- Standard Number:1910.750
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 https://www.osha.gov.
September 14, 1990
| MEMORANDUM FOR: | Charles Culver |
| THRU: | Roger Clark |
| FROM: | Roy Gurnham |
| SUBJECT: | Perimeter Guarding Utilizing Wire Rope |
Thank you for sending me a copy of your September 7 memo to Pat Clark, subject as above--the acceptance of 1/4 and 1/2-inch wire rope for perimeter guardrails.
In the last paragraph of your memo, you noted your willingness to help if Ms. Clark decides that national office direction is warranted to eliminate inconsistencies and to clarify the standard. In this regard, I thought you might want to know that in the November 25, 1986, NPRM on Subpart M--Fall Protection (1926) the agency proposed several requirements for the criteria for guardrail systems. One of these requirements is that the toprail be at least 1/4-inch diameter or thickness. The 1/4-inch requirement addresses hazards of cuts and lacerations that may occur when an employee grabs the rope. The rulemaking record supports the proposed provision of 1/4" toprails provided they are flagged for visibility. Thus, you can anticipate that the final rule will be clear as to the agency's position.
In addition, in the NPRM for steel erection, we raised an issue regarding perimeter protection. Currently, our position is that the safety railing system required in .750 must be a minimum 1/2-inch wire rope because of the impact load the railing may have to withstand if struck by hoisted steel members. In the NPRM, we are specifically asking for comments on whether we should keep this requirement and whether we should require a conventional two-rail guardrail system for steel work. We have also proposed to remove the words "or equal" which appear in the existing standard after the words "1/2 inch." The "or equal" was a reference to the materials used and not to their strength. This appears to have been misunderstood. The final rule on steel will clearly set forth the requirements for wire rope used as a fall prevention measure.
Please let me know if further clarification of the proposed rules is needed.