on a nationwide basis and when NEII members as a subcontractor make an object to the use of these material for barricades on elevator hoistways, we get the standard answer that they are approved by OSHA. In reviewing the variances and the interpretations issued by OSHA, we have not been able to find any that address this condition.

The use of wire rope for barricades is in our opinion a hazard as once they have been removed to gain access to an area, they are never pulled taut again and thereby become a tripping hazard. These wire rope barricades usually have a span over 8 feet and they do not normally have a toeboard on them. Wire rope in our opinion is not smooth which is one requirement of the OSHA regulations. I can understand the use of wire rope for perimeter protection on buildings because, no one has to enter thru them and they are usually left as installed.

The other area in which there has been an increasing problem is the use of lightweight metal dry wall studs for barricades. These studs may be rigid when they are first put up but, if there is the slightest bend or crease in them, they quickly lose that rigidity. They do not by any means meet the deflection requirements of the standard and although they are smooth on the top, they have very sharp edges which could inflict a serious laceration to personnel who would handle them to remove or replace them. Once again, when a complaint is registered with the controlling contractor, we are told that they are OSHA approved.

NEII would like a formal interpretation as to whether or not these two materials are acceptable to OSHA for barricading of floor and wall openings, especially in view of the fact that they must be removed and replaced in order to work inside the barricaded area. Your help in this matter would certainly be appreciated.

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The standard requires guardrail systems and components to be designed and built to meet the requirements of 1926.502(b)(3), (4), and (5). This Appendix serves as a non-mandatory guideline to assist employers in complying with these requirements. An employer may use these guidelines as a starting point for designing guardrail systems. However, the guidelines do not provide all the information necessary to build a complete system, and the employer is still responsible for designing and assembling these components in such a way that the completed system will meet the requirements of 1926.502(b)(3), (4), and (5). Components for which no specific guidelines are given in this Appendix (e.g., joints, base connections, components made with other materials, and components with other dimensions) must also be designed and constructed in such a way that the completed system meets the requirements of 1926.502.

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The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface. The top edge height may exceed 45 inches (114 cm), provided the guardrail system meets all other criteria of paragraph (b) of this section (see Figure D-11 of this section).

Midrails, screens, mesh, intermediate vertical members, solid panels, or equivalent intermediate members are installed between the walking-working surface and the top edge of the guardrail system as follows when there is not a wall or parapet that is at least 21 inches (53 cm) high:

Guardrail systems are capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail.

When the 200-pound (890-N) test load is applied in a downward direction, the top rail of the guardrail system must not deflect to a height of less than 39 inches (99 cm) above the walking-working surface.

Guardrail systems are smooth-surfaced to protect employees from injury, such as punctures or lacerations, and to prevent catching or snagging of clothing.

When guardrail systems are used at hoist areas, a removable guardrail section, consisting of a top rail and midrail, are placed across the access opening between guardrail sections when employees are not performing hoisting operations. The employer may use chains or gates instead of a removable guardrail section at hoist areas if the employer demonstrates the chains or gates provide a level of safety equivalent to guardrails.

When materials are not being passed through the hole, the hole must be guarded by a guardrail system along all unprotected sides or edges or closed over with a cover.

Manila or synthetic rope used for top rails or midrails are inspected as necessary to ensure that the rope continues to meet the strength requirements in paragraphs (b)(3) and (5) of this section.

The perimeter of the designated area is delineated with a warning line consisting of a rope, wire, tape, or chain that meets the requirements of paragraphs (d)(2) and (3) of this section.

Where tools, equipment, or materials are piled higher than the top of the toeboard, paneling or screening is installed from the toeboard to the midrail of the guardrail system and for a length that is sufficient to protect employees below. If the items are piled higher than the midrail, the employer also must install paneling or screening to the top rail and for a length that is sufficient to protect employees below; and

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This chapter provides technical information about fall hazards and protection methods. The information is intended to help prepare OSHA compliance officers to conduct inspections and investigations. For convenience, links are provided to applicable OSHA standards throughout this chapter. This chapter does not cover all OSHA requirements for fall prevention/protection methods, and is not intended to serve as a comprehensive guide for developing compliant fall protection programs.

OSHA-approved state occupational safety and health plans may have different standards, but those standards must be at least as effective as federal OSHA requirements. More information about state plans is available on the OSHA website.

A guardrail system can be used as a barrier installed to prevent workers from falling off a work surface edge to a lower level. Guardrail systems can be used on many work surfaces, including rooftops, platforms, mezzanines, balconies, scaffolds, incomplete decked floors, catwalks, observation platforms, mobile work surfaces and ladderway points of access. Figure 1 shows a temporary guardrail system for a walkway (see 29 CFR 1926.500; 29 CFR 1926.502(b)).

Guardrails can also be used to keep workers from falling into holes or openings in decking or floors (see 29 CFR 1926.501(b)(4)(i); 29 CFR 1926.502(b); Figure 2).

A midrail, mesh, screen, or equivalent intermediate structural members installed between the guardrail system top edge and the walking/working surface when there is no wall or parapet wall at least 21 inches high (see 29 CFR 1926.502(b)(2)).

Guardrails that deflect to lower than 39 inches above the working surface when 200 pounds of pressure are applied in a downward direction (see 29 CFR 1926.502(b)(4)).

Basic guardrail components come in a variety of materials and configuration options. It is common for employers to use material available or produced at the worksite. Upright supports may be made from wood, formed metal, pipe, or composites. Wire rope is sometimes used for the top rails and midrails.

Table 1 provides guidelines as a starting point for designing guardrail systems. However, the guidelines do not provide all the information necessary to build a complete system. The components of a guardrail system must still be designed and assembled in such a way that the completed system meets all applicable requirements.

Workers installing or removing guardrails must be protected using other forms of fall protection whenever the guardrail systems are not attached securely to a stable structure.

Premade or job-made guardrails can be used as temporary guardrails while more permanent structures are being installed or when the work is transient or in a space not intended as a permanent work area. For example, temporary guardrails can be used while constructing a wall, completing floor decking, or replacing a roof (see Figure 4). These guardrails are often constructed from reusable materials or premade guardrail system components as shown in Figure 4 (see 29 CFR 1926.502(b)).

Premade guardrails are particularly susceptible to damage if not handled properly when disassembled and stored. Specific handling instructions are typically included in the manufacturer’s recommended procedures for disassembling and storing the guardrail components. If railing components are bent, broken, or missing, the guardrail may not be effective. Damage is more likely to occur if the components are dropped when disassembled, transported in vehicles, or stored in areas not protected from conditions that could cause corrosion or distortion.

Scaffolds, aerial lifts, and scissor lifts can pose similar fall hazards. Guardrails, possibly in combination with additional types of fall protection systems (e.g., PFAS or restraint system), may be used to address these hazards (see 29 CFR 1926.451(g)(1); 29 CFR 1926.453(b)(2)(v); 29 CFR 1926.954(b)(3)(iii)(A)).

Effective handrails are 30 to 37 inches high and meet the guardrail strength requirements (i.e., able to withstand 200 pounds of weight applied within two inches of the top edge in any downward or outward direction at any point along the top edge) (see 29 CFR 1926.1052(c)(5), (c)(6)).

Workers are protected from the hazards associated with holes by the use of covers, personal fall protection or guardrail systems (see 29 CFR 1926.501(b)(4)(i)).

Covers for permanent holes are typically built for a specific purpose (e.g., permanent access points, manhole covers, and trap doors) and are only effective when they are properly designed and secured in place.

A warning line system is a barrier erected on a flat or low- sloped roof to warn workers that they are approaching an unprotected roof side or edge (see 29 CFR 1926.500(b); 29 CFR 1926.501(b)(10); Figure 11). A warning line system includes a line (rope, wire, or chain) and supporting stanchions (see 29 CFR 1926.502(f)(2)).

Fall restraint systems prevent the user from falling any distance. To determine the force needed to restrain a worker, consideration is given to the force that would be generated by the worker walking, leaning, or sliding down the working surface. OSHA has no specific standards for restraint systems, however, at a minimum, fall restraint systems should have the capacity to withstand at least 3,000 pounds of force or twice the maximum expected force that is needed to restrain the worker from exposure to the fall hazard.

PFAS components will be marked by the manufacturer with pertinent information specific to the equipment, such as warnings, serial/model number, capacity, and the materials used to make the component (see Figure 14). Information (e.g., proper use, maintenance, inspection) about fall protection components is typically provided in equipment manuals.

Many factors can contribute to a workers’ risk of falling from an elevated work area. Examples include precarious work positions, excessive leaning or reaching, improper work practices, unstable structures, trip hazards, slippery surfaces, and distractions.

When guardrails are not an option, personal fall protection equipment is helpful in some situations, but only when properly selected, worn, and attached to an adequate anchor point.

A lanyard is a flexible rope, wire rope, or strap which generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage point (see 29 CFR 1926.500(b)). Some manufacturers offer adjustable length lanyards. Effective lanyards are maintained in a clean, intact condition, and inspected prior to each use for wear, tear, and any obvious distortion or signs that the fall arrest (energy-absorbing) system has been activated (see 29 CFR 1926.502(d)(21)).

Lifelines function as an extension of an anchorage system, allowing an employee to move up and down (vertical lifeline) or back and forth (horizontal lifeline) across a work area. A sliding fitting (rope grab or shuttle) connects to the line and a lanyard connects the worker’s harness to that sliding fitting.

Even when a PFAS works properly, the fallen worker is still in danger. The worker"s body weight places pressure on the harness straps, which can compress the veins, and cause blood to pool, in the lower extremities and reduce blood return to the worker"s heart (see Figure 17). This condition is called suspension trauma, also known as harness hang syndrome. In medical terms, this results in orthostatic intolerance. If the pressure is not reduced promptly, the worker can lose consciousness within minutes. (See Suspension Trauma/Orthostatic Intolerance, OSHA Safety and Health Information Bulletin.

With proper personal fall protection equipment, training and practice, a fallen worker can take steps to minimize suspension trauma. Self-rescue methods allow a fallen worker to temporarily relieve pressure on the legs or in some cases to even lower himself or herself to the lower level. Self-rescue methods are discussed in detail in Washington Industrial Safety & Health Division"s Fall Protection Responding to Emergencies.

This example demonstrates that, even with a relatively short lanyard (2 feet), a fall arrest system can require considerable clearance below the elevated work area. In this case the free fall distance is 3 feet (less than OSHA"s 6-foot maximum); however, the total fall distance is 14.5 feet (more than the typical space between levels in a building under construction). A falling concrete worker could come in contact with (and be injured by) any object within the space 14.5 feet below the worker"s original position.

Personal fall arrest system, guardrail system (with a minimum 200 pound top rail capacity), or ¾ inch (1.9 centimeter) thick grab line or equivalent handhold securely fastened beside each crawling board

Both a personal fall arrest system and a guardrail system with a minimum 200 pound top rail capacity (when the platform is supported by ropes); guardrail system only (when the platform is supported by the frame structure)

Rope lifeline attaches to an anchorage at the top and hangs vertically down through the work area. Movable rope grab attaches to the rope. Lanyard connects the rope grab to workers’ harness. To move up and down the work area, the worker can slide the rope grab up and down the lifeline, then relock it in place. If the worker falls, the rope grab locks onto the rope to break the fall. This system’s effectiveness depends on how well the worker is trained to reposition the rope grab while moving about. The grab can slide off the end of the rope if the rope is too short, if a knot is not tied near the end of the rope, or if the grab is not installed properly.

The lifeline is wound on a reel and automatically extends or retracts to take up slack in the line as the worker moves about. A sudden extension in the line activates a locking mechanism that typically includes a deceleration device. Some self-retracting lanyards can be set to restrict the distance traveled and so can also function as part of a properly designed fall restraint system.

Thimbles provide a protective interface between the eye of a rope loop and a connector. They are used to prevent pinching or abrasion of the rope. The thimble needs to be firmly seated in the eye of the rope loop.

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Scope. This section applies to slings used in conjunction with other material handling equipment for the movement of material by hoisting, in employments covered by this part. The types of slings covered are those made from alloy steel chain, wire rope, metal mesh, natural or synthetic fiber rope (conventional three strand construction), and synthetic web (nylon, polyester, and polypropylene).

Employers must not use improved plow-steel wire rope and wire-rope slings with loads in excess of the rated capacities (i.e., working load limits) indicated on the sling by permanently affixed and legible identification markings prescribed by the manufacturer.

An eye splice made in any wire rope shall have not less than three full tucks. However, this requirement shall not operate to preclude the use of another form of splice or connection which can be shown to be as efficient and which is not otherwise prohibited.

Except for eye splices in the ends of wires and for endless rope slings, each wire rope used in hoisting or lowering, or in pulling loads, shall consist of one continuous piece without knot or splice.

Wire rope shall not be used if, in any length of eight diameters, the total number of visible broken wires exceeds 10 percent of the total number of wires, or if the rope shows other signs of excessive wear, corrosion, or defect.

Cable laid and 6 × 19 and 6 × 37 slings shall have a minimum clear length of wire rope 10 times the component rope diameter between splices, sleeves or end fittings.

Safe operating temperatures. Fiber core wire rope slings of all grades shall be permanently removed from service if they are exposed to temperatures in excess of 200 °F (93.33 °C). When nonfiber core wire rope slings of any grade are used at temperatures above 400 °F (204.44 °C) or below minus 60 °F (15.55 °C), recommendations of the sling manufacturer regarding use at that temperature shall be followed.

Wire rope slings shall have permanently affixed, legible identification markings stating size, rated capacity for the type(s) of hitch(es) used and the angle upon which it is based, and the number of legs if more than one.

Employers must not use natural- and synthetic-fiber rope slings with loads in excess of the rated capacities (i.e., working load limits) indicated on the sling by permanently affixed and legible identification markings prescribed by the manufacturer.

In manila rope, eye splices shall contain at least three full tucks, and short splices shall contain at least six full tucks (three on each side of the centerline of the splice).

In layed synthetic fiber rope, eye splices shall contain at least four full tucks, and short splices shall contain at least eight full tucks (four on each side of the centerline of the splice).

Strand end tails shall not be trimmed short (flush with the surface of the rope) immediately adjacent to the full tucks. This precaution applies to both eye and short splices and all types of fiber rope. For fiber ropes under 1-inch diameter, the tails shall project at least six rope diameters beyond the last full tuck. For fiber ropes 1-inch diameter and larger, the tails shall project at least 6 inches beyond the last full tuck. In applications where the projecting tails may be objectionable, the tails shall be tapered and spliced into the body of the rope using at least two additional tucks (which will require a tail length of approximately six rope diameters beyond the last full tuck).

Safe operating temperatures. Natural and synthetic fiber rope slings, except for wet frozen slings, may be used in a temperature range from minus 20 °F (-28.88 °C) to plus 180 °F (82.2 °C) without decreasing the working load limit. For operations outside this temperature range and for wet frozen slings, the sling manufacturer"s recommendations shall be followed.

Splicing. Spliced fiber rope slings shall not be used unless they have been spliced in accordance with the following minimum requirements and in accordance with any additional recommendations of the manufacturer:

In manila rope, eye splices shall consist of at least three full tucks, and short splices shall consist of at least six full tucks, three on each side of the splice center line.

In synthetic fiber rope, eye splices shall consist of at least four full tucks, and short splices shall consist of at least eight full tucks, four on each side of the center line.

Strand end tails shall not be trimmed flush with the surface of the rope immediately adjacent to the full tucks. This applies to all types of fiber rope and both eye and short splices. For fiber rope under 1 inch (2.54 cm) in diameter, the tail shall project at least six rope diameters beyond the last full tuck. For fiber rope 1 inch (2.54 cm) in diameter and larger, the tail shall project at least 6 inches (15.24 cm) beyond the last full tuck. Where a projecting tail interferes with the use of the sling, the tail shall be tapered and spliced into the body of the rope using at least two additional tucks (which will require a tail length of approximately six rope diameters beyond the last full tuck).

Removal from service. Natural and synthetic fiber rope slings shall be immediately removed from service if any of the following conditions are present:

Employers must use natural- and synthetic-fiber rope slings that have permanently affixed and legible identification markings that state the rated capacity for the type(s) of hitch(es) used and the angle upon which it is based, type of fiber material, and the number of legs if more than one.

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Re: Wire rope clips on suspension scaffolds; safety latches on large crane hooks; hanging scaffolds - order of assembly; jobsite fabricated lifting accessories - criteria; and horizontal lifelines: use of wire rope clips, anchorages, number of persons allowed to be connected, requirements relating to sag, and use of synthetic rope.

This is in response to your facsimile dated November 14, 2003, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your questions as follows:

Question 1(a) - (c): When using horizontal lifelines as part of personal fall arrest systems, what type of wire rope clips does OSHA require, and how many clips must be used? Additionally, what are the horizontal spacing criteria for the uprights?

Subpart M does not specify what type of wire rope clip or how many clips/clamps must be used when installing a horizontal lifeline. However, under §1926.502(d)(8), these decisions must be made under the supervision of a qualified person when the system is designed. The determination of the horizontal spacing criteria for uprights is also left to the qualified person"s supervisory approval.1

In an August 28, 2000 letter to Mr. Troxell2, we addressed the related issue of using wire rope clips on a wire rope guardrail. In that letter, we cautioned that, as a practical matter, it is unlikely that the criteria requirements for guardrails under §1926.502(b) could be met unless the manufacturer"s recommendations for the number of clips to be used on wire ropes of different diameters were followed (for example, the Crosby Group, Inc., general catalog 2000 edition, has tables showing their recommendations for their clips). We also pointed out that OSHA"s standard for rigging equipment used for material handling, 29 CFR 1926.251, has a table showing the number of clips required for wire rope ½-inch and greater. We noted that although that standard does not apply to wire rope used for guardrails, when designing a rope system to meet the §1926.502 guardrail requirements, following the tables at §1926.251 will normally ensure that there will be enough clips.

The forces exerted on a horizontal lifeline are substantially greater than those on a typical guardrail. Therefore, the system designer needs to ensure that the number, type, and location of clips will withstand the anticipated forces and meet the performance requirements in §1926.502 for horizontal lifelines.

Question 2: For a horizontal lifeline used as part of a personal fall arrest system during steel erection work, how tight should the lifeline be, and may synthetic rope be used for the horizontal lifeline?

Therefore, a qualified person is required to determine how tight the lifeline should be based on site-specific factors. No other requirements are imposed by OSHA regarding the tightness of the lifeline, so long as it comports with a safety factor of at least two.

With regard to the use of synthetic ropes, §1926.502(d)(14) specifies that, when using non-wire rope, synthetic rope (rather than nature fiber rope) must be used:

Question 4: Are there OSHA standards that specify criteria for constructing jobsite fabricated rigging equipment such as an equalizing beam, lifting beam, spreader beam, equalizing plates, tee lugs, lifting lugs, and welded scaffold brackets?

The only OSHA construction standards that contains specific criteria related to the construction of special custom design lifting accessories is 29 CFR 1926.251(a)(4), which states:

Question 5: Under §1926.451(d)(12)(v) and (vi), when wire rope clips are used on suspension scaffolds, "(v) U-bolt clips shall not be used at the point of suspension for any scaffold hoist," and "(vi) when U-bolt clips are used, the U-bolt shall be placed over the dead end of the rope, and the saddle shall be placed over the live end of the rope." Does §1926.451(d)(12)(v) contradict paragraph (d)(12)(vi)?

No. By its terms, §1926.451(d)(12)(v) prohibits the use of U-bolt clips at the point of suspension for any scaffold. The scaffold standard does not prohibit using U-bolt clips elsewhere. However, when using them elsewhere, under §1926.451(d)(12)(vi), the U-bolt must be placed over the dead end of the rope, and the saddle placed over the live end of the rope.

Question 6: Under §1926.251(c)(4)(iii), are eyes in wire rope bridles and slings or bull wires formed by wire rope clips permitted when used to lift scrap boxes or pendants?

This provision specifically prohibits eyes in wire rope bridles and slings or bull wires being formed by wire rope clips. There is no exception for lifting scrap boxes or pendants.

There are no OSHA standards setting criteria for horizontal high-lines. However, an employer"s use of a horizontal high-line must be in accordance with its obligations under Section 5(a)(1) of the Occupational Safety and Health Act (the "General Duty Clause"), which states:

In our view, the industry recognizes that the following engineering factors, among others, must be considered when designing horizontal high-lines: the span and sag of the wire rope line, the weight of the load being lifted, the initial tension of the rope line, and the size of the columns.

OSHA requirements for a safety latch on hooks do not depend of the size of the hook but rather the activity for which the hook is being used. Safety latches on hooks are required in two instances:

Knotting wire rope compromises the integrity of the strength of the wire rope and is therefore prohibited. Based on the picture provided, which showed a knot in wire rope secured by a U-bolt clip, this practice would be in violation of §1926.251(c)(3).

Question 10: Do OSHA standards require the attachment of an orange and white flag to the highest point of a crane that is being used in the vicinity of an airport?

There are no OSHA standards that require the highest point of a crane to be marked to enhance visibility to air traffic. However, the use of a crane in the vicinity of an airport may be subject to requirements set by other regulatory agencies, such as the Federal Aviation Administration.

Question 11: Do OSHA standards specify a particular anchorage point for connecting the lanyards of workers on crane suspended personnel platforms? Do the standards limit the number of such workers that can be attached to an anchorage point?

If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

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Each suspension rope, including connecting hardware, used on non-adjustable suspension scaffolds shall be capable of supporting, without failure, at least 6 times the maximum intended load applied or transmitted to that rope.

Each suspension rope, including connecting hardware, used on adjustable suspension scaffolds shall be capable of supporting, without failure, at least 6 times the maximum intended load applied or transmitted to that rope with the scaffold operating at either the rated load of the hoist, or 2 (minimum) times the stall load of the hoist, whichever is greater.

Where scaffolds must be used in areas that the employer can demonstrate are so narrow that platforms and walkways cannot be at least 18 inches (46 cm) wide, such platforms and walkways shall be as wide as feasible, and employees on those platforms and walkways shall be protected from fall hazards by the use of guardrails and/or personal fall arrest systems.

Except as provided in paragraphs (b)(3)(i) and (ii) of this section, the front edge of all platforms shall not be more than 14 inches (36 cm) from the face of the work, unless guardrail systems are erected along the front edge and/or personal fall arrest systems are used in accordance with paragraph (g) of this section to protect employees from falling.

Each end of a platform 10 feet or less in length shall not extend over its support more than 12 inches (30 cm) unless the platform is designed and installed so that the cantilevered portion of the platform is able to support employees and/or materials without tipping, or has guardrails which block employee access to the cantilevered end.

Each platform greater than 10 feet in length shall not extend over its support more than 18 inches (46 cm), unless it is designed and installed so that the cantilevered portion of the platform is able to support employees without tipping, or has guardrails which block employee access to the cantilevered end.

When an outrigger beam is used, the shackle or clevis with which the rope is attached to the outrigger beam shall be placed directly over the center line of the stirrup.

When winding drum hoists are used on a suspension scaffold, they shall contain not less than four wraps of the suspension rope at the lowest point of scaffold travel. When other types of hoists are used, the suspension ropes shall be long enough to allow the scaffold to be lowered to the level below without the rope end passing through the hoist, or the rope end shall be configured or provided with means to prevent the end from passing through the hoist.

Ropes shall be inspected for defects by a competent person prior to each workshift and after every occurrence which could affect a rope"s integrity. Ropes shall be replaced if any of the following conditions exist:

Swaged attachments or spliced eyes on wire suspension ropes shall not be used unless they are made by the wire rope manufacturer or a qualified person.

Portable, hook-on, and attachable ladders (Additional requirements for the proper construction and use of portable ladders are contained in subpart X of this part -- Stairways and Ladders):

Ramps and walkways 6 feet (1.8 m) or more above lower levels shall have guardrail systems which comply with subpart M of this part -- Fall Protection;

Suspension ropes supporting adjustable suspension scaffolds shall be of a diameter large enough to provide sufficient surface area for the functioning of brake and hoist mechanisms.

Suspension ropes shall be shielded from heat-producing processes. When acids or other corrosive substances are used on a scaffold, the ropes shall be shielded, treated to protect against the corrosive substances, or shall be of a material that will not be damaged by the substance being used.

To reduce the possibility of welding current arcing through the suspension wire rope when performing welding from suspended scaffolds, the following precautions shall be taken, as applicable:

An insulated thimble shall be used to attach each suspension wire rope to its hanging support (such as cornice hook or outrigger). Excess suspension wire rope and any additional independent lines from grounding shall be insulated;

The suspension wire rope shall be covered with insulating material extending at least 4 feet (1.2 m) above the hoist. If there is a tail line below the hoist, it shall be insulated to prevent contact with the platform. The portion of the tail line that hangs free below the scaffold shall be guided or retained, or both, so that it does not become grounded;

Each employee on a single-point or two-point adjustable suspension scaffold shall be protected by both a personal fall arrest system and guardrail system;

Each employee on a crawling board (chicken ladder) shall be protected by a personal fall arrest system, a guardrail system (with minimum 200 pound toprail capacity), or by a three-fourth inch (1.9 cm) diameter grabline or equivalent handhold securely fastened beside each crawling board;

Each employee on a self-contained adjustable scaffold shall be protected by a guardrail system (with minimum 200 pound toprail capacity) when the platform is supported by the frame structure, and by both a personal fall arrest system and a guardrail system (with minimum 200 pound toprail capacity) when the platform is supported by ropes;

Each employee on a walkway located within a scaffold shall be protected by a guardrail system (with minimum 200 pound toprail capacity) installed within 9 1/2 inches (24.1 cm) of and along at least one side of the walkway.

Each employee performing overhand bricklaying operations from a supported scaffold shall be protected from falling from all open sides and ends of the scaffold (except at the side next to the wall being laid) by the use of a personal fall arrest system or guardrail system (with minimum 200 pound toprail capacity).

For all scaffolds not otherwise specified in paragraphs (g)(1)(i) through (g)(1)(vi) of this section, each employee shall be protected by the use of personal fall arrest systems or guardrail systems meeting the requirements of paragraph (g)(4) of this section.

When horizontal lifelines are used, they shall be secured to two or more structural members of the scaffold, or they may be looped around both suspension and independent suspension lines (on scaffolds so equipped) above the hoist and brake attached to the end of the scaffold. Horizontal lifelines shall not be attached only to the suspension ropes.

When lanyards are connected to horizontal lifelines or structural members on a single-point or two-point adjustable suspension scaffold, the scaffold shall be equipped with additional independent support lines and automatic locking devices capable of stopping the fall of the scaffold in the event one or both of the suspension ropes fail. The independent support lines shall be equal in number and strength to the suspension ropes.

Vertical lifelines, independent support lines, and suspension ropes shall not be attached to each other, nor shall they be attached to or use the same point of anchorage, nor shall they be attached to the same point on the scaffold or personal fall arrest system.

Guardrail systems installed to meet the requirements of this section shall comply with the following provisions (guardrail systems built in accordance with Appendix A to this subpart will be deemed to meet the requirements of paragraphs (g)(4)(vii), (viii), and (ix) of this section):

Guardrail systems shall be installed along all open sides and ends of platforms. Guardrail systems shall be installed before the scaffold is released for use by employees other than erection/dismantling crews.

The top edge height of toprails or equivalent member on supported scaffolds manufactured or placed in service after January 1, 2000 shall be installed between 38 inches (0.97 m) and 45 inches (1.2 m) above the platform surface. The top edge height on supported scaffolds manufactured and placed in service before January 1, 2000, and on all suspended scaffolds where both a guardrail and a personal fall arrest system are required shall be between 36 inches (0.9 m) and 45 inches (1.2 m). When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria of paragraph (g)(4).

When midrails, screens, mesh, intermediate vertical members, solid panels, or equivalent structural members are used, they shall be installed between the top edge of the guardrail system and the scaffold platform.

When midrails are used, they shall be installed at a height approximately midway between the top edge of the guardrail system and the platform surface.

When screens and mesh are used, they shall extend from the top edge of the guardrail system to the scaffold platform, and along the entire opening between the supports.

Each toprail or equivalent member of a guardrail system shall be capable of withstanding, without failure, a force applied in any downward or horizontal direction at any point along its top edge of at least 100 pounds (445 n) for guardrail systems installed on single-point adjustable suspension scaffolds or two-point adjustable suspension scaffolds, and at least 200 pounds (890 n) for guardrail systems installed on all other scaffolds.

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members of a guardrail system shall be capable of withstanding, without failure, a force applied in any downward or horizontal direction at any point along the midrail or other member of at least 75 pounds (333 n) for guardrail systems with a minimum 100 pound toprail capacity, and at least 150 pounds (666 n) for guardrail systems with a minimum 200 pound toprail capacity.

Suspension scaffold hoists and non-walk-through stirrups may be used as end guardrails, if the space between the hoist or stirrup and the side guardrail or structure does not allow passage of an employee to the end of the scaffold.

Manila or plastic (or other synthetic) rope being used for toprails or midrails shall be inspected by a competent person as frequently as necessary to ensure that it continues to meet the strength requirements of paragraph (g) of this section.

In addition to wearing hardhats each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toeboards, screens, or guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures that contain or deflect the falling objects. When the falling objects are too large, heavy or massive to be contained or deflected by any of the above-listed measures, the employer shall place such potential falling objects away from the edge of the surface from which they could fall and shall secure those materials as necessary to prevent their falling.

Where tools, materials, or equipment are piled to a height higher than the top edge of the toeboard, paneling or screening extending from the toeboard or platform to the top of the guardrail shall be erected for a distance sufficient to protect employees below; or

When canopies are used on suspension scaffolds for falling object protection, the scaffold shall be equipped with additional independent support lines equal in number to the number of points supported, and equivalent in strength to the strength of the suspension ropes.

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The Occupational Safety and Health Administration (OSHA) hereby revises the construction industry safety standards which regulate the design, construction, and use of scaffolds. The final rule updates the existing scaffold standards and sets performance-oriented criteria, where possible, to protect employees from scaffold-related hazards such as falls, falling objects, structural instability, electrocution and overloading.

In particular, the final rule has been updated to address types of scaffolds -- such as catenary scaffolds, step and trestle ladder scaffolds, and multi-level suspended scaffolds -- not covered by OSHA"s existing scaffold standards. In addition, the final rule allows employers greater flexibility in the use of fall protection systems to protect employees working on scaffolds and extends fall protection to erectors and dismantlers of scaffolds to the extent feasible.

The Occupational Safety and Health Act of 1970 (the OSH Act) authorized the Secretary of Labor to adopt established federal standards issued under other statutes, including the CSA, as occupational safety and health standards. Accordingly, the Secretary of Labor adopted the Construction Standards, which had been issued under the CSA, as OSHA standards. The Safety and Health Regulations for Construction were subsequently redesignated as 29 CFR part 1926. Standards addressing scaffolds, §§1926.451 and 1926.452, were adopted in subpart L of part 1926 as OSHA standards as part of this process.

Various amendments were made to subpart L during the first two years of the OSH Act. The amendments revised scaffold provisions that addressed planking grades, wood pole scaffold construction, overhead protection, bracket scaffold loading, and plank spans. Also, substantive provisions concerning pump jack scaffolds, height of catch platforms, and guardrails were added.

Based on concerns regarding the effectiveness of the existing scaffold standards, OSHA began a complete review of subpart L in 1977. The Agency consulted the Advisory Committee on Construction Safety and Health (ACCSH) several times regarding draft revisions to subpart L.

Based on its review of existing subpart L, OSHA believes that certain provisions in the existing standards are outdated, redundant, or ambiguous. In addition, some types of scaffolds used in construction (e.g., catenary scaffolds) are not clearly addressed by the existing standards, and some provisions cover only certain types of scaffolds when they should apply to all. The final rule eliminates those unnecessary, outdated and redundant provisions (e.g., revised subpart L st

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