Safety Notice

In August of 1994 OSHA announced a new Subpart M to be effective early the next year. Recognizing the impact upon the reinforcing steel industry and problems for Iron Workers ascending to their place of work (work station) upon vertical assemblies of reinforcing steel being built in place, as well as moving horizontally on the vertical face of rebar assemblies, NARSC and Iron Workers International representatives met with OSHA for clarification. To assist our presentation, we prepared a video of the increased hazards Iron Workers encounter with the use of lanyards when carrying rebar up a wall or column being built.

Following is the correspondence with OSHA, including their decision that “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.” Note that the Iron Worker must tie off when he reaches his work station and that this applies only when rebar assemblies are being constructed.

12/8/94 - Letter from NARSC to OSHA

12/23/94 - Letter from OSHA to NARSC

5/19/97 - Letter from OSHA to NARSC and International Association of Bridge, Structural and Ornamental Iron Workers

12/23/97 - Letter from OSHA to NARSC

03/10/2004 - Fall protection is not required where there is no feasible means of providing it while working on vehicles or trailers.

Download all 5 letters as PDF file

Safety Notice

In March of 2005 NARSC requested a clarification from OSHA as to certain protection requirements during the installation of reinforcing steel in a slab.  The clarification dealt with the protective coverings for protrusions through the slab by reinforcing steel, “chairs” or other accessories during active construction.  Slabs are frequently layered with protrusions coming from the lower slab.

3/16/05 - Letter from NARSC to OSHA

3/27/06 - OSHA Response to NARSC 3/16/05 Letter

Download both letters as PDF file