Fall protection while working on reinforcing steel

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 26, 1995
Christopher Seniuk, M.P.A. C.S.P. C.I.H.
Assistant Vice President
Director of Safety and Health Services
Lovell Safety Management Co., Inc.
[Recipient address omitted]
Dear Mr. Seniuk:
This is in response to your letter of January 20 in which you raise a number of concerns and questions about a December 23, 1994 letter from the Occupational Safety and Health Administration (OSHA) to the National Association of Reinforcing Steel Contractors (NARSC). I apologize for the delay of the response.
Your first question concerned whether or not fall protection is to be used when reinforcing steel is being installed. Your specific concern was with a December 23, 1994, letter from OSHA to the National Association of Reinforcing Steel Contractors (NARSC) in which we stated "fall protection is not normally required when employees are moving" on reinforcing steel. Please be advised that our response applies only to reinforcing steel (re-bars) used in concrete structures; the letter does not apply to other types of reinforcing steel.
With regard to whether citations are to be issued prior to or after precast concrete slab connecting bolts are secure or the reinforcing wires have been stressed, please be advised that the duty to provide fall protection arises when there is exposure to the fall hazard and is independent of the two conditions listed.
OSHA is not aware of any documentation indicating there is a problem with falls from vertical walls or cages built in place. If you have any such information we would appreciate you sending a copy to OSHA for review.
Your fourth concern was the application of OSHA's job-made ladder requirements to rebar cages. Proper spacing of the rebars used as rungs would, of course, be an important consideration in evaluating the access, as would other requirements contained in Subpart X. Please understand, our response to Mr. Codding was oriented to the issue of tying-off during access; it should not be read to mean that OSHA has deemed all rebar configurations to be equivalent to a ladder, nor that regardless of spacing rebar assemblies may be used in lieu of a ladder. For example, as you correctly point out, untied rebar used as a ladder can pose a serious hazard.
Your next point concerned carrying loads while climbing the rebar. Subpart X allows loads to be carried on a ladder provided the load does not cause the climbers to lose their balance. OSHA has no information indicating that carrying rebars, as described in the NARSC letter, should be prohibited.
With respect to pile drivers, fall protection is covered by 29 CFR 1926.603(a)(8). Subparts M and X do not affect that requirement.
Your final point concerns the need for fall protection on rebar assemblies at heights less than 24 feet. Please be advised that fall protection is required at heights of six feet or more once the employee has reached the level of the work to be performed. Fall protection is also required for these same employees during access to heights exceeding 24 feet.
If you have further questions, please do not hesitate to contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 219-8136.
Sincerely,
James W. Stanley,
Deputy Assistant Secretary

[Requester correspondence and earlier OSHA letters reproduced on OSHA page; omitted here.]