Standard Interpretations - Table of Contents
• Standard Number: 1926.701(b); 1926.25(a)

March 18, 2014

Eric M. Dean
General Secretary
International Association of
Bridge, Structural, Ornamental and Reinforcing Iron Workers
Suite 400
1750 New York Ave. NW
Washington, DC 20006

Dear Mr. Dean:

Thank you for your March 12, 2013, letter to the Occupational Safety and Health Administration (OSHA). You asked for clarification regarding impalement hazards on construction worksites. Specifically, whether OSHA recognizes objects other than reinforcing steel as impalement hazards and, if so, what standards are applicable?

Yes. OSHA recognizes that there are objects other than reinforcing steel that can present potential impalement hazards. OSHA has two construction standards which apply to impalement hazards.

29 CFR 1926.701(b) applies to reinforcing steel. It states:

All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement.

29 CFR 1926.25(a) applies to protruding nails. It states:

During the course of construction, alteration, or repairs, form and scrap lumber with protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and around buildings or other structures.

In addition, with respect to impalement hazards not covered by these standards, the General Duty Clause (section 5(a)(1)) of the Occupational Safety and Health Act requires employers to furnish a workplace which is free from recognized hazards that are causing or are likely to cause death or serious physical harm. Therefore, employers are required to protect employees exposed to the hazard of impalement by sharp objects. For example, where steel stakes and metal conduit pose a recognized impalement hazard and there are feasible means of protection, the employer is required to implement protective measures