September 2018

Bending Rebar - A False Sense of Security

The topic of covering of all rebar(straight/bent) and all metal or wood stakes, falls under the category of Impalement Hazards. In §1712. Requirements for Impalement Protection, OSHA covers the topic of Protection from Reinforcing Steel and Other Similar Projections
to all work sites and locations where employees work around or over expose projections. Projections are defined as a thing that extends outward from something else. Rebar, straight or bent; vertical or horizontal, along with metal and wood stakes, falls under this category; and here is why:

 

On December 5, 2014, In an effort to observe and evaluate impalement hazard (due to a notification of an unsafe practice of bending rebar dowel ends was being used in lieu of appropriate protective covers), drop tests on rebar were conducted at the Ironworkers Regional Training Facility in Benicia, California.  The Ironworkers International Union, officials from the California OSHA Research and Standards Unit, Western Steel Council, and other reinforcing steel stakeholders observed test-drops to evaluate and document the drop-test results.

 

After observing the test-drops and documenting results, Mr. Eric Berg, Principal Safety Engineer of the Research and Standards Unit for California OSHA provided an official letter of clarification to the Ironworkers International.  In Mr. Berg’s letter he stated: “Cal-OSHA does not accept the bending or hooking of rebar as an acceptable method of impalement protection..  An employer that bends or hooks rebar for employee impalement protection instead of providing approved covers or troughs is in violation of Title 8, section 1712.  Such an employer would be placing their employees at risk of serious injury”.

 

§1712 becomes applicable to all work sites and locations where employees work around or over exposed, projecting, reinforcing steel or other similar projections.

 

If the impalement hazard exists at or above working level, exposed protruding reinforcing steel or other similar projections, shall be protected against the hazard of impalement by guarding all exposed ends that extend up to 6 feet above grade or other work surface, with protective covers, or troughs.

 

Employees working above grade or any surface and exposed to protruding reinforcing steel or other similar projections shall be protected against the hazard of impalement. Protection shall be provided by:

 

  1. The use of guardrails, or
  2. Approved fall protection systems meeting the design requirements of Article 24, or
  3. Protective covers

 

What are acceptable forms of “Protective Covers”?

 

  1. Plastic Covers*, 4” x 4” Square caps; or Circular Caps with a diameter of 4 ½”.
  2. Troughs made of wood, plastic or 14 gauge steel in accordance with Appendix Plate C-25.

 

Job built protective covers shall be designed as specified by an engineer currently registered in the State of California, unless the trough is designed according to the Exception**. Copies of the engineer drawings shall be made readily available to OSHA upon request. Job-built wood protective covers and troughs shall be constructed of at least “Standard Grade” Douglas Fir. Job-built protective covers, except for troughs as depicted in Appendix Plate C-25, shall, at the minimum, be capable of withstanding the impact of a 250-pound weight dropped from a height of 10 feet without penetration failure of the cover.

 

*Manufactured protective covers made on or after October 1, 2000 shall meet the testing requirements of Section 344.90

**Exception: Job-built troughs as depicted in Appendix Plate C-25 may be used as a substitute for engineered or manufactured protective covers when employees are working at heights not greater than 6 feet above grade or other working surface.

 

Appendix Plate C-25

 

 “An employer that bends or hooks rebar for employee impalement protection instead of providing approved covers or troughs is in violation of Title 8, section 1712.  Such an employer would be placing their employees at risk of serious injury.”

-Eric Berg, Principal Safety Engineer of the Research and Standards Unit for Cal-OSHA