Can safety chains be used instead of a traditional guardrail system?

If a guardrail system is used as fall protection, it must meet the design, construction, and strength requirements outlined in 1910.29(b). Under new Subpart D, OSHA allows the use of safety chains for hoist areas, the warning lines of designated areas, and around the top of mobile ladder stands and platforms used for special applications. On the other hand, OSHA explicitly prohibits the use of chains at the top of fixed ladders now and says in the preamble to the final rule that, “safety chains are unsafe and do not provide the protection necessary to keep employees safe from falls.”

While OSHA says that “equivalent” guardrail system members can be used, it is not entirely clear what OSHA ultimately will and won’t allow now regarding the use of safety chains because the protection used must provide equal or greater protection to employees. Again, OSHA strongly feels that safety chains do not keep employees safe from falls, except in limited situations.

Until citations and Letters of Interpretation are issued to clarify this issue, employers must carefully evaluate the use of chains in their workplace based on this information.

If safety chains are used, a single safety chain is not allowed. A guardrail system — or the equivalent — must have both a top rail and midrail. This was the requirement under old Subpart D, and remains under new Subpart D.