The standard's definition of a guardrail system is: "a vertical barrier, consisting of, but not limited to, Toprails, midrails , and posts, erected to prevent employees from falling off a. 62 m) of lateral travel for employees. This letter constitutes OSHA’s. Previous OSHA regulations fell short of addressing many operations in which. * The CPSC recommends that. 62 cm). 4 cm) in height. Guardrails should be inspected per the manufacturer specifications or a qualified person’s requirements. 26 (b) (2)OSHA requirements are set by statute, standards and regulations. 1915. If you need additional information, please contact us by fax (202-693-1689) at: U. 1. Stairs other than fixed industrial stairs have different requirements for being equipped with standard stair railing or standard handrails when compared to the requirements of fixed industrial stairs. 10(a)] All subcontractors who agree to perform any part of the labor or material requirements of a contract. OSHA Handrail Standards. Wherever guardrail protection is required, the following standards shall be adhered to except that other types and arrangements of guardrail construction will be acceptable where the height, surface and end projection of the top rail complies with the standard specifications and the closure of the vertical area between the top rail and floor, platform,. You will still be OSHA compliant without safety harnesses if the guardrail is adequate, but we recommend using them when: The scissor lift work platform is higher than six feet; wearing a harness is part of the scissor lift manufacturer’s instructions; and. Fall protection consists of either personal fall arrest systems or guardrail systems meeting OSHA requirements. Since that time, OSHA has received many questions and requests for interpretation of the requirements for handrails and stair rail systems. OSHA requirements are set by statute, standards and regulations. 1052 (c) (2) Winding and spiral stairways shall be equipped with a handrail offset sufficiently to prevent walking on those portions of the stairways where the tread width is less than 6 inches (15 cm). S. OSHA requirements are set by statute, standards and regulations. See the following elevated work platform OSHA requirements in 29 CFR 1910. Federal OSHA: requires a 200 pound point load. 500 (f) (l) (vi) provides for the utilization of types, sizes and arrangements of railing construction provided they meet the conditions established in sub-paragraph a thru d. 555 (a) (1) Means for stopping the motor or engine shall be provided at the operator's station. 112 (a) (1) Vehicle curbs, bull rails, or other effective barriers at least six inches (15. "The employer must ensure each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1. There are 29 OSHA-approved State Plans operating state-wide occupational safety and health programs. 46 m 2) for each person. 1-2007, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace Floor, Wall and Roof Openings; Stairs and Guardrail Systems. Guardrail systems used at hoist areas: A removable guardrail section, consisting of a top rail and midrail, must be placed across the access opening between guardrail sections when the hoist is not being America's Safest Companies. 24 cm) in height shall be provided at the waterside edges of aprons and bulkheads, except where vehicles are prohibited. The Safety Boot guardrail system is designed for this specific purpose, and when paired with the material listed above and properly fastened to the substrate, this bracket system makes it very easy to meets the OSHA requirements. These scaffolding safety guidelines, which come directly from OSHA standards, are explored in greater depth in the sections below. On outside plaza, patio, and garden areas, alternate means of protection are acceptable if the same degree of safety is provided. 29 (b) (1) The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface. Safety Tips for Pedestrians. 29 (b), ladders and hatches are required to be secured with a self-closing safety gate and safety-compliant railing. Field Information Memorandum #75-40, June 2, 1975, Subject: Guarding Floor and Wall Openings and Holes - General Industry (copy enclosed) covers situations where. In addition, Section 5 (a) (1) of the Occupational Safety and Health (OSH) Act, often referred to as the General Duty Clause, requires employers to "furnish to each of his employees employment and a place of employment which are free from recognized. Cleat means a ladder crosspiece of rectangular cross section placed on edge upon which a person may step while ascending or descending a ladder. 1926. Training and qualification of each roadway worker in charge. These include: The top edge height of top rails, or equivalent guardrail system members, are 42 inches (107 cm), plus or minus 3 inches (8 cm), above the walking-working surface. This is the first OSHA requirement to be aware of. Under 29 CFR 1926. 3 OSHA standards permit fall arrest systems to be anchored to scissor lifts as long as the anchorage requirements in §1926. However, OSHA 1910. Handrail height, measured above stair tread nosings, or finish surface of ramp slope, shall be uniform, not less than 34 inches (864 mm) and not more than 38 inches (965 mm). 82 cm ±7. 1910. Access to wing walls from floors of dry docks shall be by ramps, permanent stairways or ladders meeting the applicable requirements of § 1915. According to OSHA guardrail requirements, a railing is required when working at 4 feet or more. Purpose of a Guardrail . 71(j) (1) and (2). GPO Source: e-CFR. 1-2007, Safety. 10(a)] All subcontractors who agree to perform any part of the labor or material requirements of a contract. Training and qualification of each roadway worker in on-track safety for operators of roadway maintenance machines. 3. OSHA is therefore proposing to clarify that the top rail of stair rail systems installed prior to January 17, 2017, can serve as a handrail if that top rail is 30 to 38 inches in height and meets the other handrail requirements of paragraph (f). 503(a) and (c). Details are at GUARDRAIL CODES & STANDARDS - this article. If you choose to use a guardrail system, you must comply with the 10 OSHA provisions listed below. OSHA 1910. 502). This subpart applies to all general industry workplaces. The safety ledge shall be designed to carry a live load of 100 pounds per square foot. 7 - Definition and requirements for a nationally recognized testing laboratory. 23(e)(5)(iii), states in part: "The length of brackets shall be such as will give a clearance between handrail and wall or any projection thereon of at least 3 inches. Railings & Guardrail. With both standards, OSHA deems guardrail compliant under the following conditions: Vertical height of 42 inches. Wherever guardrail protection is required, the following standards shall be adhered to except that other types and arrangements of guardrail construction will be acceptable where the height, surface and end projection of the top rail complies with the standard specifications and the closure of the vertical area between the top rail and floor, platform,. An OSHA-approved state plan must have safety and health requirements at least as effective as those of Federal OSHA and must adopt comparable state they satisfy all of the guardrail requirements. 1. Guardrail systems that are not at least 42 inches high can be cited as a technical. , an opening in the roof of a building through which persons may fall. 29(b) and its subparts. Guard rail, guardrails, or protective guarding, [1] in general, are a boundary feature and may be a means to prevent or deter access to dangerous or off-limits areas while allowing light and visibility in a greater way than a fence. 500 (f) (1) (vi) provides the specification criteria for a standard railing exception as follows: (vi) Other types, sizes, and arrangements of railing construction are acceptable, provided they meet the following conditions: (a) A smooth-surfaced top rail at a height above floor, platform, runway, or ramp level of approximately 42. 23(e)(2) A stair railing shall be of construction similar to a standard railing, but the vertical height shall be not more than 34 inches nor less than 30 inches from an upper surface of top rail to the surface of tread in line with the face of the riser at the forward edge of the tread. The top rails on guardrails must not be built from steel or plastic banding. 500(d)(1) and 29 CFR 1926. OSHA's guardrail height requirements include a variance of plus or minus 3 inches. OSHA requirements are set by statute, standards and regulations. The final rule covers all construction workers except those erecting structural steel. 502 (b) (3), (4), and (5). The guardrails need to include a mid rail halfway between the top rail and the ground, at around the 21" mark for a standard height rail. Falls from heights and on the same level (a working surface) are among the leading causes of serious work-related injuries and deaths. 25 inches thick. The final rule requires that employers must provide guardrail, safety net, or personal fall protection systems to protect workers from falling off unprotected sides/edges of residential roofs that are four feet or more above a lower level. A guardrail is a safety railing or barrier located along a horizontal surface such as a balcony, deck, or porch. 5. Your Guardrail Compliance Checklist. Field Information Memorandum #75-40, June 2, 1975, Subject: Guarding Floor and Wall Openings and Holes - General Industry (copy enclosed) covers situations where. Under 29 CFR 1926. Prevent water from pooling and damaging your roof by using a lightweight PVC counterweight to give your team all the protection they. Railings and Guardrails – OSHA handrail requirements 390 | IBC handrail 320 Balusters – OSHA 1910. 48 (a) (2) An elevated walkway with guardrail or equivalent means of protection shall be provided where employees cross over moving conveyors, and suitable guarding shall be provided when employees pass under moving conveyors. 75(g) Catwalks on stiles of marine railways shall be no less than 20 inches wide and shall have on at least one side a guardrail and midrail meeting the requirements of § 1915. 112(c)(1) on both sides and that are not less than 30 inches (76. , Washington, D. the system meets the guardrail. Install guardrail systems along all open sides and ends of platforms. Under §1910. Minimum width of 22”. Passive fall protection protects many vulnerable areas and provides safety for all people, not just active employees on a job site. [29 CFR 1926. Though the terms guardrails and handrails are. 25 inches. Mr. With both standards, OSHA deems guardrail compliant under the following conditions: Vertical height of 42 inches. 1052 (c) (3) The height of stairrails shall be as follows: 1926. The three major components of a strong post barrier are the rail, posts, and blockouts. 2. Be sure to check with your code official regarding your area’s guardrail height requirements. OSHA 1910. Minimum width of 22”. 451–1926. When a forklift truck is used for lifting personnel on a secured safety platform with a guardrail to. 452(y)] 1910. This letter constitutes OSHA's interpretation of the requirements discussed. 502(d) and the requirements of the scaffold standard are met. Docket S-775 Safety Standards for Steel Erection (proposed January 26, 1988, 53 FR 2048, final rule published January 18, 2001 66 FR 5196). OSHA requirements are set by statute, standards and regulations. The agency’s standard on walking-working surfaces for general industry (1910 Subpart D) was developed to help prevent dangerous falls from height or slips and trips on the same level (working surface). 91-596, encourages states to develop and operate, under OSHA guidance, their own job safety and health plans. The area shall be located on the same lot not less than 50 feet (15 240 mm) away from the building requiring egress. a worker leaves the elevated aerial lift work platform. Office listed on the back cover of this guide. 1926. 82 cm ±7. Figure D-11-- Guard Rail Systems. The following definitions apply in this subpart: Alternating tread-type stair means a type of. 451 (a) (5). Maximum 12′-7″ vertical height (rise) for a flight of stairs. 23 & 1926. ”. This 28-page document covers the basics of fall protection systems, equipment, and regulations, as well as practical tips and examples for different work scenarios. Cal OSHA has a force requirement of 20 pounds per linear foot along the entire rail system. 3. According to OSHA guardrail requirements, a railing is required when working at 4 feet or more. Specifically, we will consider the use of certain physical barriers that fail to meet the criteria for a. 1926. 5 inches (24 cm); and. S. 71 (d) (2) All vertical and horizontal members shall be fastened together with a coupler or locking device which will form a positive connection. Scaffolding. Surface requirements: OSHA standard 1926. 452, . 502(b)(6) requires that guardrail components have smooth surfaces to prevent snagging of clothing and injuries from lacerations and punctures. The fall protection safety requirements for residential construction should be the same as those for commercial construction. Guardrail systems and their use shall comply with the following provisions: 1926. Safety Railing and Guardrail Systems. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N. 500-1926. When a guardrail system is used, the guardrail height must be increased in height equal to the height of the stilts. The safety ledge shall be designed to carry a live load of 100 pounds per square foot. 501(b)(13), workers engaged in residential construction six (6) feet or more above lower levels must be protected by conventional fall protection (in other words, guardrail systems, safety net systems, or personal fall arrest systems) or other. 1 - Purpose and scope. . 2. Your inquiry concerns the guardrail requirements for suspension scaffolds. 29 (b) (1): The top edge height of top rails, or equivalent guardrail system. They must be protected by guardrail systems, safety net systems, or personal fall arrest systems, or They must work in a controlled access zone (CAZ) . Spiral stairs must meet the vertical clearance requirements. 26. 651 (d) Exposure to vehicular traffic. It also must be able to withstand 50lbs being. Here are some basic pieces of information to bear in mind when constructing a handrail to comply with OSHA Standards. They must be protected by guardrail systems, safety net systems, or personal fall arrest systems, or They must work in a controlled access zone (CAZ) . Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this section (§ 1926. However, guard rail’s role in protecting the loading dock area extends. 1(2) of O. Under 29 CFR 1926. 5 - Applicability of standards. 451(g). 213/91, the highest being a travel restraint system that meets the requirements of section 26. In these cases, a handrail must be mounted on at least one side if the stairway is less than 44 inches wide. 451(g)(4). Compliance requirements for the use of U-bolt-type cable clamps in horizontal lifelines. According to OSHA 1910. See the following elevated work platform OSHA requirements in 29 CFR 1910. Finally, remember handrails must be between 30 and 38 inches as measured from the leading edge of the stair tread. 23(c)(1) states that “e very open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides. This ribbon of rail acts to capture impacting vehicles and to. More information about the OSHA Standards and agricultural safety is available at the following Web sites:1926. 5 inches (24 cm); and. 30″ to 38″. Guardrail systems and their use shall comply with the following provisions: – 1926. 1431 (b) (2) Exceptions: A personnel platform is not required for hoisting employees: 1926. Under §1926. Particular industries require certain specifications on safety railing systems. OSHA Standard. Guardrail is required for any platform 4 feet. A guardrail is, first and foremost, a safety barrier intended to shield a motorist who has left the roadway. Top rail at 42” to 45” and a midrail. Handrail height, spacing, and incline are all addressed by the International Residential Code (IRC) and the International Building. The width of ramps that are part of a means of egress may further be determined by applicable life safety codes and requirements for minimum exit widths greater than 36″. 5" tall, with no more than a 1/4" gap at the bottom. The top rail of the handrail must be a minimum of 42" [ref. ) from the surface of the walking area. The spacing of vertical posts differs between the two sets of code as well. 1917. 29 Fall Protection Systems and Falling Object Protection-Criteria and. The top edge height may exceed 45 inches (114 cm). 3) the top must not fail and may deflect to a point no lower than 39 inches above the floor when a 200 pound load is imposed on it in a downward or outward. 25 (b) (1) Handrails, stair rail systems, and guardrail systems are provided in accordance with § 1910. 5". Construction Safety and Health Standards, Subpart L, 29 CFR 1926. The use of wire ropes as top rails and intermediate rails of guardrail systems used for perimeter. OSHA requirements for guardrails are also quite stringent. 501 ), any worker constructing a leading edge 6 feet or more above a lower level “must be protected by guardrail systems, safety net systems, or personal fall arrest systems. This ribbon of rail acts to capture impacting vehicles and to. If such a railing is not possible then the workers must be protected by a fall protection device such as a personal fall arrest system or a safety net. 1053 (a) (4) (i) The minimum clear distance between the sides of individual-rung/step ladders and the minimum clear distance between the side rails of other fixed ladders shall be 16 inches (41 cm). 28 includes unprotected sides and edges. OSHA 1910. American National Standards Institute (ANSI) ANSI/ASSE A1264. 4. Under §1926. We will now cover some additional areas. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. The standard's definition of a guardrail system is: "a vertical barrier, consisting of, but not limited to, Toprails, midrails , and posts, erected to prevent employees from falling off a. 29: 29 CFR 1910. Where the guardrail requirements of subsections (a) and (b) are impracticable due to machinery requirements or work. According to OSHA: When workers installing solar panels are exposed to fall distances of six feet or more, they need to be. 2. CDOT’s guardrail standards are defined in: • Standard Plan . According to OSHA’s construction fall protection standard ( 29 CFR 1926. This regulation states that, “Guardrail systems. (2) The landing length shall be a minimum of 60 in (1525 mm) clear. 1052(c)(7) Dear Mr. balusters) can be a maximum of 19 inches apart. Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate. The area shall be permanently maintained and identified as a safe dispersal area. Section 1910. Federal OSHA says the height of the top rail can be between 39 and 45 inches, while Cal-OSHA does not permit top rails to be so low. 29 (b): "Fall protection systems and falling object protection -- criteria and practices. [29 CFR 1926. The Occupational Safety and Health Administration requires that employers provide fall protection for employees working at heights over 4 feet. 1917. The stairway is over 88 inches in width. Occupational Safety and Health Administration 200 Constitution Ave NW Washington, DC 20210 1-800-321-OSHA 1-800-321-6742. As a reference, OSHA's fall protection standards would require a safety net used in this scenario to extend 8 feet from the edge of the walking/working surface. Haydl: This is in response to your letter of June 24, 2004 regarding the Occupational Safety and Health Administration (OSHA) standards for heights for stair rails and handrails and corresponding building code requirements. 23 (a) (4), therefore, requires that skylights in the roof of buildings through which persons may fall while walking or working shall be guarded by a standard. The IBC code for structural design has some very specific requirements for deck stairs: Stair rails on decks should be between 34 inches and 38 inches high, measured vertically from the nose of the tread to the top of the rail. 2Height. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Our portable guard railing is 42 inches tall. When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria. The California Division of Occupational Safety and Health (Cal-OSHA) has specific requirements for rooftop railing protection under its fall protection standards. 10. or more in size. In work situations where a standard railing is not practical, safety belts and lanyards attached to a structural member or static line meeting the requirements of 29 CFR 1926. 50 inches (38mm). 8 m) or more above a lower level shall be protected from falling by the use of guardrail systems,. 1926. [29 CFR 1926. A guardrail is shown by the red arrows in our photo at left. Similarly, OSHA's general industry standards related to guardrail systems (Subpart D Walking-Working Surfaces, specifically 29 CFR 1910. Whenever guardrail systems are used, they must meet the definition of a "guardrail system" in §1926. OSHA Requirements. 34 (copy attached), OSHA standards are minimum safety requirements; employers may apply more protective requirements. Use internal couplings, Type 18-7, to maintain continuity. 500, Guardrails, handrails & guards. NATIONAL STANDARDS FOR THE PHYSICAL INSPECTION OF REAL ESTATE U. 36″ minimum. Standard Interpretations are letters or memos written in response to public inquiries or field office inquiries regarding how some aspect of or terminology in an OSHA standard or regulation is to be interpreted and enforced by the Agency. Top rail and midrail dimensions: Must be at least 0. If the top of a tank is not a "platform" under the analysis called for in OSHA's guidance document, the guardrail requirements of that standard would not apply. 22 m) or more in depth so as to require no more than 25 feet (7. Suite 301 Chadds Ford, PA 19317. A guardrail is a safety railing or barrier located along a horizontal surface such as a balcony, deck, or porch. This letter constitutes OSHA's interpretation of the requirements discussed. Maximum 7-3/4 inch stair riser height. Advanced Notice of Proposed Rules 64:38077-38086, (July 14, 1999). Federal OSHA: requires a maximum single rail length of 10 feet. The top edge height may exceed 45 inches (114 cm), provided the guardrail. If the employer chooses to use a guardrail system, he must comply with the following provisions: Top edge height of top rails, or equivalent guardrail system members, must be between 39 and 45 inches above the. 500, Guardrails, handrails & guards. OSHA gives you some flexibility on this. 1926. 2. Mounting guardrail to your existing parapet is a simple and effective way to secure your rooftop. 1926. Depending on the type of scaffold, each employee more than 10 feet above a lower level must be protected from falling either by a personal fall arrest system, a. 28 of OSHA’s standard on walking-working surfaces (1910. Oct 27 2017. 450(b) 1926. OSHA standard 1926. Scope . ”. The top edge of the guardrail should be 42 inches above the walking/working surface. Guardrail systems used at hoist areas: A removableAmerica's Safest Companies. 501(b)(1), even where there is a permanent guardrail with a 36-inch top rail that, pursuant to STD 01-01-010, is acceptable for. Guard Height. Whenever guardrail systems are used, they must meet the definition of a "guardrail system" in §1926. Department of Labor, Occupational Safety and Health Administration (OSHA) under the general industry standard 29 CFR 1910. According to the IBC code, guard rails are required when there is a difference of 30 inches or greater between two upper and lower surfaces. All other guardrail systems and their components shall meet the following. Scope and definitions. Guardrail Requirements vs. TO: ALL AREA DIRECTORS Paragraph 1926. 451(g). 5 inches (24 cm); ( 3) Have a minimum tread depth of 9. Some areas require taller guardrail. The job-built guardrail systems were evaluated to determine whether they complied with OSHA regulation 29 CFR 1926. Guardrail requirements are covered under OSHA 1910. HEALTH AND SAFETY DETERMINATION: Moderate The. Guardrail systems. Railing height for guard rail. OSHA requirements are set by statute, standards and regulations. WASHINGTON, DC – The U. Department of Labor’s Occupational Safety and Health Administration is proposing updates in the handrail and stair rail system requirements for its general industry, Walking-Working Surfaces standard. OSHA requires that a competent or qualified person inspect each knot in a lanyard or vertical lifeline to ensure it meets the strength requirements in § 1910. (4) If a doorway is located at a landing, then the. OSHA has issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems to better protect workers in general industry from these hazards by updating and clarifying standards and adding. The employer must ensure: 1910. A handrail and a wall or other surface adjacent to the handrail shall be free of any sharp or abrasive elements. 1052(c)(7) Dear Mr. California Code of Regulations, Title 8, Section 3214. This letter constitutes OSHA's interpretation of the requirements discussed. 9 (1) A fixed ladder installed after the day of the coming into force of this section shall be designed, constructed and installed in accordance with the requirements of ANSI Standard A14. 8. 502(b)(3) requires railing systems meet a 200 pound concentrated load test. Any working surface 4 feet or higher must be protected with guardrails on all sides at least 42″ tall and have to withstand 200 pounds of force. 1910. Maximum 12′-7″ vertical height (rise) for a flight of stairs. 6) (1926. handrails (1) A stairway shall have a handrail on at least one side, and if 1 100 mm or more in width, shall have handrails on both sides. Occupational Safety and Health Standards; Subpart: 1910 Subpart D; Subpart Title: Walking-Working Surfaces; Standard Number: 1910 Subpart D Title:. The employer must ensure: 1910. Objects which have fallen into the safety net, such as scrap pieces, equipment, and tools, must be removed as soon as possible from the net and at least before the next work shift. 453, and . Here is a summary to make it easy for you: The top rail must be 42 inches in height, give or take 3 inches. The safety ledge shall be designed to carry a live load of 100 pounds per square foot. Based on the relevant OSHA standards 1910. This appendix serves as a non-mandatory guideline to assist employers in complying with these requirements. This threshold differs from 29. Purpose of a Guardrail . The Guardrail height shall not be less than 36 inches above the walking surface. Regarding roof protection from falls for work on low-slope roofs, OSHA has general industry (1910) regulations based on various distances: Work done less than 6 feet from the roof edge:For other scaffolding guardrail requirements, see 29 CFR 1926. 555 (a) General requirements. OSHA addressed ten issues, most of which have been raised by interested parties who believe that alternatives to some of the existing fall protection rule's provisions should be permitted. Stair railing height requirements are derived from handrail code—a model building code that communities can adopt and adapt as needed. Handrail safety is just as important as the safety of the staircase itself. Guardrail systems. (3) For structural steel railings: posts, top rails, and. Cal OSHA requires a maximum single rail length of 8 feet. All mesh crossings must be secured to prevent enlargement of the mesh opening, which must be no longer than 6. 5 inches for stands with a top height of 4 feet or more, 36 inches for stands with a top. Use a non-penetrating guardrail that doesn’t mount to any structure on your building. 1917. A handrail and a railing as applied to fixed industrial stairs have two different meanings. Most loading docks are 48-52” tall, but we do see instances of docks a few inches shy of four feet–say 46”. 23 (a) (2): Every ladderway floor opening or platform shall be guarded by a standard railing with standard toeboard on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a. Understand the requirements of OSHA’s Fall Protection standards at 29 CFR 1926, Subpart M, to protect workers exposed to falls six feet or more above a lower level. 25 (b) (2) Vertical clearance above any stair tread to any overhead obstruction is at least 6 feet, 8 inches (203 cm), as measured from the leading edge of the tread. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. 502(b)(6) requires that guardrail components have smooth surfaces to prevent snagging of clothing and injuries from lacerations and punctures.