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Steel bands as top and intermediate guardrails

Summary A union asked whether steel bands could be used as top and intermediate rails. OSHA said alternate rail materials were allowed if they met strength and layout requirements, with exposed band edges protected and tension sufficient to limit deflection. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-12-11-1
Date issued
December 11, 1979
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 11, 1979
Joe A. Adam, Director
Department of Safety and Health
United Association of Journeyman and Apprentices
of the Plumbing and Pipe Fitting Industry
[Recipient address omitted]
Dear Mr. Adam:
This is in response to your inquiry concerning the acceptability of steel bands for top rails and intermediate rails of a guardrail system.
29 CFR 1926.500(f)(1)(vi), for temporary or emergency conditions, states that other types, sizes, and arrangements of railing construction are acceptable, provided they meet the requirements contained in (a), (b), (c) and (d). The standard permits the use of any material meeting the above requirements.
The use of the word "normally" was included in the memorandum to clarify that the metal banding thickness usually requires the edges to be rolled, covered or otherwise shielded to protect employees that may make sudden contact with the edges.
In situations where the span between columns exceeds ten feet, it may be difficult to provide enough tension in a steel band to keep the level of deflection at a minimum while withstanding a two-hundred pound force.
On many construction projects when wire rope is used for the top and intermediate rails, employers are confronted with a similar difficulty in providing enough tension on the rope to minimize the deflection. The compliance officers making construction inspections are required to evaluate the wire rope and the metal banding systems during the course of an inspection. In this regard, plans are in progress to provide the field staff with force measurement equipment to evaluate such systems.
As indicated in your letter, Subpart R, 29 CFR 1926.750 allows the use of 1/2 inch wire rope or equal, to be installed around the periphery of temporary planked or metal decked floors during structural steel assembly. Steel bands providing equivalent strength could be used in lieu of the 1/2 wire rope, provided the metal banding edge is rolled, covered or otherwise protected.
I hope this information will be helpful to you in understanding our position in this matter. If I can be of any further assistance, please feel free to contact me.
Sincerely,
Grove C. Wrenn Director
Federal Compliance and State Programs

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