Fall Protection - walking/working along bridge decks

September 3, 2013

Dear Mr. F****:

Thank you for your letter dated April 5, 2013 to the Occupational Safety and Health Administration (OSHA). In your letter you discussed safe guarding for employees required to work next to finished concrete barriers commonly used in highway construction. Most of these barriers are only 32 inches high. Employees could be exposed to falls of 6 feet or more when performing ancillary tasks, such as painting or removal of concrete curing material. You stated that the vast majority of Department of Transportation Contracts through the Federal Highway Administration have contract specifications that do not permit the use of systems such as anchorages for a personal fall protection system if there is a need to penetrate the surface of decks or barrier walls. While it's an accepted practice to use job-fabricated wooden built-up rail systems, you point out that this could entail tens of thousands of circular saw cuts. You contend that exposure to cuts and ergonomic considerations of these systems create greater hazards to employees than that of a fall exposures. Given your scenario we paraphrased above, you asked the following question:
Would the use of high visibility warning stripes placed on the decking during construction and subsequent use of permanent pavement markings in conjunction with training and enforcement meet the requirements for protection of workers having to walk and/or travel along decks between the offset markings when the edges are protected with a finished 32 inch high barrier wall?

No. Using a 32" high concrete barrier to serve as a guardrail to protect employees doesn't comply with minimum top edge requirement of the guardrail system to be 42 inches high plus or minus 3 inches.

The fabricated plywood saddle system described in your letter is one of many systems that can be used. On May 10, 2013, we briefly discussed alternatives such as c-clamp guardrail systems that are easily transportable and available for rent. We also discussed OSHA's alternative uses of warning line systems meeting the requirements defined in 29 CFR 1926.502(f)(2) providing it's use maintains a "no entry" 15 foot setback from an edge or hole 6 feet or more above a lower level. You indicated that your employees would need to work within the 15 foot restriction and thus a warning line system would be infeasible. See the attached Letter of Interpretation. This letter can also be found on OSHA's website at the following link: http://www.oshainterpretations.com/1926_Safety_and_Health_Regulations_for_Construction/?url=/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS~p_id=24802&n=Fall%20protection%20non-conforming%20guardrail%20criteria%20for%20application%20of%20a%20de%20minimis%20policy.
Thank you for your interest on occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such development, you can consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Construction at 202 693-2020.

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