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Fall protection while climbing rebar assemblies and formwork

Summary A reinforcing-steel group asked whether ironworkers could climb concrete rebar assemblies without tying off. OSHA said its then-current interpretation allowed movement on rebar assemblies built in place up to 24 feet without tie-off, while formwork required protection at fall distances of six feet or more. It treated steel erection separately and now labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-09-26-2
Date issued
September 26, 1995
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 9, 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 26, 1995
Mr. Victor Walther, Jr.
President
Concrete Reinforcing Steel Institute
[Recipient address omitted]
Dear Mr. Walther, Jr.:
This is in response to your letter of December 14, 1994 to the Occupational Safety and Health Administration (OSHA) in which you asked us to clarify or modify 29 CFR 1926.501(b)(5), which states, "Each employee on the face of formwork or reinforcing steel shall be protected from falling 6 feet or more to lower levels by personal fall arrest systems, safety net systems, or positioning device systems." In addition, you requested that OSHA allow ironworkers to climb or move horizontally on wall and column assemblies without being tied off.
Paragraph .501(b)(5) applies only to formwork and reinforcing steel used in concrete structures. It does not apply to steel erection activities. Recently, the paragraph has been interpreted by OSHA to mean that on rebar assemblies (not formwork) that are built in place for concrete structures, employees of any trade can climb and move about up to the height of twenty-four (24) feet without being tied off. On formwork, however, employees must be protected at all times where the fall distance is six (6) feet or more, including when employees are moving from point to point.
Ironworkers involved in steel erection activities must be protected from falls in accordance with the enclosed July 10, 1995 memorandum.
If you have any questions, please call me or Dave 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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