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Steel band guardrails at concrete slab edges

Summary A concrete contractor asked whether steel bands could protect workers at building slab edges. OSHA said ordinary bands posed an edge hazard, but a flagged, edge-protected, strong, and regularly inspected banding system could meet the then-current guardrail rule; it said no variance was needed for the described system. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1981-07-28
Date issued
July 28, 1981
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

July 28, 1981

Mr. A. J. Weaver
Safety Director
Miller & Long Co., Inc.
Concrete Construction
[Recipient address omitted]

Dear Mr. Weaver:

This is in response to your letter of July 15, 1981, concerning perimeter protection at building slab edges. Your letter addressed to Mr. James Concannon was forwarded to this office for response.

Normally steel bands are not acceptable as top rails or intermediate rails of a guardrail system because the edges of the band constitute a potential hazard to hands and other portions of the body exposed to the bands. However, steel bands well flagged for easy identification with sufficient strength to meet design criteria in 29 CFR 1926.500(f)(1)(vi)(a)(b)(c) and (d) and with the edges protected could be used as guardrails. In addition, your system will be maintained by regularly inspecting the metal banding and replacing any that exhibit rust, corrosion, or deflects more than three inches when two hundred pounds pressure or less is applied to it.

Your request for a variance for the above method of perimeter protection is unnecessary because your guardrail system, as described, using steel banding would comply with the 29 CFR 1926.500(f)(1)(vi).

If I may be of further assistance, please feel free to call or write.

Sincerely,
John K. Barto Chief,
Division of Occupational Safety Programming

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