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OSHA 1926SubpartRAppG

Guardrail system requirements

Subpart R

32 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.502(b)(1), what is the required height for the top edge of a guardrail system and how do stilts affect that height?

The top edge of a guardrail must be 42 inches (1.1 m) plus or minus 3 inches above the walking/working level, and if employees are on stilts you must raise the top rail by the height of the stilts. See 1926.502(b)(1) and the general 1926.502(b) provisions for the stilts note.

Under 1926.502(b), can the top rail height exceed 45 inches and when is that allowed?

Yes — the top edge height may exceed 45 inches when conditions warrant, provided the guardrail system still meets all other requirements in 1926.502(b). The standard allows flexibility for site conditions so long as the system continues to satisfy strength, deflection, and opening-size rules.

Under 1926.502(b)(2), when must midrails, screens, mesh, or equivalent members be installed and where should they be placed?

Midrails, screens, mesh, intermediate vertical members, or equivalent members are required when there is no wall or parapet at least 21 inches (53 cm) high, and they must be installed between the top edge of the guardrail and the walking/working surface. See 1926.502(b)(2).

Under 1926.502(b)(2)(i)-(iv), what are the placement and spacing rules for midrails, screens, and intermediate members?

Midrails must be placed midway between the top rail and the walking/working surface; screens/mesh must extend from the top rail to the walking surface and cover the full opening; intermediate vertical members (balusters) must be no more than 19 inches (48 cm) apart; and other structural members must ensure no openings are more than 19 inches (0.5 m) wide. See 1926.502(b)(2)(i), 1926.502(b)(2)(ii), 1926.502(b)(2)(iii), and 1926.502(b)(2)(iv).

Under 1926.502(b)(3)-(4), what strength and deflection performance must guardrails meet?

Guardrail top edges must resist at least a 200 pound (890 N) force applied outward or downward within 2 inches of the top edge without failing, and when that 200‑pound load is applied downward the top edge must not deflect below 39 inches (1.0 m) above the walking/working level. See 1926.502(b)(3) and 1926.502(b)(4).

Under 1926.502(b)(5), what load must midrails, screens, mesh, and other intermediate members withstand?

Midrails, screens, mesh and similar intermediate members must withstand at least a 150 pound (666 N) force applied downward or outward at any point without failure. See 1926.502(b)(5).

Under 1926.502(b)(6)-(9), what are the requirements to prevent cuts, projections, and use of certain materials for top and midrails?

Top rails and midrails must be surfaced to prevent punctures, lacerations, and snagging; ends must not overhang terminal posts unless they are not a projection hazard; steel or plastic banding cannot be used as top or midrails; and top/midrails must be at least 1/4 inch (0.6 cm) nominal diameter or thickness. See 1926.502(b)(6), 1926.502(b)(7), 1926.502(b)(8), and 1926.502(b)(9).

Under 1926.502(b), what must you do if you use wire rope for guardrail top rails?

If you use wire rope as a top rail, it must be flagged with high-visibility material at intervals of no more than 6 feet. This requirement appears in the guardrail provisions of 1926.502(b).

Under 1926.502(b)(10), what must be provided at hoisting area access openings when hoisting is not taking place?

When guardrail systems are used at hoisting areas, you must place a chain, gate, or removable guardrail section across the access opening whenever hoisting operations are not occurring. See 1926.502(b)(10).

Under 1926.502(b)(11)-(13), what are the guardrail requirements for holes, holes used for material passage, and holes used as access (ladderways)?

Guardrails must be erected on all unprotected sides or edges of holes; holes used for material passage may have no more than two sides with removable guardrail sections to allow material passage (and must be closed or guarded when not in use); holes used as access must have a gate or be offset so a person cannot walk directly into the hole. See 1926.502(b)(11), 1926.502(b)(12), and 1926.502(b)(13).

Under 1926.502(b)(14), where must guardrail systems be used on ramps and runways?

Guardrail systems used on ramps and runways must be erected along each unprotected side or edge. See 1926.502(b)(14).

Under 1926.502(b)(15), how often must manila, plastic, or synthetic rope used as rails be inspected?

Manila, plastic, or synthetic rope used for top rails or midrails must be inspected as frequently as necessary to ensure it continues to meet the strength requirements in 1926.502(b)(3). See 1926.502(b)(15).

Under 1926.502(c)(2), how far must safety nets extend outward from the edge of the work surface based on the fall distance?

Safety nets must extend outward from the outermost projection of the working surface by a minimum horizontal distance that depends on the vertical distance to the net: 8 feet for up to 5 feet vertical, 10 feet for more than 5 up to 10 feet, and 13 feet for more than 10 feet. See 1926.502(c)(2).

Under 1926.502(c)(4)(i)-(ii), when must safety nets be drop-tested and when can an employer use a certification instead?

Generally, safety nets must be drop-tested at the jobsite after initial installation and before first use, whenever relocated, after major repair, and at 6‑month intervals if left in place; however, if the employer can demonstrate that performing the drop test is unreasonable, a competent person may instead prepare a written certification that the net and installation comply with the performance and clearance requirements before the net is used. See 1926.502(c)(4)(i) and 1926.502(c)(4)(ii).

Under 1926.502(c)(4)(i), what is the drop-test method and the test object specifications for safety nets?

The drop test requires dropping a 400‑pound (180 kg) bag of sand 30 inches (±2 in) in diameter into the net from the highest walking/working surface employees are exposed to, but not less than 42 inches (1.1 m) above that level. See 1926.502(c)(4)(i).

Under 1926.502(c)(3) and (c)(5)-(6), what clearances, inspections, and housekeeping must be maintained for safety nets?

Safety nets must have enough clearance under them so they do not contact structures when loaded by the drop test; nets must be inspected at least weekly and after any occurrence that could affect integrity; defective nets must not be used; and materials or tools that fall into a net must be removed as soon as possible and before the next shift. See 1926.502(c)(3), 1926.502(c)(4)(i), 1926.502(c)(5), and 1926.502(c)(6).

Under 1926.502(c)(7)-(9), what are the mesh size, border rope strength, and panel connection rules for safety nets?

Each safety‑net mesh opening must not exceed 36 square inches nor be longer than 6 inches on any side, all mesh crossings must be secured to prevent enlargement, each net must have a border rope or webbing with at least 5,000 pound breaking strength, and connections between net panels must be as strong as the net and spaced no more than 6 inches apart. See 1926.502(c)(7), 1926.502(c)(8), and 1926.502(c)(9).

Under 1926.502(d), are body belts still acceptable in personal fall arrest systems?

No — effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system (they may still be used in positioning device systems as regulated under 1926.502(e)). See 1926.502(d).

Under 1926.502(d)(1)-(5), what are the minimum requirements for connectors, dee‑rings, and snaphooks in personal fall arrest systems?

Connectors must be drop forged, pressed or formed steel or equivalent materials, have a corrosion‑resistant finish, and smooth edges; dee‑rings and snaphooks must have a minimum tensile strength of 5,000 pounds (22.2 kN); and dee‑rings/snaphooks must be proof‑tested to 3,600 pounds (16 kN) without cracking or permanent deformation. See 1926.502(d)(1), 1926.502(d)(2), 1926.502(d)(3), and 1926.502(d)(4).

Under 1926.502(d)(6) and related provisions, what are the rules for snaphook connections and use of locking snaphooks?

Only locking‑type snaphooks are allowed (effective January 1, 1998), and unless the snaphook is locking and designed for certain connections it must not be engaged directly to webbing, to another snaphook, to a dee‑ring with another connector attached, to a horizontal lifeline, or to any incompatibly shaped object that could depress the keeper and release itself. See 1926.502(d)(6) and the related 1926.502(e)(8) restrictions for positioning systems.

Under 1926.502(d)(8)-(10), what are the requirements for horizontal lifelines, lifeline strength, and how many employees per vertical lifeline?

Horizontal lifelines must be designed, installed, and used under a qualified person's supervision as part of a complete personal fall arrest system with at least a 2:1 safety factor; lanyards and vertical lifelines must have a minimum breaking strength of 5,000 pounds (22.2 kN); and except for a narrow elevator‑shaft exception, each employee must be attached to a separate vertical lifeline. See 1926.502(d)(8), 1926.502(d)(9), and 1926.502(d)(10).

Under 1926.502(d)(12)-(16), what are the strength requirements and performance limits for self‑retracting devices, lanyards, anchorages, and arresting forces?

Self‑retracting lifelines that limit free fall to 2 feet or less must sustain 3,000 pounds (13.3 kN); other SRLs and most lanyards must sustain 5,000 pounds (22.2 kN); anchorages must support at least 5,000 pounds per employee or be designed/installed under a qualified person to provide a 2:1 safety factor; personal fall arrest systems must limit maximum arresting force to 900 pounds (4 kN) with a body belt and 1,800 pounds (8 kN) with a body harness, limit free fall to 6 feet, limit deceleration distance to 3.5 feet, and have enough strength to withstand twice the potential impact energy of the permitted free fall. See 1926.502(d)(12), 1926.502(d)(13), 1926.502(d)(15), and 1926.502(d)(16).

Under 1926.502(d)(18)-(21), where should the harness attachment point be located, and what are the inspection and post‑impact requirements?

The harness attachment point should be centered on the wearer's back near shoulder level or above the head; personal fall arrest systems and components that have been subjected to impact must be removed from service immediately and not reused until inspected and found undamaged by a competent person; and systems must be inspected prior to each use for wear or damage. See 1926.502(d)(18), 1926.502(d)(19), and 1926.502(d)(21).

Under 1926.502(d)(20), what must an employer provide for workers who may be suspended after a fall?

The employer must provide for prompt rescue of employees in the event of a fall or ensure employees can rescue themselves. See 1926.502(d)(20).

Under 1926.502(d)(23), can personal fall arrest systems be attached to guardrail systems or hoists?

No — personal fall arrest systems must not be attached to guardrail systems, and they must not be attached to hoists except where other specific subparts of the standards allow it. See 1926.502(d)(23).

Under 1926.502(e)(1)-(2), what are the free‑fall and anchorage strength limits for positioning device systems?

Positioning device systems must be rigged so an employee cannot free fall more than 2 feet (0.9 m), and they must be secured to an anchorage capable of supporting at least twice the potential impact load of a fall or 3,000 pounds (13.3 kN), whichever is greater. See 1926.502(e)(1) and 1926.502(e)(2).

Under 1926.502(e)(3)-(7) and (e)(9)-(10), what connector, proof‑test, snaphook, and inspection requirements apply to positioning device systems?

Connectors for positioning device systems must be drop forged, pressed or formed steel (or equivalent), have corrosion‑resistant finishes and smooth edges, connecting assemblies must have a minimum tensile strength of 5,000 pounds (22.2 kN), dee‑rings and snaphooks must be proof‑tested to 3,600 pounds (16 kN), snaphooks must be sized or locking‑type to prevent unintentional disengagement, and systems must be inspected prior to each use with defective components removed from service. See 1926.502(e)(3), 1926.502(e)(5), 1926.502(e)(6), 1926.502(e)(7), and 1926.502(e)(9).

Under 1926.502(e)(10) and 1926.502(d)(18), can body belts, harnesses, or their components be used to hoist materials?

No — body belts, harnesses, and components are to be used only for employee protection as part of personal fall arrest or positioning device systems and must not be used to hoist materials. See 1926.502(e)(10) and 1926.502(d)(18).

Under 1926.502(d)(16) and Appendix C to Subpart M, how can employers meet the performance requirements for personal fall arrest systems for workers under 310 pounds?

If a personal fall arrest system meets the criteria and protocols in Appendix C to Subpart M and is used by an employee (including tools) weighing less than 310 pounds (140 kg), the system will be considered compliant with the performance limits in [1926.502(d)(16)]. See 1926.502(d)(16) and the note referencing Appendix C to Subpart M.

Under 1926.502(d)(6)(i)-(v) and 1926.502(e)(8)(i)-(v), what specific snaphook connections are prohibited unless the snaphook is a locking type designed for that connection?

Unless the snaphook is a locking type specifically designed for the connection, you must not engage a snaphook directly to webbing, rope or wire rope; to another snaphook; to a dee‑ring that already has another snaphook or connector attached; to a horizontal lifeline; or to any object that is shaped or sized so the keeper could be depressed and allow disengagement. See 1926.502(d)(6)(i)-(v) and 1926.502(e)(8)(i)-(v).

Under 1926.502(c)(4)(ii), what must a certification record include if the employer does not perform the safety net drop test?

If the employer demonstrates the drop test is unreasonable and uses a certification instead, the certification record must identify the net and installation, state the date it was determined the net met the clearance requirement in [1926.502(c)(3)], and include the signature of the competent person making the determination; the most recent certification must be available at the jobsite. See 1926.502(c)(4)(ii).

Under 1926.502(b) and the scaffold/fall protection Letter of Interpretation (Dec. 5, 2023), when might conveyances be treated like suspended scaffolds and require the scaffold fall protection rules?

Conveyances that are suspended by temporary guides, temporary cables, or temporary hoisting machines (or that operate with incomplete guides or temporary devices) can meet the definition of a suspended scaffold and therefore must follow fall‑protection requirements found in scaffold standards such as 1926.451(g) as well as applicable fall‑protection rules in [1926.502]; see OSHA’s interpretation clarifying that such conveyances are treated as suspended scaffolds. See 1926.502(b) and OSHA’s Letter of Interpretation, "Scaffold and fall protection clarification," (Dec. 5, 2023) at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.