EHS glossary>Safety term

The Definition of Impalement Hazard

An impalement hazard is the risk that a worker falls onto or into protruding rebar, stakes or other sharp projections, which OSHA requires employers to guard or eliminate.

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Impalement Hazard definition

Definition of Impalement Hazard

An impalement hazard is the risk of a worker falling onto or into a sharp or protruding object that can pierce the body. On construction sites, the most common source is vertical reinforcing steel (rebar) sticking out of footings, walls and columns. Other sources include form stakes, anchor bolts, dowels, lightning rods and cut-off pipe or conduit.

Impalement injuries are often catastrophic even from short falls. A worker who trips while walking past a row of rebar, or who falls a few feet from a ladder or scaffold, can suffer deep puncture wounds to the abdomen, chest or groin. Preventing impalement means preventing falls onto projections and guarding the projections themselves.

OSHA Requirements for Impalement Protection

Federal OSHA

Under 29 CFR 1926.701(b), all protruding reinforcing steel onto and into which employees could fall must be guarded to eliminate the hazard of impalement. This is a performance standard, so it does not prescribe a specific device. OSHA has said in interpretation letters that protective covers or wooden troughs capable of withstanding at least 250 pounds dropped from a height of 10 feet are generally adequate.

OSHA has also warned that the small, mushroom-style plastic rebar caps commonly seen on job sites do not provide impalement protection. They may help prevent scrapes and minor cuts, but testing showed they fail even in short falls. Other sharp objects can be cited under OSHA's general housekeeping rules and the General Duty Clause where they create a recognized hazard.

California

California's Title 8, Section 1712 sets more detailed requirements. It requires impalement protection for workers at grade and working above exposed projections, and it includes specific testing and approval rules for protective covers. Manufactured covers must be approved and marked, and covers may not be relied on where the fall height to the top of the cover exceeds 7 1/2 feet unless they are designed for the higher impact.

Controlling Impalement Hazards

Prevent the Fall First

When workers are above exposed rebar, OSHA's position is that fall protection is the first line of defense. Guardrails, covers and personal fall arrest systems keep workers from reaching the projections in the first place. See fall protection.

Eliminate or Guard the Projection

  • Bend it over: Where design allows, rebar can be bent so the ends are no longer pointing up, which removes the hazard.
  • Use rated covers: Steel-reinforced caps rated for impalement protection can cover individual bars.
  • Use troughs: Wooden or manufactured troughs cover a row of bars and spread the impact load.
  • Remove unneeded stakes: Pull form stakes and temporary pins as soon as they are no longer required.
  • Plan work sequence: Schedule tasks so workers are not walking or working next to exposed bars longer than necessary.

Consider Every Exposure

Exposure is not limited to falls from height. A worker walking at grade can trip onto low rebar, and a worker on a ladder near a footing can fall a few feet onto it. Look at all nearby work, including ladders, scaffolds, trenches and walkways, during pre-task planning.

Example of Impalement Hazard

A concrete contractor is pouring footings for a commercial building. Vertical dowels stick up about 3 feet from the footings along a walkway the crew uses to move between forms. The bars are fitted with mushroom-style plastic caps. During a site walk, the safety manager points out that the caps would not stop impalement if a worker tripped onto them.

The crew replaces the caps with wooden troughs along the walkway and steel-reinforced impalement covers on isolated bars near the ladder access to the formwork. The foreman also reroutes foot traffic away from the dowels and adds impalement protection to the daily pre-task plan checklist.

Frequently Asked Questions: Impalement Hazard

Do mushroom rebar caps meet OSHA requirements?

Not for impalement protection. OSHA has stated that standard mushroom-style plastic caps do not protect against impalement and should not be relied on for that purpose.

What does OSHA consider adequate impalement protection?

OSHA has said protective covers or troughs that can withstand at least 250 pounds dropped from 10 feet will eliminate the hazard in most cases. Bending rebar or preventing falls onto it are other options.

Is impalement protection needed if rebar is low to the ground?

It depends on the exposure. Low rebar along walkways or near ladders can still cause impalement in a trip or short fall, so it should be assessed and guarded where needed.

Does impalement protection apply to things other than rebar?

Yes. Stakes, anchor bolts, pipe stubs and other sharp projections can also create impalement hazards and should be guarded or removed.

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