Historical fall protection while moving on rebar assemblies

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 23, 1994
Mr. Fred H. Codding
National Association of Reinforcing Steel Contractors
[Recipient address omitted]
Dear Mr. Codding:
Your December 8 letter addressed to Ms. Barbara Bielaski requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) final rule addressing fall protection during rebar assembly construction has been forwarded to the Office of Construction and Maritime Compliance Assistance for response.
With regard to whether paragraph 1926.501(b)(5) of the final rule on subpart M applies to employees while moving vertically and/or horizontally on the vertical face or rebar assemblies built in place, please be advised that fall protection is not normally required when employees are moving. OSHA considers the multiple hand holds and foot holds on rebar assemblies as providing similar protection as that provided by a fixed ladder. Similarly, no fall protection is necessary while moving point to point for heights below 24 feet.
As is required by the fixed ladder standard, an employee must be provided with fall protection when climbing or otherwise moving at a height more than 24 feet. Other provisions of the ladder requirements might have application, however, many would be treated on a de minimus basis.
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 Assistance

[Requester letter reproduced on OSHA page; omitted here.]