Rebar impalement protection and scaffold midrails

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 18, 1991
Mr. Paul Vincent Bonfigio
Safety Advisor
Vincent Safety Service Company
[Recipient address omitted]
Dear Mr. Bonfigio:
Thank you for your letters of March 28, 1991 concerning guarding of protruding reinforcement steel rods and May 29, 1991 concerning guardrails on intermediate levels of scaffolds.
When the standard on concrete and masonry construction was changed in 1988, it was broadened to protect employees not only while working above vertically protruding rod but also to protects employees from the hazard of falling into horizontal protruding rods or rods at the same level as the employee.
Enclosed are the pages from the Federal Register of the preamble which address this change.
Your suggestion to use a 2" x 4" wood rail or pipe rail placed horizontally at or near the junction of the cross braces and a plank for a toeboard would partially address the guard rail problem on the intermediate levels; however it does not provide for a midrail as required. Enclosed find a copy of material on a unit made by WACO SCAFFOLDING and EQUIPMENT which appeared in the April 1991 issue of the Newletter of the SCAFFOLD INDUSTRY ASSOCIATION.
If I may be of further assistance please contact me.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs