Rebar Impalement Caps - Cal/OSHA

Federal OSHA's rebar rule is a single sentence: protruding reinforcing steel that employees could fall onto or into must be guarded to eliminate the hazard of impalement. It says what has to happen, not what the guard has to be. California's rule, Title 8, Section 1712, spells it out: which workers need which protection, how big a cover must be, how it must be tested, how it must be marked, and the fall height above which a cover alone is not allowed. This Cal/OSHA Rebar Impalement Protection Toolbox Talk covers those California specifics.

Where the boundary of this talk sits#

This talk covers what Section 1712 and its testing section, Section 344.90, require. The full control sequence — prevent the fall, bend or clear the steel, then cover — belongs to the impalement protection and rebar caps talk.

The anchor#

Here is the distinction that carries this whole talk: in California a rebar cover is not "any cap in the bin" — a manufactured cover must carry its maker's mark and a California Approval Number and be made to pass the Section 344.90 drop test, a job-built cover needs a drawing from a California-registered engineer kept at the site, every cover must present at least a 4-inch by 4-inch square face or, if round, a 4½-inch diameter, and covers alone are not allowed where the fall to the top of the cover exceeds 7½ feet unless they are designed for it — so the question on a California deck is not "is the rebar capped?" but "is it capped with something the rule would recognize, at a height where a cap is allowed to be the answer?"

Who is covered, and how#

Section 1712(a) applies to all work sites and locations where employees work around or over exposed, projecting reinforcing steel or other similar projections. The rule then splits protection by where the worker is.

Working at the same level as the steel. Under Section 1712(c)(1), employees working at grade, or at the same surface as exposed protruding reinforcing steel or similar projections, are protected by guarding all exposed ends that extend up to 6 feet above grade or other work surface, with protective covers or troughs. That covers the worker who trips onto a starter bar along a walkway.

Working above the steel. Under Section 1712(c)(2), employees working above grade or any surface and exposed to protruding reinforcing steel must be protected by guardrails, by approved fall protection systems meeting the design requirements of Article 24, or by protective covers that meet subsection (d).

The height limit on covers. Section 1712(c)(3) says protective covers shall not be used to protect against impalement where the maximum height of fall exposure, to the top of the protective cover, exceeds 7½ feet, unless the covers meet subsection (d)(4)(D). Above that height, the answer is guardrails or fall protection, or a job-built cover designed and tested for the higher fall.

What a cover has to be#

Section 1712(d) sets the specifications.

• Material: wood, plastic, or other materials of equal or greater strength.
• Size: a minimum 4-inch by 4-inch square surface area, or if round, a minimum diameter of 4½ inches.
• Manufactured covers: approved as provided in Section 1505 and legibly marked with the manufacturer's name or logo. Covers manufactured after October 1, 2000, must meet the testing requirements of Section 344.90.
• Job-built covers: designed as specified by an engineer currently registered in the State of California, with a copy of the engineering drawings kept at the worksite and made available to the Division on request. Job-built wood covers and troughs must be made of at least Standard Grade Douglas Fir under the grading rules the section names. Except for the Plate C-25 troughs, job-built covers must at minimum withstand the impact of a 250-pound weight dropped from 10 feet without penetration failure, and the drop test must be modified where fall heights greater than 7½ feet are anticipated.

There is one exception for simple troughs. Job-built troughs as depicted in Appendix Plate C-25 may be used instead of engineered or manufactured covers when employees are working at heights not greater than 6 feet above grade or other working surface.

The drop test#

Section 344.90 is the test manufactured covers must pass. It uses a 250-pound bag of dry sand, with less than 10 percent moisture by weight, dropped from 10 feet. The bag is generally round, 36 to 42 inches around. Rebar covers are tested three times, with a new cover for each test; troughs are tested four times, with a new trough each time. Troughs must be at least 4 inches wide. Passing is verified by a person, firm, or entity with appropriate registered-engineering competence, or by a person, firm, or entity independent of the manufacturer with demonstrated competence in that kind of evaluation.

Section 344.90 also requires each cover to be marked with its model number or trademark, its California Approval Number issued under Sections 1712 and 1505, and its size designation. That marking is what ties a cover on the deck to a product that passed the test. An unmarked cap, a cut piece of plastic pipe, or a cap from an unknown source cannot show that.

California versus federal#

The federal rule, 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. It is a performance standard: it does not set a cover size, a test, a marking requirement, or a height limit. California's Section 1712 sets all four, and it separates workers at the same level from workers above the steel.

Where the duty sits#

8 CCR 1712 carries the California duty: (a) scope; (b) definitions of job-built, protective covers, and troughs; (c) protection at grade up to 6 feet, protection above grade by guardrails, fall protection, or covers, and the 7½-foot limit on covers; (d) materials, size, marking, testing, and job-built engineering. 8 CCR 344.90 sets the drop test. For contrast, federal 29 CFR 1926.701(b) is a one-sentence performance standard.

What can go wrong?#

• A deck crew caps a mat of dowels with unmarked caps from the bottom of a bucket.
• Covers are used as the only protection for workers on formwork 12 feet above a wall of vertical bar.
• A foreman builds a wooden trough cover with no engineer's drawing, for work 9 feet above the steel.
• Starter bars along a walkway are left uncovered because they're "only knee high."

How do we manage this properly?#

• Guard at grade — cover or trough every exposed end up to 6 feet above the working surface.
• Above the steel, start with guardrails or fall protection — covers only where the rule allows them.
• Respect 7½ feet — no covers as the only protection above that fall height unless engineered for it.
• Use marked, tested covers — model or trademark, California Approval Number, and size on every cover.
• Engineer job-built covers — California-registered engineer, drawings at the site.
• Check the size — 4 by 4 inches square or 4½ inches round, minimum.

Before you start#

Walk the rebar with the crew. For each area, ask whether workers are at the same level as the steel or above it, and how far they could fall onto it. Pick up a cover and look for its California Approval Number.

Talk it over#

• Where on this job could someone fall onto exposed rebar?
• Would you know a compliant cover from an unmarked one?
• Where is the fall height to the top of the covers more than 7½ feet?

The bottom line#

California's impalement rule is a specification, not just a goal. Guard exposed ends up to 6 feet above the working surface for workers at the same level. Protect workers above the steel with guardrails, fall protection, or compliant covers. Use covers at least 4 by 4 inches or 4½ inches round, marked by the manufacturer and made to pass the 250-pound, 10-foot drop test, or job-built to a California engineer's drawing. And do not rely on covers alone where the fall to the top of the cover is more than 7½ feet.

Frequently asked questions about Cal/OSHA rebar impalement protection#

When are rebar covers not enough?

Under Section 1712(c)(3), protective covers may not be used where the maximum height of fall exposure to the top of the cover exceeds 7½ feet, unless job-built covers are designed and tested for the higher fall under subsection (d)(4)(D). Otherwise, workers above the steel need guardrails or fall protection.

Download the Cal/OSHA rebar impalement protection toolbox talk PDF#

Download this Cal/OSHA Rebar Impalement Protection Toolbox Talk as a printable PDF in English and Spanish, and walk the rebar with it before the next pour.

Related toolbox talks#

• Impalement Protection and Rebar Caps
• Formwork Safety
• Guardrails
• Fall Protection

Sources#

• Cal/OSHA, Title 8 CCR §1712 — Requirements for Protection Against Impalement ((a) scope; (b) definitions; (c)(1) at grade or same surface, guard exposed ends up to 6 ft with covers or troughs; (c)(2) above grade, guardrails, Article 24 fall protection, or covers; (c)(3) covers not used where fall to top of cover exceeds 7½ ft unless (d)(4)(D) met; (d)(1)–(3) material, 4 in by 4 in or 4½ in round, manufactured covers approved per §1505 and marked, post-October 1, 2000 covers meet §344.90; (d)(4) job-built covers by California-registered engineer, drawings at worksite, Standard Grade Douglas Fir, 250-lb weight from 10 ft, modified for falls over 7½ ft; Plate C-25 trough exception up to 6 ft; operative 1-1-2018): https://www.dir.ca.gov/title8/1712.html
• Cal/OSHA, Title 8 CCR §344.90 — Impalement Protection, Specifications and Testing Criteria (250-lb bag of dry sand under 10% moisture, 10-ft drop, 36–42 in circumference; three tests for covers, four for troughs, new device each test; troughs at least 4 in wide; verification by registered-engineering competence or a competent evaluator independent of the manufacturer; covers marked with model number or trademark, California Approval Number, and size; operative 10-1-2000): https://www.dir.ca.gov/title8/344_90.html
• OSHA, 29 CFR 1926.701(b) (federal: protruding reinforcing steel guarded to eliminate the hazard of impalement): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.701

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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