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Guarding protruding reinforcing steel

Summary A construction employer asked whether large reinforcing bars protruding from a concrete floor had to be guarded. OSHA said any diameter or length of protruding bar must be guarded where a worker could fall onto it and face an impalement hazard.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-03-23
Date issued
March 23, 1994
Status
Active
Status last verified October 9, 2026

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March 23, 1994

Mr. Rich Krohn
Corporate Safety Director
Mortenson
[Recipient address omitted]
Dear Mr. Krohn:

Your June 4 letter to Mr. Gerald Cunningham, Area Director, Milwaukee Area Office, requesting an interpretation of 29 CFR 1926.701(b) has been forwarded to the Office of Construction and Maritime Compliance Assistance for a response. We apologize for the delay in responding to your inquiry.

With regard to the applicability of the above mentioned standard to large diameter (1 inch and greater) reinforcing steel which protrude vertically 24 - 72 inches from the concrete floor under construction, please be advised that reinforcing steel of any diameter and any length must be guarded when there is the hazard that an employee could fall onto the rebar and be impaled (skin pierced).

Accordingly, the intent of the standard is to provide employee protection by guarding all protruding reinforcing steel which creates an impalement hazard.

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,
Roy F. Gurnham, P.E., J.D.
Director, Office of Construction and Maritime Compliance Assistance

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