EHS glossary>Safety term

The Definition of Rebar Impalement Hazard

A rebar impalement hazard is the risk of a worker falling onto or into exposed, protruding reinforcing steel and being pierced, which OSHA requires employers to guard against under 29 CFR 1926.701(b).

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Rebar Impalement Hazard definition

Definition of Rebar Impalement Hazard

A rebar impalement hazard is the risk that a worker could fall onto or into protruding reinforcing steel, commonly called rebar, and be pierced by it. Rebar often sticks up from footings, walls, columns and slabs during concrete construction, and it can also protrude horizontally from walls and forms.

Under OSHA's concrete and masonry construction standard, 29 CFR 1926.701(b), "all protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement." OSHA has explained that when the standard was revised in 1988, its scope was expanded from vertically protruding steel to all protruding steel, and that OSHA's intent is to eliminate the hazard of impalement completely.

Impalement injuries can be catastrophic or fatal, and they can happen from relatively short falls. The hazard is closely linked to fall protection and to general jobsite safety in concrete work.

Where Rebar Impalement Hazards Occur

Common situations

  • Workers on elevated decks, forms or scaffolds above vertical rebar.
  • Workers walking near footings or excavations where rebar sticks up below grade. See excavation hazard.
  • Workers tripping and falling into horizontal rebar protruding from walls or columns.
  • Workers climbing or working on rebar mats and cages.

How OSHA evaluates the hazard

The key question is whether a worker could fall onto or into the steel. OSHA has stated that horizontal rebar close to ground level would not normally pose an impalement hazard, but that protection is needed where a worker could trip and fall into horizontal rebar. Site conditions, the height of the steel and the work being done nearby all matter.

Other sharp objects

Impalement hazards are not limited to rebar. Form stakes, anchor bolts and other protruding objects can also pierce a worker who falls on them. OSHA has said that 29 CFR 1926.701(b) itself applies only to reinforcing steel, but that the same performance benchmark used for rebar covers is an appropriate criterion for impalement protection devices on other sharp objects.

Acceptable and Unacceptable Protection

Standard plastic caps are not impalement protection

OSHA memos from 1997 state that common mushroom-style plastic rebar caps were tested and do not provide protection from impalement, even from a short fall of three feet. These caps are designed to prevent scratches and cuts. They can still be used for that purpose, but they do not meet 29 CFR 1926.701(b) where an impalement hazard exists.

Performance benchmark for impalement protection

OSHA has stated that covers or troughs for rebar are adequate if they can withstand at least 250 pounds dropped from a height of 10 feet. Steel-reinforced caps and wooden troughs that meet this benchmark have been recognized as acceptable. OSHA does not approve or endorse specific products, and manufacturer test data should be checked before use.

Fall protection comes first

When workers are working at height above exposed rebar, OSHA describes fall protection or fall prevention as the first line of defense against impalement. Guarding the rebar does not replace fall protection required by other standards.

Controlling Rebar Impalement Hazards

Use the hierarchy of controls to plan protection:

  • Eliminate: sequence work so rebar is not left exposed longer than needed, or bend exposed ends over where the design allows.
  • Engineer: install wooden troughs or rated impalement caps over rows of rebar, and use guardrails or covers to keep workers from reaching exposed ends.
  • Prevent falls: use guardrails, safety nets or personal fall arrest systems for work above rebar.
  • Administer: include impalement hazards in the pre-task plan, mark hazard areas and inspect protection at the start of each shift.
  • Maintain: replace caps and troughs that are damaged or knocked off, and keep the area clear of debris that could cause trips.

A competent person should check for impalement hazards as work progresses, since rebar exposure changes daily as forms are built and concrete is placed.

Example of Rebar Impalement Hazard

On a parking structure project, a crew was building column forms next to a row of vertical rebar dowels about 4 feet tall. The dowels had orange mushroom caps on them. During a site walk, the project's safety manager noted that workers on a ladder next to the dowels could fall onto them and that the caps would not stop impalement.

The contractor replaced the mushroom caps with wooden troughs built over each row of dowels and moved the ladder work so it was not directly above the steel. The superintendent added rebar protection to the daily inspection checklist so that troughs knocked loose by equipment were replaced before work resumed.

Frequently Asked Questions: Rebar Impalement Hazard

Do orange mushroom caps protect against impalement?

No. OSHA has stated that standard plastic mushroom caps do not protect against impalement and are intended only to prevent scratches and cuts.

What OSHA standard covers rebar impalement?

29 CFR 1926.701(b) requires all protruding reinforcing steel onto and into which employees could fall to be guarded to eliminate the hazard of impalement.

Does horizontal rebar need protection?

Yes, where a worker could trip or fall into it. OSHA has said that horizontal rebar close to ground level would not normally pose an impalement hazard, but each situation must be evaluated.

What test should impalement covers meet?

OSHA has referenced a benchmark of withstanding at least 250 pounds dropped from 10 feet as appropriate for covers and troughs used for impalement protection.

Is guarding the rebar enough when working at height?

No. Where workers are exposed to falls, fall protection is the first line of defense. Rebar guarding is still needed where workers could fall onto the steel.

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