Standard Interpretations - Table of Contents
• Standard Number: 1926.502; 1926.760(d); 1926.760(d)(3); 1926.760(a)(2)

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

July 17, 2002

Mr. Barry A. Cole
Executive Vice President
Miller Safety Consulting, Inc.
5750 Pecos Street, Suite 6
Denver, CO 80221

Dear Mr. Cole:

By letter dated April 11, 2002, we responded to an inquiry that you sent us regarding perimeter guardrail requirements under the new steel erection standard. Since our letter, you have discussed this issue further with members of my staff. We have developed the question and answer below in order to address an aspect of your question that was not addressed in our April 11 letter.

Scenario: In a multi-story structure, prior to the installation of decking, an ironworker installs a perimeter cable to be used as a horizontal lifeline -- as an anchorage for personal fall protection equipment. The lifeline meets the criteria for a personal fall arrest anchorage. However, since it is a single cable, it does not meet the guardrail requirements under §§1926.760(d) and