OSHA INSTRUCTION
| DIRECTIVE NUMBER: CPL 2-1.34 |
EFFECTIVE DATE: Friday, March 22,
2002 |
| SUBJECT: Inspection policy
and procedures for OSHA's steel erection standards for
construction. |
| Purpose: |
This instruction describes OSHA's
inspection policy and procedures and provides clarification to
ensure uniform enforcement by field enforcement personnel of the
steel erection standards for construction. |
| |
|
| Scope: |
OSHA-wide |
| |
|
| References: |
Construction Safety and Health
Standards, Subpart R, 29 CFR 1926.750-761, Subpart M, 1926.502 and
§1926.105; Federal Register, Vol. 66, No. 12, January 18, 2001,
pages 5196-5280, Final Rule; Safety Standards for Steel Erection;
Federal Register, Vol. 66, No. 137, July 17, 2001, pages
37137-37139, Final Rule; Delay of Effective Date; OSHA Instruction
CPL 2.103, The Field Inspection Reference Manual (FIRM); and
Occupational Safety and Health Act of 1970, Section 5(a)(1). |
| |
|
| Cancellations: |
All interpretations (including letters
of interpretation and memoranda) of the previous version of Subpart
R issued prior to January 18, 2001. |
| |
|
| State Plan Impact: |
This instruction describes a Federal
Program change for which State adoption is not required. |
| |
|
| Action Offices: |
National, Regional and Area
Offices |
| |
|
| Originating Office: |
Directorate of Construction |
| |
|
| Effective Date: |
The effective date for the steel
erection standard is January 18, 2002 except that §1926.754(c)(3)
will not take effect until July 18, 2006. Certain other provisions
are subject to a phase-in period (see Chapter 1, Section X). |
| |
|
| Contact: |
(202) 693-2020 Directorate of
Construction N3468, FPB 200 Constitution Ave.,
N.W. Washington, D.C. 20210 |
| |
|
| Approval: |
By and Under the Authority of John L.
Henshaw Assistant Secretary |
Executive
Summary
This instruction implements the
inspection policy and procedures necessary for uniform enforcement of
OSHA's new steel erection standard. To achieve this objective, the Agency
has included in this instruction a list of anticipated questions and
answers along with a Compliance Officer Guide containing inspection
tips.
Significant
Changes
The new standard addresses the
hazards that have been identified as the major causes of injuries and
fatalities in the steel erection industry. Concepts addressed by the
standard include:
- Site layout and construction sequence
- Site-specific erection plan
- Hoisting and rigging
- Structural steel assembly
- Column anchorage
- Beams and columns
- Open web steel joists
- Systems-engineered metal buildings
- Falling object protection
- Fall protection
- Training
TABLE OF
CONTENTS
ABSTRACT
CHAPTER
1. BACKGROUND
- Purpose.
- Scope.
- Cancellation.
- Significant
Changes.
- Site layout and construction sequence.
- Site-specific erection plan
- Hoisting and rigging.
- Structural steel assembly.
- Column anchorage.
- Beams and columns.
- Open web steel joists.
- Systems-engineered metal buildings.
- Falling object protection.
- Fall protection.
- Training.
- References.
- Construction Safety and Health Standards
- Federal Register, Vol. 66, No. 12, January 18, 2001
- Federal Register, Vol. 66, No. 137, July 17, 2001
- OSHA Instruction CPL 2.103
- Occupational Safety and Health Act of 1970
- Application.
- Action
Information.
- Responsible Office.
- Action Offices.
- Information Offices.
- Action
- Federal
Program Change.
- Phase-in
of certain requirements
- Component requirements
- Column joist requirements in §1926.757(a)(3)
- General Schedule Inspection Delay
CHAPTER
2. STANDARD OVERVIEW
- Quick
overview of the subjects addressed in the new standard
- §1926.750 Scope
- §1926.751 Definitions
- §1926.752 Site layout and construction sequence.
- §1926.753 Hoisting and rigging.
- §1926.754 Structural steel assembly and stability.
- §1926.755 Column anchorage.
- §1926.756 Beams and columns.
- §1926.757 Open web steel joists.
- §1926.758 Systems-engineered metal buildings.
- §1926.759 Falling object protection
- §1926.760 Fall protection
- §1926.761 Training
CHAPTER
3. COMPLIANCE OFFICER GUIDE AND INSPECTION TIPS
- INTRODUCTION.
- OPENING
CONFERENCE.
- During the opening conference with the controlling contractor
- During the opening conference with the steel
erector
- STANDARD
SECTIONS
- SCOPE - §1926.750.
- DEFINITIONS - §1926.751.
- SITE LAYOUT, SITE-SPECIFIC ERECTION PLAN AND CONSTRUCTION SEQUENCE
- §1926.752.
- HOISTING AND RIGGING - §1926.753.
- STRUCTURAL STEEL ASSEMBLY - §1926.754.
- COLUMN ANCHORAGE - §1926.755.
- BEAMS AND COLUMNS - §1926.756.
- OPEN WEB STEEL JOISTS - §1926.757.
- SYSTEMS-ENGINEERED METAL BUILDINGS - §1926.758.
- FALLING OBJECT PROTECTION - §1926.759.
- FALL PROTECTION - §1926.760.
- TRAINING - §1926.761.
CHAPTER
4. QUESTIONS AND ANSWERS
- GENERAL
GUIDANCE
Question 1
Question 2
Question 3
- SECTION
1926.750-SCOPE
Question 4(a)
Question 4(b)
Question 5
Question 6
Question 7
Question 8
Question 9
Question 10
Question 11
- SECTION
1927.752-SITE LAYOUT
Question 12
Question 13
Question 14
Question 15
Question 16(a)
Question 16(b)
- SECTION
1926.753-HOISTING AND RIGGING
Question 17
Question
18
Question 19
Question 20
Question 21
Question 22
- SECTION
1926.754-STRUCTURAL STEEL ASSEMBLY.
Question 23
Question 24
Question 25
Question 26
Question 27
Question 28
- SECTION
1926.755-COLUMN ANCHORAGE
Question 29
Question 30
- SECTION
1926.757-OPEN WEB STEEL JOISTS
Question 31
Question
32
Question 33
Question 34
Question 35
Question 36(a)
Questions 36(b)
Question 37
- SECTION
1926.759-FALLING OBJECT PROTECTION
Question 38
- SECTION
1926.760-FALL PROTECTION
Question 39
Question 40
Question 41
Question 42
Question 43
Question 44
Question 45
Question 46
Question 47
Question 48
Question 49
Question 50
Question 51
Question 52
- SECTION
1926.761-TRAINING.
Question 53
Question 54
Question 55
Question 56 CHAPTER
5. DEFINITIONS AND PHOTOS
Anchored bridging
Bolted diagonal bridging
Bridging
clip
Choker
Column
Connector
Controlled
decking zone (CDZ)
Controlled load lowering
Critical
lift
Double connection
Double connection seat
Girt
"Z" shaped girt
Headache ball
Hoisting equipment
Leading edge
Metal decking
Multiple lift rigging procedure (MLRP)("Christmas Treeing")
Multiple lift rigging
Opening
Personal fall
arrest system
Positioning device
Post
Purlin
Safety deck attachment
Shear connector
Steel
joist
Steel joist girder
Systems-engineered metal
building
CHAPTER
6. ILLUSTRATIONS OF CONCEPTS [RESERVED: ILLUSTRATIONS ARE BEING PREPARED
AND WILL BE ADDED]
INDEX
- Purpose. This instruction describes OSHA's
inspection policy and procedures and provides clarification to ensure
uniform enforcement by field enforcement personnel of the steel erection
standards for construction.
- Scope. This instruction applies OSHA-wide.
- Cancellation. All interpretations (including
letters of interpretation and memoranda) regarding the previous version
of Subpart R issued prior to January 18, 2001 are cancelled.
- Significant Changes. The new standard's
provisions that are significantly different from the previous steel
erection standard include:
- Site layout and construction sequence.
- Requires notification of proper curing of concrete in footings,
piers, etc. for steel columns.
- Requires controlling contractor to provide erector with a safe
site layout.
- Site-specific erection plan.
- Requires pre-planning of key erection elements, including
coordination with controlling contractor before erection begins, in
certain circumstances.
- Hoisting and rigging.
- Provides additional crane safety for steel erection.
- Minimizes employee exposure to overhead loads through
pre-planning and work practice requirements.
- Prescribes proper procedure for multiple lifts
(Christmas-treeing).
- Structural steel assembly.
- Provides safer walking/working surfaces by eliminating tripping
hazards and minimizing slips through new slip resistance
requirements (effective July 18, 2006).
- Provides specific work practices regarding safely landing deck
bundles and protecting against fall hazards from interior
openings.
- Column anchorage.
- Requires 4 anchor bolts per column along with other column
stability requirements.
- Requires procedures to ensure adequacy of anchor bolts that have
been modified in the field.
- Beams and columns.
- Eliminates collapse hazards associated with making double
connections at columns.
- Open web steel joists.
- Erection bridging and attachment requirements to minimize risk
of collapse of lightweight steel joists.
- Requirements for bridging terminus anchors, with illustrations
and drawings in a non-mandatory appendix.
- Requirements addressing how to place loads on steel joists to
minimize risk of collapse.
- Systems-engineered metal buildings.
- Requirements to minimize collapse in the erection of these
specialized structures.
- Falling object protection.
- Performance provisions that address hazards of falling objects
in steel erection.
- Fall protection.
- Deckers in a Controlled Decking Zone (CDZ) and connectors must
be protected at heights greater than two stories or 30 feet.
- Connectors between 15 feet and two stories or 30 feet must wear
fall arrest or restraint equipment and be able to be tied off or be
provided another means of fall protection. Deckers working between
15 feet and two stories or 30 feet may be protected by a CDZ.
- Requires fall protection for all others engaged in steel
erection at heights greater than 15 feet.
- Training.
- Requires qualified person to train exposed workers in fall
protection.
- Requires qualified person to train exposed workers engaged in
special, high risk activities.
- References.
- Construction Safety and Health Standards, Subpart R, 29 CFR
1926.750-761 and Subpart M, 1926.502.
- Federal Register, Vol. 66, No. 12, January 18, 2001, pages
5196-5280, Final Rule; Safety Standards for Steel Erection.
- Federal Register, Vol. 66, No. 137, July 17, 2001, pages
37137-37139, Final Rule; Delay of Effective Date.
- OSHA Instruction CPL 2.103, Field Inspection Reference Manual
(FIRM)
- Occupational Safety and Health Act of 1970, Section
5(a)(1).
- Application. This instruction applies to
construction, alteration and/or repair involving steel erection
activities.
- Action Information.
- Responsible Office. Directorate of Construction (DOC)
- Action Offices. Regional Offices, Area Offices, State Plan
States
- Information Offices. Information copies of this Instruction
are provided to OSHA Directorate heads and the Solicitor of Labor
(SOL)
- Action. Regional Administrators and Area
Directors shall ensure that compliance officers are familiar with the
contents of this instruction and that the enforcement guidelines are
followed. This instruction will be re-evaluated after one year.
- Federal Program Change. This instruction
describes a Federal program change for which State adoption is not
required. States were notified on July 18, 2001 of the requirement to
adopt a standard equivalent to the Federal standard for steel erection
by January 18, 2002.
NOTE: In order to effectively enforce safety and health
standards, guidance to compliance staff is necessary. Although
adoption of this instruction is not required, States are expected to
have standards, enforcement policies and procedures which are at least
as effective as those of Federal OSHA.
- Phase-in of certain requirements.
- Component requirements. Component requirements are
provisions that address the safety of certain structural members.
These are provisions that: prohibit shear connectors on members before
they are erected (§1926.754(c)(1)(i)); require all columns to be
anchored by a minimum of 4 anchor bolts, which must meet specified
strength requirements (§1926.755(a)) (there is a comparable
requirement for systems-engineered metal buildings, §1926.758(b)); set
requirements for double connections (§1926.756(c)(1)) (there is a
comparable requirement for systems-engineered metal buildings
§1926.758(e)); require column splices to be at a specified height and
meet a strength requirement (§1926.756(d)); require perimeter columns
to have holes or other devices for perimeter safety cables
(§1926.756(e)); in some instances require a vertical stabilizer plate
to stabilize steel joists (§1926.757(a)(1)(i)); require certain joists
to be strong enough to allow one employee to release the hoisting
cable without the need for erection bridging (§1926.757(a)(3)), and
require certain joists to be fabricated to allow for field bolting
during erection (§1926.757(a)(8)(i)).
- For building construction, the component requirements of the
final rule will not be applied: (1) where the building permit was
obtained prior to January 18, 2001, or (2) where steel erection
began on or before September 16, 2001 (see volume 66 of the Federal
Register, page 37137-37139).
- For bridge construction, the component requirements of the final
rule will not be applied where: (1) the bridge project has a
contract date before January 18, 2001; or (2) steel erection began
on or before September 16, 2001.
- Column joist requirements in §1926.757(a)(3).
- Until July 18, 2003, for all joists at or near columns that span
60 feet or less, employers will be considered to be in compliance
with §1926.757(a)(3) if they erect these joists either by: (1)
installing bridging or otherwise stabilizing the joist prior to
releasing the hoisting cable, or (2) releasing the cable without
having a worker on the joists. This will allow the joist industry
the necessary time to develop joists that will meet the
requirement.
- General Schedule Inspection Delay
- The Agency will not conduct general schedule inspections of
steel erection until March 18,
2002.
CHAPTER 2. STANDARD OVERVIEW
- This section is a quick overview of the subjects
addressed in the new standard. References to sections of the standard
that pertain to these subjects are included.
- §1926.750 Scope of coverage for Subpart R, Steel Erection,
Final Rule (§1926.750-761 and Appendices A-H).
- Defines what activities are always covered by Subpart R
[§.750(b)(1)]
- Provides examples of job activities that are covered only when
they occur during and as a part of steel erection [§.750(b)(2)]
- Lists specific activities that are not covered [§.750(a)]
- Defines the duties of the controlling contractor as including,
but not limited to, the duties specified in §§1926.752(a) and (c),
1926.755(b)(2), 1926.759(b), and 1926.760(e).
[§.750(c)]
- §1926.751 Definitions.
Key terms used throughout
the standard are defined in this section.
- §1926.752 Site layout and construction sequence.
- Prior to commencement of steel erection:
- Controlling contractor must ensure that the steel erector is
provided with written notification that concrete has attained
sufficient strength for steel erection activities [§.752(a)(1)]
Note: The steel erector is prohibited from erecting steel
until it receives written notification that the concrete has cured
enough to support steel erection [§.752(b)]
- Controlling contractor must ensure that the steel erector is
provided with written notification of any repairs, replacements
and modifications to anchor bolts.[§.752(a)(2)] —
requirements are also found in #167; .755(b)
- Controlling contractor must ensure that the worksite has
adequate access and storage areas [§.752(c)]
- Hoisting operations must be pre-planned to reduce employee
exposures to overhead loads [§.752(d)]
- Allows Site-specific erection plans as substitute
for certain requirements (Appendix A contains sample
plans) [§.752(e)].
- Safety latches on hooks activated [§.753(c)(5)]
- Setting joists 60'+ at/near columns in tandem [§.757(a)(4)]
- Landing decking on steel joists
[§.757(e)(4)]
- §1926.753 Hoisting and rigging.
- Crane safety: All provisions of §1926.550 apply to hoisting and
rigging with the exception of §1926.550(g)(2). In addition,
§1926.753(c) through (e) contain additional hoisting and rigging
requirements. [§.753]
- Pre-shift inspection requirements
- Pre-shift inspection must be done by a competent person
[§.753(c)]
- Qualified rigger (rigger who is also a qualified person) must
inspect the rigging prior to each shift.
[§.753(c)(2)]
- Responsibilities during crane operations
- Safety latches on hooks may not be deactivated unless a
qualified rigger determines it is safer to place purlins and
joists without them, or equivalent protection is provided in a
site specific erection plan [§.753(c)(5)]
- The standard allows employees engaged in initial steel
erection or hooking/unhooking to work under loads in some specific
instances. When that occurs, the load must be rigged by a
qualified rigger [§.753(d)]
- Operators are responsible for operations under their control
and have the authority to stop and refuse to handle loads until
safety has been assured [§.753(c)(2)(iv)]
- Rules for crane operations
- Prohibits the use of cranes to hoist personnel unless all
provisions of §1926.550 are met except §1926.550(g)(2)
[§.753(c)(4)]
- When employees work under loads (allowed in specified
instances), requirements in this section must be followed
[§.753(d)]
- Multiple lift rigging ("Christmas Treeing") is permitted as
long as the requirements in this section are met
[§.753(e)]
- §1926.754 Structural steel assembly and stability.
- Stability requirements
- Structural stability must be maintained at all times during
the erection process [§.754(a)]. This section contains a number of
specific requirements for stability (Note: Requirement for four
anchor bolts found in §1926.755(a)(1))
- Additional requirements for multi-story structures [§.754(b)]
- Requirements applicable when plumbing up
[§.754(d)]
- Decking requirements
- Requirements for hoisting, landing, and placing metal decking
[§.754(e)(1)]
- Requirements for installing metal decking at roof and floor
holes/openings [§.754(e)(2)]
- Other requirements
- Requirements for skeletal steel walking surfaces [§.754(c)]
(NOTE: These do not go into effect until July 18,
2006).
- §1926.755 Column anchorage.
- General requirements for stability
- Minimum of 4 anchor bolts required on columns
[§.755(a)(1)]
- Requirement to withstand 300 pound load [§.755(a)(2)]
- All columns must be evaluated by competent person
[§.755(a)(4)]
- Repair, replacement, or field modification of anchor rods/bolts
- Approval required by the project structural engineer
[§.755(b)(1)]
- Written notification to steel erector
[§.755(b)(2)]
- §1926.756 Beams and columns.
- This section of the standard focuses on increasing safety for
employees involved in connecting solid web beams and columns.
- Requires that solid web structural members remain attached to
the hoisting line until members are secured with at least two
bolts per connection drawn up wrench tight [§.756(a)(1)]
- Competent person shall determine if more than two bolts are
necessary to ensure the stability of cantilevered members
[§.756(a)(2)]
- Solid web structural members used as diagonal bracing shall be
secured by at least one bolt per connection drawn up wrench tight
[§.756(b)]
- Requires that one wrench-tight bolt or a seat (or seat
equivalent) secure the first member and column throughout the
entire double connection process [§.756(c)]
- Requires column splices to be designed to resist a minimum
eccentric gravity load of 300 pounds (136.3 kg) [§.756(d)]
- Sets requirements for the erection of perimeter columns
[§.756(e)]
- §1926.757 Open web steel joists.
- This section focuses on increasing safety for employees involved
in connecting open web steel joists. (Some requirements may be
modified through a site-specific erection plan [§§.757(a)(4) and
.757(e)(4)])
- Requirements for stabilizing steel joists and girders before
releasing hoisting cables [§.757(a)]
- Requirements for attaching steel joists and steel joist
girders (includes requirements for "K," "LH," and "DLH" series
steel joists) [§.757(b)]
- Requirements for the erection of steel joists (short span and
long span) [§.757(c)]
- Requirements for the erection of erection bridging (short span
and long span) [§.757(d)]
- Requirements for landing and placing loads on joists
[§.757(e)]
- §1926.758 Systems-engineered metal buildings.
- All the requirements of the standard apply to the erection of
systems-engineered metal buildings except §1926.755 (column
anchorage) and §1926.757 (open web steel joist). In addition:
- All columns are to have a minimum of four anchor rods/bolts
[§.758(b)]
- The rigid frames must have 50$ of their bolts or the number
specified by manufacturer (whichever is greater) installed and
tightened before the hoisting equipment is released [§.758(c)]
- Construction loads prohibited unless the framework is
adequately secured [§.758(d)]
- Requirements for girt and eave-to-strut connections [§.758(e)]
- Steel joists must be secured before releasing hoisting cables,
allowing employees on the joist, or placing construction loads on
the joists. [§.758(f)]
- Purlins and girts are not to be used as anchorages for fall
arrest systems unless written approval is obtained from a
qualified person [§.758(g)]
- Only after permanent bridging has been installed and fall
protection provided can purlins be used as a walking/working
surface when installing safety systems [§.758(h)]
- Limitations on placing construction loads on joists
[§.758(i)]
- §1926.759 Falling object protection
- All materials, equipment, and tools that are not being used must
be secured against accidental displacement [§.759(a)]
- The controlling contractor must bar other construction processes
below steel erection unless overhead protection is provided for the
employees working below [§.759(b)]
- §1926.760 Fall protection
- All employees must be protected at 15 feet, except for deckers
in controlled decking zones and connectors [§.760(a)]
- Exception for connectors — protected at 30 feet or two stories,
whichever is less [§.760(b)]
- Controlled decking zone requirements [§.760(c)]
- Exception for deckers in controlled decking zones - protected at
30 feet or two stories above lower deck, whichever is less
[§.760(c)(1)]
- Criteria for fall protection [§.760(d)]
- Responsibility of controlling contractors to choose whether to
accept responsibility for fall protection equipment
[§.760(e)]
- §1926.761 Training.
- Requirements found in this section supplement those found in
§1926.21
- Training conducted by qualified person(s) [§.761(a)]
- Requirements that must be included in training [§.761(b)]
- Special training programs required for multiple lift rigging,
connectors, and controlled decking zones [§.761(c)(1) through
(3)(ii)]
CHAPTER 3. COMPLIANCE OFFICER GUIDE AND INSPECTION
TIPS
- INTRODUCTION.
This section is
designed to assist compliance officers in the practical aspects of
conducting enforcement inspections under the new Steel Erection rule.
The suggestions below should be considered helpful hints.
The
new steel erection rule addresses a wide range of issues related to
steel erection safety. The new standard not only addresses fall
protection for iron workers, but places a heavy emphasis on maintaining
the structural integrity of the building during the erection process.
NOTE On Effective Date: See Steel Erection Delay
Notice (Federal Register #66 pages 37137-37139) to determine if
component requirements of the new standard are in effect for a
particular project. A number of provisions in the final rule address
the safety of certain structural components. These provisions
("component requirements") contain requirements for these components
to help ensure that the structure can be erected safely. There are
provisions that: prohibit shear connectors on members before they are
erected (§1926.754(c)(1)(i)); require all columns to be anchored by a
minimum of 4 anchor bolts, which must meet specified strength
requirements (§1926.755(a)) (there is a comparable requirement for
systems-engineered metal buildings, §1926.758(b)); set requirements
for double connections (§1926.756(c)(1)) (there is a comparable
requirement for systems-engineered metal buildings §1926.758(e));
require column splices to be at a specified height and meet a strength
requirement (§1926.756(d)); require perimeter columns to have holes or
other devices for perimeter safety cables (§1926.756(e)); in some
instances require a vertical stabilizer plate to stabilize steel
joists (§1926.757(a)(1)(i)); require certain joists to be strong
enough to allow one employee to release the hoisting cable without the
need for erection bridging (§1926.757(a)(3)), and require certain
joists to be fabricated to allow for field bolting during erection
(§1926.757(a)(8)(i)).
- For building construction, the component requirements of the
final rule will not be applied: (1) where the building permit was
obtained prior to January 18, 2001, or (2) where steel erection
began on or before September 16, 2001 (see volume 66 of the Federal
Register, page 37137-37139).
- For bridge construction, the component requirements of the final
rule will not be applied where: (1) the bridge project has a
contract date before January 18, 2001; or (2) steel erection began
on or before September 16, 2001.
The Agency will
not conduct general schedule inspections of steel erection until March
18, 2002.
- OPENING CONFERENCE.
Consider
obtaining the information outlined below at the opening conference and
during the initial observations of the steel erection site. Note that a
number of the tips suggest asking for various documents. This does not
mean that those documents are required by the standard. While it
is advisable to obtain the documents mentioned below, the only documents
an employer is required to have are those specified in Subpart R or
other standards.
- During the opening conference with the controlling contractor,
consider doing the following:
- Obtain a copy of the blueprints and consult with someone
knowledgeable in blueprint reading (engineer). Note the name of the
structural engineer of record from the blueprints.
- Find out when the steel erection began and on what date they
obtained the permits for the job. (This information will only be
important during the first few months after the standard becomes
effective.)
- Ask for a copy of the written notification to the steel erector
that the concrete in the footings, piers and walls and the mortar in
the masonry piers and walls has attained the required strength
[.752(a)(1)]. You will also want to find out when the concrete was
poured, how long after the pour they waited before allowing steel
erection to begin, and what compressive strength of concrete was
required.
- Ask if there have been any changes to anchor bolts. Ask for a
copy of the written notifications of
repairs/replacements/modifications.
- Determine if, prior to the erection of columns, they provided
written notification to the steel erector if any repairs,
replacements and modifications to the anchor bolts were conducted.
[§§.752(a)(2) and .755(b)]. Were these repairs, replacements and
modifications performed with approval of the project structural
engineer of record? If so, obtain a copy.
- Was the fall protection provided by the steel erector left in
the area where steel erection activity has been completed for use by
other trades?
- If yes, ask the following: Did you or your authorized
representative direct the steel erector to leave the fall
protection in place? Have you or your authorized representative
inspected and accepted control and responsibility of the fall
protection prior to authorizing persons other than steel erectors
to work in the area? (the answer to both of these questions must
be yes to be in compliance with §1926.760(e))
- If no, the controlling contractor is not required to take any
further action with regard to this
section.
- During the opening conference with the steel erector, consider
doing the following:
- Determine if they are using open web joists (also known as bar
joists).
- Determine the current stage of the erection process.
- Ask for a copy of the lift procedure (if kept).
- Determine who is the competent person and qualified rigger.
- Determine if they are using a site specific steel erection plan
(a plan is only required in some circumstances. See Chapter 2,
Section I, Paragraph C).
- STANDARD SECTIONS. The following is a
section-by-section description of observations the CSHO should make and
questions the CSHO should ask while performing a steel erection
inspection.
- SCOPE - §1926.750.
- Subpart R does NOT cover - precast concrete, electrical
transmission towers, communication and broadcast towers, or tanks.
NOTE on tanks: a tank is defined as a container for holding gases,
liquids, or solids. Subpart R does apply to the construction
of the steel structure that supports a tank. Construction of the
tank would be covered under Subpart E - 1926.105.
- The CSHO must initially determine if the activity being
inspected is covered by Subpart R. The first question to ask: Is
this activity listed in §1926.750(b)(1)? If so, then it is covered
by the standard.
- If the activity is listed only in §1926.750(b)(2), then you must
determine if it is going on in conjunction with ("during and [is] a
part of") steel erection activities listed in §1926.750(b)(1). A
question also to ask: Does this (b)(2) activity have to be done for
the steel erection to continue? The following flow chart may help:

NOTE: Paragraph .750(b)(2)
lists a number of activities that are covered by subpart R when they
occur during and are a part of the steel erection activities described
in paragraph (b)(1). Paragraph (b)(2) explicitly states that coverage
depends on whether an activity occurs during and is a part of steel
erection. For example, there are standing seam metal roofing systems
that incorporate a layer of insulation under the metal roof. In the
installation process, a row of insulation is installed, which is then
covered by a row of metal roofing. Once that row of roofing is
attached, the process is repeated, row by row, until the roof is
completed. The installation of the row of insulation is a part of the
installation of the metal roofing (which is steel erection), and so
the installation of the insulation is covered by Subpart R.
- DEFINITIONS - §1926.751.
The following definitions,
which are in the standard, should be helpful when conducting the walk
around inspection (see photos in Chapter 5):
- Anchored bridging means that the steel joist
bridging is connected to a bridging terminus point.
- Bolted diagonal bridging means diagonal bridging
that is bolted to a steel joist or joists.
- Bridging clip means a device that is attached to
the steel joist to allow the bolting of the bridging to the steel
joist.
- Bridging terminus point means a wall, a beam,
tandem joists (with all bridging installed and a horizontal truss in
the plane of the top chord) or other element at an end or
intermediate point(s) of a line of bridging that provides an anchor
point for the steel joist bridging.
- Choker means a wire rope or synthetic fiber
rigging assembly that is used to attach a load to a hoisting device.
- Cold forming means the process of using press
brakes, rolls, or other methods to shape steel into desired cross
sections at room temperature.
- Column means a load-carrying vertical member that
is part of the primary skeletal framing system. Columns do not
include posts.
- Competent person (also defined in §1926.32) means
one who is capable of identifying existing and predictable hazards
in the surroundings or working conditions which are unsanitary,
hazardous, or dangerous to employees, and who has authorization to
take prompt corrective measures to eliminate them.
- Connector means an employee who, working with
hoisting equipment, is placing and connecting structural members
and/or components.
- Constructibility means the ability to erect
structural steel members in accordance with Subpart R without having
to alter the overall structural design.
- Construction load (for joist erection) means any
load other than the weight of the employee(s), the joists and the
bridging bundle.
- Controlled decking zone (CDZ) means an area in
which certain work (for example, initial installation and placement
of metal decking) may take place without the use of guardrail
systems, personal fall arrest systems, fall restraint systems, or
safety net systems and where access to the zone is controlled.
- Controlled load lowering means lowering a load by
means of a mechanical hoist drum device that allows a hoisted load
to be lowered with maximum control using the gear train or hydraulic
components of the hoist mechanism. Controlled load lowering requires
the use of the hoist drive motor, rather than the load hoist brake,
to lower the load.
- Controlling contractor means a prime contractor,
general contractor, construction manager or any other legal entity
which has the overall responsibility for the construction of the
project -- its planning, quality and completion.
- Critical lift means a lift that (1) exceeds 75
percent of the rated capacity of the crane or derrick, or (2)
requires the use of more than one crane or derrick.
- Decking hole means a gap or void more than 2
inches (5.1 cm) in its least dimension and less than 12 inches (30.5
cm) in its greatest dimension in a floor, roof or other
walking/working surface. Pre-engineered holes in cellular decking
(for wires, cables, etc.) are not included in this definition.
- Derrick floor means an elevated floor of a
building or structure that has been designated to receive hoisted
pieces of steel prior to final placement.
- Double connection means an attachment method where
the connection point is intended for two pieces of steel which share
common bolts on either side of a central piece.
- Double connection seat means a structural
attachment that, during the installation of a double connection,
supports the first member while the second member is connected.
- Erection bridging means the bolted diagonal
bridging that is required to be installed prior to releasing the
hoisting cables from the steel joists.
- Fall restraint system means a fall protection
system that prevents the user from falling any distance. The system
is comprised of either a body belt or body harness, along with an
anchorage, connectors and other necessary equipment. The other
components typically include a lanyard, and may also include a
lifeline and other devices.
- Final interior perimeter means the perimeter of a
large permanent open space within a building such as an atrium or
courtyard. This does not include openings for stairways, elevator
shafts, etc.
- Girt (in systems-engineered metal buildings) means
a "Z" or "C" shaped member formed from sheet steel spanning between
primary framing and supporting wall material.
- Headache ball means a weighted hook that is used
to attach loads to the hoist load line of the crane.
- Hoisting equipment means commercially manufactured
lifting equipment designed to lift and position a load of known
weight to a location at some known elevation and horizontal distance
from the equipment's center of rotation. "Hoisting equipment"
includes but is not limited to cranes, derricks, tower cranes,
barge-mounted derricks or cranes, gin poles and gantry hoist
systems. A "come-a-long" (a mechanical device, usually consisting of
a chain or cable attached at each end, that is used to facilitate
movement of materials through leverage) is not considered "hoisting
equipment."
- Leading edge means the unprotected side and edge
of a floor, roof, or formwork for a floor or other walking/working
surface (such as deck) which changes location as additional floor,
roof, decking or formwork sections are placed, formed or
constructed.
- Metal decking means a commercially manufactured,
structural grade, cold rolled metal panel formed into a series of
parallel ribs; for this subpart, this includes metal floor and roof
decks, standing seam metal roofs, other metal roof systems and other
products such as bar gratings, checker plate, expanded metal panels,
and similar products. After installation and proper fastening, these
decking materials serve a combination of functions including, but
not limited to: a structural element designed in combination with
the structure to resist, distribute and transfer loads, stiffen the
structure and provide a diaphragm action; a walking/working surface;
a form for concrete slabs; a support for roofing systems; and a
finished floor or roof.
- Multiple lift rigging means a rigging assembly
manufactured by wire rope rigging suppliers that facilitates the
attachment of up to five independent loads to the hoist rigging of a
crane (Note: Under §1926.753(e)(2), components from several
manufacturers may be assembled by a qualified rigger. See Question
and Answer #18).
- Opening means a gap or void 12 inches (30.5 cm) or
more in its least dimension in a floor, roof or other
walking/working surface. For the purposes of this subpart, skylights
and smoke domes that do not meet the strength requirements of
§1926.754(e)(3) shall be regarded as openings (Note: The definition
of "opening" in subpart R is different than the definition of
"opening" in subpart M).
- Permanent floor means a structurally completed
floor at any level or elevation (including slab on grade).
- Personal fall arrest system means a system used to
arrest an employee in a fall from a working level. A personal fall
arrest system consists of an anchorage, connectors, a body harness
and may include a lanyard, deceleration device, lifeline, or
suitable combination of these. The use of a body belt for fall
arrest is prohibited.
- Positioning device means a body belt or body
harness rigged to allow an employee to be supported on an elevated,
vertical surface, such as a wall or column and work with both hands
free while leaning.
- Post means a structural member with a longitudinal
axis that is essentially vertical, that: (1) weighs 300 pounds or
less and is axially loaded (a load presses down on the top end), or
(2) is not axially loaded, but is laterally restrained by the above
member. Posts typically support stair landings, wall framing,
mezzanines and other substructures.
- Project structural engineer of record means the
registered, licensed professional responsible for the design of
structural steel framing and whose seal appears on the structural
contract documents.
- Purlin (in systems-engineered metal buildings)
means a "Z" or "C" shaped member formed from sheet steel spanning
between primary framing and supporting roof material.
- Qualified person (also defined in §1926.32) means
one who, by possession of a recognized degree, certificate, or
professional standing, or who by extensive knowledge, training, and
experience, has successfully demonstrated the ability to solve or
resolve problems relating to the subject matter, the work, or the
project.
- Safety deck attachment means an initial attachment
that is used to secure an initially placed sheet of decking to keep
proper alignment and bearing with structural support members.
- Shear connector means headed steel studs, steel
bars, steel lugs, and similar devices which are attached to a
structural member for the purpose of achieving composite action with
concrete.
- Steel erection means the construction, alteration
or repair of steel buildings, bridges and other structures,
including the installation of metal decking and all planking used
during the process of erection.
- Steel joist means an open web, secondary
load-carrying member of 144 feet (43.9 m) or less, designed by the
manufacturer, used for the support of floors and roofs. This does
not include structural steel trusses or cold-formed joists.
- Steel joist girder means an open web, primary
load-carrying member, designed by the manufacturer, used for the
support of floors and roofs. This does not include structural steel
trusses.
- Steel truss means an open web member designed of
structural steel components by the project structural engineer of
record. For the purposes of this subpart, a steel truss is
considered equivalent to a solid web structural member.
- Structural steel means a steel member, or a member
made of a substitute material (such as, but not limited to,
fiberglass, aluminum or composite members). These members include,
but are not limited to, steel joists, joist girders, purlins,
columns, beams, trusses, splices, seats, metal decking, girts, and
all bridging, and cold formed metal framing which is integrated with
the structural steel framing of a building.
- Systems-engineered metal building means a metal,
field-assembled building system consisting of framing, roof and wall
coverings. Typically, many of these components are cold-formed
shapes. These individual parts are fabricated in one or more
manufacturing facilities and shipped to the job site for assembly
into the final structure. The engineering design of the system is
normally the responsibility of the systems-engineered metal building
manufacturer.
- Tank means a container for holding gases, liquids
or solids.
- Unprotected sides and edges means any side or edge
(except at entrances to points of access) of a walking/working
surface, for example a, floor, roof, ramp or runway, where there is
no wall or guardrail system at least 39 inches (1.0 m)
high.
- SITE LAYOUT, SITE-SPECIFIC ERECTION PLAN AND CONSTRUCTION
SEQUENCE - §1926.752.
This section of the standard sets
forth OSHA's requirements for communication between the controlling
contractor and the steel erector prior to the beginning of steel
erection, and pre-planning by the steel erector to minimize overhead
exposure during hoisting operations.
- During an inspection, visually determine the following:
- Did the controlling contractor provide adequate road access on
the site for the delivery and movement of derricks, cranes,
trucks, steel erection materials and other equipment? (Note: This
requirement does not apply to roads outside of the construction
site.) [§.752(c)(1)]
- Did the controlling contractor provide means and methods for
pedestrian and vehicular control? [§.752(c)(1)]
- Did the controlling contractor provide a firm, properly
graded, drained area, readily accessible to the work with adequate
space for the safe storage of materials and safe operation of the
erectors' equipment? [§.752(c)(2)]
- Did the controlling contractor either bar other construction
processes below steel erection or provide overhead protection for
the employees below? (This relates only to protection from falling
objects other than materials being hoisted.)
[§.759(b)]
- Site-specific erection plan [§.752(e)]. A site-specific erection
plan is required only when the contractor has decided to use
alternative means to protect employees from three specific hazards:
- When safety latches on hooks are being deactivated or made
inoperable. [§.753(c)(5)]
- When joists (which span more than 60 feet) at or near columns
are not being set in tandem with all bridging installed.
[§.757(a)(4)]
- When bundles of decking are being placed on steel joists
before all bridging has been installed and anchored and all joist
bearing ends attached. [§.757(e)(4)]
- If it is determined that any of the above three conditions
exist, a site-specific erection plan is required. The employer may
use Appendix A as a framework for the plan. Methods for providing
alternative worker protection from the above three conditions must
be specified in the plan.
- Determine if there is a plan available at the site. (Note: The
plan does not need to be in writing - only §1926.757(e)(4)) requires
a written plan.
- HOISTING AND RIGGING - §1926.753.
The requirements
of §1926.753 supplement the existing crane and rigging standards in
§1926.251 and §1926.550. The requirements of Subpart R cover every
type of crane. All the provisions of §1926.550 apply to hoisting and
rigging with the exception of §1926.550(g)(2).
- Questions to ask the steel erector:
- Who is the qualified rigger?
- Did they do a pre-shift inspection of the rigging?
- Who is the competent person assigned to inspect the
crane?
- Questions to ask the crane operator and/or qualified rigger:
- Do they have load charts, operator manual or riggers'
handbook?
- Has the heaviest anticipated lift been calculated?
(Note:
See the June 1994 booklet "Mobile Crane Inspection Guidelines for
OSHA Compliance Officers")
- Paragraph(c)(2) requires the qualified rigger inspect the
below-hook rigging before each shift. Section 1926.251 inspection
procedures will be applied for each type of rigging equipment to be
used during the shift. In addition, paragraph (c)(5)(i) allows the
safety latch on hoisting hooks to be deactivated when the qualified
rigger makes a determination that it is safer for the connectors
during the placement of purlins and single joists (Note that a
safety latch is required to be used only where: (1) the manufacturer
has equipped the hook with a latch, or (2) when working under
suspended loads pursuant to §1926.753(d)).
- Observe hooks with deactivated safety latches for anything
other than single joists or purlins.
- Refer to the site-specific erection plan for equivalent
protection.
- Talk to the qualified rigger.
- Paragraph (d) addresses the hazards associated with overhead
loads. Specifically, these hazards include failure of the lifting
device, which would create a crushing hazard, and items falling from
the load, which creates a struck-by and crushing hazard, among
others. Given the nature of the loads used in steel erection, either
of these events could result in serious injury or death.
- See if employees are exposed to overhead loads. If you see
employees working under loads, determine if the route was
pre-planned (and exposure minimized) by interviewing the competent
person, crane operator, etc. (The exception being connectors doing
initial connection; or riggers hooking or unhooking of the load.
These employees may work under the load.)
- MULTIPLE LIFT RIGGING PROCEDURE (MLRP).
Paragraph
(e)(1) lists the prerequisite conditions for multiple lift
procedures (MLRP assembly, maximum of 5 pieces of steel per lift,
only beams or similar structural members allowed, only by
specifically trained employees, and the crane manufacturer must
allow.)
- If the steel erector is performing multiple-lifts:
(1)
Request a copy of their multiple-lift procedure (if kept). (2)
Determine the number of pieces being lifted (no more than 5 are
allowed). (3) Check for certification of the rigging assembly
from the qualified rigger (whether a manufacturer supplied rigging
or the qualified rigger assembled it) and inspect the rigging
equipment. (4) Review the rigging chart and calculate the total
load. (5) Check the crane for controlled load lowering
capability. (6) Assure that the rigging is 7 feet or more
apart.
- The MLRP rigging assembly must be specifically designed for
the structural steel members to be lifted. The design must
incorporate the maximum anticipated load for each component part
as it will be used in the assembly.
- On a manufacturer-assembled rig, check for a tag or other
means to specify the limits of the rig.
- On a qualified rigger-assembled rig, check that the qualified
rigger certified the maximum loading of the assembly and its
component parts.
- STRUCTURAL STEEL ASSEMBLY - §1926.754.
- Paragraph (a): This paragraph requires that structural stability
be maintained throughout the structural steel erection process.
While guy wires (steel cable) are not specifically required, they
are often used for this purpose. (See also §.755(a)(4)). These guy
wires may also be used to plumb the building and add support to
resist wind conditions.
- Look for guying and bracing and see if any apparent problems
exist.
- Paragraph (c)(1): Shear connectors and similar devices. The
standard requires that, where used, shear connectors must be
field-installed rather than shop-installed.
- Check steel beams for shear connectors. There should not be
any shear connectors on beams without the decking or other
walking/working surface in place, unless conventional fall
protection is used (see Q & A # 25).
- Ask the steel erector if they field-install shear connectors
and what procedures are followed.
- Paragraph (c)(3): THIS PROVISION ONLY APPLIES AFTER JULY 18,
2006. Once in effect, this will require documented or certified
slip resistance of any painted or coated structural steel that an
employee would walk on.
- After July 18, 2006, observe the following conditions: Does
the site have any painted or coated steel? If so, ask the steel
erector for documentation or certification of slip resistance.
This would probably be something the steel erector would obtain
from the steel fabricator and/or paint manufacturer certifying the
slip resistance of the paint.
- Paragraph (d)(1): Plumbing-up.
- Look for plumbing-up equipment. Guy wires (steel cable) and
turnbuckles are generally used to plumb structures. Check for
proper installation -- see if the wire rope components (U clips)
were installed according to the manufacturers'
requirements.
- Paragraph (e)(1)(i) (general prohibition against using bundle
packaging and strapping for hoisting): This hazard usually occurs
while unloading trucks, when the metal decking bundles are tightly
packed together and the rigging is difficult to attach and the end
of the bundle is lifted with the bundles banding straps.
- Ask the steel erector or observe if these straps are marked as
approved for lifting.
- Paragraph (e)(1)(iii)-(iv)(requirements for landing metal
decking bundles). Generally, the competent person (foreman) will
layout specific locations for the placement of bundles of decking
for the ease of installation.
- Look for metal decking landed on joists. Climb the ladder and
ensure that bridging is installed and all joist ends are attached.
Check the placement of the decking bundles. Refer to
§1926.757(e)(4) for specific requirements.
- Look for metal decking landed on solid web framing members.
Check placement and support of bundles.
- Paragraph (e)(2): Roof and floor holes and openings.
- Look for any "decking holes" and "openings" on the site.
Framed openings in metal decking must have structural members
turned down. Any openings (as defined in the standard) that do
exist because of constructibility or design constraints must be
covered or employees protected by fall protection
[.760(a)(1)].
- Paragraph (e)(3): Covers for roof and floor openings. Look for
any covers on the site. If covers exist:
- Are they secured?
- Are they painted, or marked visibly with "HOLE" or
"COVER"?
- COLUMN ANCHORAGE - §1926.755.
- Paragraph (a) contains requirements to ensure that columns
remain stable during the erection process.
- Paragraph (a)(1) requires 4 anchor rods/bolts on all columns.
However, this requirement does not include posts. The standard
defines these terms as follows: A column is a load-carrying vertical
member that is part of the primary skeletal framing system. A post
is a structural member with a longitudinal axis that is essentially
vertical, that: (1) is axially loaded (a load presses down on the
top end) and weighs 300 pounds or less, or (2) is not axially
loaded, but is laterally restrained by the above member. Posts
typically support stair landings, wall framing, mezzanines and other
structures.
- Determine whether a vertical member is a column. If it is,
check if it has the required 4 anchor rods/bolts. Remember that a
post can have less than 4.
- Paragraph (a)(2) requires that columns be able to withstand a
specified load.
- Check for unusually small bolts, insufficient length or
failure.
- Request documentation of the design criteria from the
contractor.
- Paragraph (a)(3) is intended to ensure that the column is
properly set.
- If leveling nuts are used, make sure the weight of the column
rests on all 4 nuts. If shims are used, look for loose shims or
instances where only a few shims are supporting the
load.
- Paragraph (a)(4) requires that a competent person evaluate the
columns to determine whether guying or bracing is needed. If guying
or bracing is needed, it must be provided. All columns need to be
evaluated; in some instances the 4 anchor bolts/rods may not provide
sufficient stability.
- Ask the contractor who their competent person is and ask the
competent person if and how this evaluation was
performed.
- Paragraph (b) requires that all anchor bolt/rod repairs be
approved by the project structural engineer of record and that all
such repairs be communicated in writing to the steel erector.
- Ask for a copy of the notification when it is suspected that
anchorage bolts/rods have been damaged, repaired, replaced or
field-modified.
- BEAMS AND COLUMNS - §1926.756.
- Paragraph (c)(1): Double connections at columns and /or at beam
webs over columns.
- Ask the steel erector's representative/competent person if the
structure's design includes double connections at columns and/or
beam webs over columns. If the answer is yes, you should observe
the double connection operation.
- Ask the employer the following questions on how the connectors
are being protected during this type operation:
(1) Are
the connectors able to maintain at least 1-bolt and nut at least
wrench tight at a common connection hole at all times? Among the
ways of doing this are to use clipped end connections or staggered
connections. (2) If not, is the erector using seats or
equivalent connection devices that were supplied with the
member? (3) If a seat or equivalent device is used, is it
attached to both the supporting member and the first member before
the nuts on the shared bolts are removed? (4) If a seat or
equivalent device is used, has it been adequately bolted or welded
to both a supporting member and the first member before the
nuts on the shared bolts are removed to make the double
connection?
- Paragraph (d): Column splices.
- If a need arises to determine if column splices were designed
to resist a minimum eccentric gravity load of 300 pounds located
18 inches from the extreme outer face of the column in each
direction at the top of the column shaft, ask the project
structural engineer of record.
- The perimeter columns must extend a minium of 48 inches above
the finish floor and have holes or other devices attached to them
at 42 - 45 inches above the finish floor (and also at the
mid-point) to permit the installation of perimeter safety cables.
If this requirement is not met, and the employer claims that
constructibility does not allow meeting the requirement, ask the
employer why constructibility does not allow this and what the
employer is doing in the mean time to provide protection to the
employees exposed to the perimeter.
- OPEN WEB STEEL JOISTS - §1926.757.
Some of the most
serious risks facing the ironworker are encountered during the
erection of open web steel joists, particularly from landing loads on
unbridged joists and improperly placing loads on joists.
- Questions to ask the steel erector and the ironworkers with
regard to steel joists:
- What type of joists are you installing?
- What's the elevation?
- Are you installing joists in bays? If so, how many joists per
bay and how many bays?
- What are the spans of the joists and are there different types
of joists being installed?
- Are you familiar with the Steel Joist Institute and/or OSHA's
requirements for the safe installation of steel joists?
- Can I see the steel erection drawings and can you explain the
joist pattern?
- Are you following a site specific erection plan? If so, may I
see a copy?
- How are you bracing/bridging the joists? Diagonal and/or
horizontal?
- What bridging is required? What type of bridging is being
used?
- When is the erection bridging installed and by whom is it
installed?
- How much and what type of erection bridging is required by the
plans?
- At what point during the installation process is the erection
bridging installed?
- Is all the erection bridging designated in the drawings being
installed? If not, why not?
- How are you lifting the joists?
- What are the qualifications of the crane operator?
- How are the joists rigged? Is a qualified rigger being used?
- Is the erection bridging installed before or after releasing
the joist from the crane?
- How are the joists released from the crane? (Open hooks?
Remote release? Ironworker walks the joists? From an aerial lift?)
- Are the joist connections bolted or welded? If welded, do
welds meet the standard's requirements [.757(b)]?
- Are joists in bays of 40 feet or more bolted? If not, why not?
If the employer claims that constructibility does not allow
field-bolting, ask its basis for making that claim.
- What type of fall protection is being used during joist
installation and during the installation of erection bridging?
- Are you setting joists in tandem?
- How are you securing your joists - are both sides of the seat
at one end of the joist secured?
- Have there been any stability problems? Problems with anchor
bolts or wall pockets?
- Have there been any change orders? May I see the change log
(if kept)?
- Are you field bolting your joists at the columns?
- Are the columns framed in at least two directions?
- When landing joists, how are you securing them against
accidental displacement?
- What kind of bridging terminus points are you using? Please
identify them.
- Are you placing any loads on the joists? If so, what are they
(e.g., bundles of bridging or deck or joists)? How much load is
being placed on the joists and across how many joists is the load
spread?
- SYSTEMS-ENGINEERED METAL BUILDINGS - §1926.758.
- When performing an inspection on a systems-engineered metal
building, be aware that all the requirements in subpart R apply to
these structures except for §1926.755 (column anchorage) and
§1926.757 (steel joist erection).
- Check column base plates for four anchor bolts/rods [§.758(b)]
- Check for any double connections on the structure and ensure
that either a seat or similar connection device is being used for
double connections.
- If joists are being installed, observe the operation to ensure
that joists are fully bolted or welded prior to release of the
hoisting cable, allowing an employee on the joists or placing any
construction load on the joist.
- FALLING OBJECT PROTECTION - §1926.759.
- Under paragraph (b), when it is necessary to have work performed
below on-going steel erection activities (other than hoisting),
effective overhead protection must be provided to those workers to
prevent injuries from falling objects.
- If this protection is not provided, work by other trades is not
to be permitted below steel erection work -- the controlling
contractor must institute measures to keep employees out of the area
below the steel erection activities.
- Check the site for unsecured materials, tools and equipment
that are not in use [§.759(a)].
- If you see workers below where steel erection activities are
being performed, ask some of the employees if they know of any
tools or other materials that have fallen from the worksite above.
If they have, look into what falling hazards are present and what
has and is being done to protect the
employees.
- FALL PROTECTION - §1926.760.
- Paragraph (a): The first thing that needs to be determined is if
the activity is covered by Subpart R (see §1926.750(b)) or by
Subpart M.
- Ask the general contractor about their fall protection program
and what they require their subcontractors to follow. Then ask the
erectors. Check to see if the employers are effectively
communicating and enforcing the standard. If the erector allows
employees to work unprotected between 15 and 30 feet, make sure
that the unprotected workers meet the connector definition or are
working on the leading edge of a decking operation in a CDZ (see
definitions of connector, leading edge, and controlled decking
zone).
- Establish by observation and asking employees the following:
(1) What fall protection system are you using? (2) Who
are the connectors? (Note: Come-a-longs and chain-falls are not
hoisting equipment, so employees cannot be considered connectors
simply on the basis of using these to move steel into
place.) (3) How often do you inspect your fall protection
equipment? (4) For decking operations between 15 and 30 feet/2
stories, are you using fall protection or CDZs? (5) Are all
employees over 30feet/2 stories protected by conventional fall
protection?
- Paragraph (c): Controlled decking zone
- If the employer is using a CDZ between 15 and 30 feet/2
stories, observe the operation to determine if the employer is
complying with the requirements of §1926.760(c).
- Physically inspect CDZ from outside the zone if possible.
Measure the size and ask employees working in the zone about their
training and what activities are performed in the
zone.
- Paragraph (a)(2): Perimeter cables
- Look at the perimeter cables. Do they meet the criteria of
§1926.502(g)? Are the perimeter cables being installed as soon as
the metal decking is completed?
- TRAINING - §1926.761.
Section 1926.761 supplements
§1926.21(b)(2) training requirements. Failure to train on hazards not
covered by this section should be cited under §1926.21(b)(2) (for
example: training on falling objects, bolting, impalement hazards from
rebar). Subpart R does not require a certification that training has
been conducted.
- Employees must be provided the training prior to exposure to the
hazard.
- Ask the employer whether it trained the employees or relied on
a third-party trainer. If a third-party trainer was used, ask how
the employer determined that the training meets the standard.
- Subpart R does not include a testing requirement. However, an
effective training program necessarily involves some means of
determining whether the instruction was understood. Ask the
employer how it makes this determination (this can be done in a
variety of ways, such as formal oral, or written tests,
observation, or through discussion). Also, ask employees about
their training.
- Section (a): Requires that all training required by this section
be provided by a qualified person.
- A qualified person, is defined in §1926.751 as one who by
possession of a recognized degree, certificate, or professional
standing, or by extensive knowledge, training, and experience has
successfully demonstrated the ability to solve or resolve problems
relating to the subject matter, the work, or the
project.
CHAPTER 4. QUESTIONS AND ANSWERS
Note: Several questions and answers that appeared in the
draft version of this directive have been removed pending further
consideration.
- GENERAL GUIDANCE.
Question 1:
What is the effective date of the standard?
Answer: The
effective date for the final rule has been changed to January 18, 2002.
Note also that the effective date of §1926.754(c)(3)(slip resistance
requirement for coated skeletal structural steel) is July 18, 2006.
NOTE: The Agency will not conduct general schedule inspections
of steel erection until March 18, 2002.
For more information on
how the new standard will be phased-in, see Question and Answer 2 below.
Question 2: On February 1, 2002, a contractor receives the
columns at the site to be erected. They have only 2 anchor bolts, and
column splice locations do not meet the standard's requirements. The
design and/or fabrication of these columns was done prior to the new
effective date (January 18, 2002) of the final rule. Is the contractor
required to comply with §1926.755 (a)(1)(requirement for 4 anchor bolts)
and §1926.756(d) (requirement for column splice height)?
Answer: In two situations the component requirements (provisions
that address the safety of certain structural members) of the final rule
will not be applied: (1) where the building permit was obtained prior to
January 18, 2001, or (2) where steel erection began on or before
September 16, 2001 (see volume 66 of the Federal Register, page
37137-37139). Steel erection begins when a steel erection activity
covered by the standard begins.
In this scenario, the answer
depends on when the building permit was obtained and when steel erection
began. If the building permit was obtained before January 18, 2001 (the
date the final rule was published), these component requirements would
not be applied to these columns. If steel erection began on or before
September 16, 2001, the component requirements would not apply,
irrespective of when the building permit was obtained. Otherwise, the
requirements would apply.
For bridge construction, OSHA will
exempt a bridge project from the component requirements of the new steel
erection standard if: (1) the project has a contract date before January
18, 2001; or (2) steel erection began on or before September 16, 2001.
Question 3: Which provisions in the standard are
considered "component requirements"?
Answer: A number of
provisions in the final rule address the safety of certain structural
components. These provisions contain design requirements for these
components to help ensure that the structure can be erected safely. For
example, there are provisions that prohibit shear connectors on members
before they are erected (§1926.754(c)(1)(i)); require all columns to be
anchored by a minimum of 4 anchor bolts, which must meet specified
strength requirements (§1926.755(a)) (there is a comparable requirement
for systems-engineered metal buildings, §1926.758(b)); set requirements
for double connections (§1926.756(c)(1)) (there is a comparable
requirement for systems-engineered metal buildings §1926.758(e));
require column splices to be at a specified height and meet a strength
requirement (§1926.756(d)); require perimeter columns to have holes or
other devices for perimeter safety cables (§1926.756(e)); in some
instances require a vertical stabilizer plate to stabilize steel joists
(§1926.757(a)(1)(i)); require certain joists to be strong enough to
allow one employee to release the hoisting cable without the need for
erection bridging (§1926.757(a)(3)), and require certain joists to be
fabricated to allow for field bolting during erection
(§1926.757(a)(8)(i)).
- SECTION 1926.750-SCOPE.
Question 4(a): The structural steel and decking has been
completed on floor 4. Structural steel is being erected for floor 6. Is
the installation of an item listed only in §1926.750(b)(2) on floor 4
considered steel erection?
Answer: No. The activities listed
in §1926.750(b)(1) are covered by the standard. The activities listed in
§1926.750(b)(2) are covered by the standard only if they are installed
"during and are a part of" steel erection activities listed in (b)(1).
In this scenario no (b)(1) activities are taking place on the
4th floor, the ongoing steel erection activities have
progressed to the 6th floor, and the installation of the
(b)(2) item is not part of the work on floor 6. The work on floor 4 is
not covered by Subpart R.
Question 4(b): Some structural
steel work (listed in (b)(1)) is taking place in the northeast corner of
floor 5. In the southwest corner of floor 5, some work listed in (b)(2)
is taking place. Is the installation of the (b)(2) item covered by
subpart R?
Answer: No. As long as the §1926.750(b)(1)
activities can proceed irrespective of the progress on the
§1926.750(b)(2) activities, the (b)(2) activities are excluded from
coverage under Subpart R.
Question 5: When a tank is to be
supported by a structure that falls under the scope of Subpart R, does
construction of the tank also fall within the scope of Subpart
R?
Answer: No. 1926.750(a) excludes tank construction
from the scope of Subpart R. It is excluded because it is considered to
be a specialized industry based upon its unique use of cylindrical
construction techniques. The construction of the tank itself would not
be steel erection even though the structure supporting the tank is
covered by subpart R.
Question 6: When installing an
integrated metal roof decking system, which includes the metal banding,
insulation, and screw down clips, is the entire process considered steel
erection?
Answer: Yes. These operations take place in a
repeating sequence of steps. Once the banding is in place, a row of
insulation is put down, metal decking is laid over it and then secured
with clips. The metal decking forms both the structural and
weather-proofing roof surface. Working from that completed row, the next
row of insulation and decking is then installed and the process repeated
across the building.
The installation of the metal roof decking
is covered by subpart R under 1926.750(b)(1). Because the metal banding,
insulation and screw-down clips are installed "during and [as] a part
of" the installation of the metal decking, these activities are covered
by subpart R under 1926.750(b)(2).
Question 7: Is the
construction of a house framed with metal studs within subpart
R?
Answer: No. Metal studs are not mentioned in
§1926.750, and while the installation of "structural steel" is covered,
the definition of structural steel in §1926.751 includes metal studs
only where those studs are "integrated with the structural steel framing
of a building." Since such a house has no such structural steel framing,
but simply the cold-formed metal studs, a house framed with metal studs
is not covered by subpart R. The use of one or several hot-formed
I-beams in such a structure would not constitute "structural steel
framing" [emphasis added], so their use in such a house would not change
the answer; subpart R would apply only to the installation of the
hot-formed I-beams.
Question 8: When would the
installation of metal studs be covered by subpart R?
Answer: The installation of metal studs is covered by subpart R
when the studs are "integrated with the structural steel framing of a
building." For example, in some buildings, the skeletal frame is
composed of hot-formed columns and beams. However, the filler walls and
roof structure, which are attached to that frame, are constructed with
metal studs. In that case, the installation of the metal studs are
covered by subpart R.
Question 9: Is the installation of
metal stairways, and the installation of an iron fence and gate outside
a completed building, considered "miscellaneous metals" and covered by
subpart R?
Answer: Yes. The activities listed in
§1926.750 (b)(1), which are covered by Subpart R, include installing
"miscellaneous metals, [and] ornamental iron . . ." An iron fence and
gate have traditionally been considered ornamental iron, and so are
covered. Metal stairways have also traditionally been considered
miscellaneous metals and would be covered by the standard.
Question 10: Scenario: A prefabricated tank is installed
on a pad. The tank has connection points for a catwalk pre-installed by
the manufacturer. The catwalk will be installed by a crane crew after
the tank is installed. Do the fall protection requirements of Subpart R
apply to the installation of the catwalk?
Answer: Yes,
the installation of the catwalk on a completed tank is covered by
Subpart R. Catwalks traditionally have been considered "miscellaneous
metals." The installation of miscellaneous metals are covered by Subpart
R pursuant to §1926.750(b)(1). Therefore, fall protection by use of a
guardrail system, safety net system, personal fall arrest system,
positioning device system or fall restraint system is required by
§1926.760 (a)(1) at heights more than 15 feet above a lower level.
Question 11: Subpart R does not apply to transmission
towers. Some power lines are supported with steel poles. Is the
installation of these steel poles covered by subpart R?
Answer: No. Although such poles are not "towers," 1926 Subpart V
(Power Transmission and Distribution) is a more specifically applicable
standard. Under 1926.950(a), Subpart V applies to "the construction of
electric transmission and distribution lines and equipment." "Equipment"
is defined in §1926.960(s) as including "fittings, devices, appliances,
fixtures, apparatus, and the like, used as part of, or in connection
with, an electrical power transmission and distribution system, or
communication systems." Steel poles used to support power lines meet
this definition. Therefore, the installation of these poles is covered
by 1926 Subpart V, not Subpart R.
- SECTION 1927.752-SITE LAYOUT, SITE-SPECIFIC
ERECTION PLAN AND CONSTRUCTION SEQUENCE.
Question 12:
Before any steel erection begins, who is responsible for performing the
test to determine whether the concrete has cured to 75% of the intended
minimum compressive design strength or cured enough so that it can
support the loads imposed during steel erection?
Answer:
The controlling contractor must ensure that written notification is
given to the steel erector that the concrete has cured to the level
required by the standard. The standard does not require any specific
entity to perform the test. The choice of who will do the test is left
to the controlling contractor. Since it is the controlling contractor's
responsibility to ensure that the notification is given to the steel
erector, the controlling contractor must select an entity that has the
expertise to perform the test. The controlling contractor may do the
test itself if it has the expertise to do so. In the preamble of the
final rule (page 5206), OSHA stated:
In the proposed rule, the controlling contractor
would have had to provide the ASTM test results to the steel erector.
The final rule has been changed to reflect that the controlling
contractor must ensure that the test results are provided to the steel
erector. This rephrasing will allow the controlling contractor to have
a contractor familiar with the ASTM test methods perform the test and
provide the results to the steel
erector. Question 13: Can the controlling
contractor contract with subcontractors to perform the work required by
§1926.752(a)? If so, is the controlling contractor still responsible for
these duties after subcontracting them out?
Answer:
Under §1926.752 (a), the controlling contractor "shall ensure that the
steel erector is provided" with written notification that the concrete
has cured to the specified degree. While the controlling contractor may
contract with subcontractors to do the requisite tests and provide the
written notification, the controlling contractor remains responsible for
ensuring that the subcontractor does that work. If the subcontractor
fails to do the test and provide the notification, the controlling
contractor may be cited for a violation under §1926.752(a).
Question 14: Section 1926.752(a)(1) requires the
controlling contractor to ensure that the steel erector is provided with
written notifications that the concrete and masonry meet certain
specified strength requirements. To what extent is the controlling
contractor responsible for the accuracy of the strength assessments in
the written notifications?
Answer: As explained in
Q&A #12, the controlling contractor can choose to either: (1)
conduct the tests itself, if it has the expertise to do so; or (2)
select an entity that has the expertise to do the test. If the
controlling contractor does the tests itself, it is responsible for the
accuracy of the tests.
If the controlling contractor selects
someone else to do the tests, it is responsible for exercising
reasonable care in the selection of the testing entity. As long as it
has a reasonable basis for believing that the testing entity is
competent and capable of doing the work, and the controlling contractor
has no actual knowledge that the tests results are wrong, erroneous test
results will not constitute a violation of 1926.752(a).
Question 15: Section 1926.752(a)(1) and (b) require that
an appropriate ASTM standard test method be used to determine that
field-cured concrete/mortar testing samples have attained 75% of the
intended minimum compressive strength or sufficient strength to support
loads imposed during steel erection before that erection begins. Can I
rely on cure time instead of doing such a test?
Answer:
No. The standard does not provide that cure time may be used instead of
the ASTM test. Because of the many factors that influence cure rates
(temperature, humidity, ingredient ratios, etc.), cure time is an
unreliable means of assessing how much the concrete has cured.
Question 16(a): Does the written notification from the
controlling contractor to the steel erector about concrete footings,
etc. in §1926.752(a) and (b) have to be maintained on site?
Answer: Once the written notification is given to the erector,
there is no requirement that it be maintained at the site.
Question 16(b): Does the anchor bolt repair, replacement
or field-modification approval from the Structural Engineer of Record
(SER) required by §1926.755(b)(1) have to be maintained on site?
Answer: No. Where an anchor bolt repair, replacement or
field-modification is made, §1926.752(a)(2) requires that the
controlling contractor ensure that the steel erector is provided with
written notification that the requirements in §1926.755(b) were met.
Section 1926.755(b)(1) requires that, prior to erection, the repair,
replacement or field-modification must be approved by the SER. Once the
written notification is given to the erector under §1926.752(a)(2),
there is no requirement that it be maintained at the site. Also, there
is no requirement that a record of the SER's approval be maintained at
the site.
- SECTION 1926.753-HOISTING AND
RIGGING.
Question 17: Section 1926.753(e)(4) requires
the members be rigged at least 7 feet apart on a multiple lift rigging
assembly (Christmas tree rig). If they are rigged 7' apart and the
connector needs to slacken the line to unhook the lower beam, the beam
above now has less than 7' of clearance. Does a 7' clearance need to be
maintained at all times?
Answer: No. The 7 feet
specifically refers to the distance as rigged.
Question
18: Does the standard permit a qualified rigger to design and assemble a
"multiple lift rigging" assembly on the jobsite by mixing components
from one rigging supplier or by mixing components from several rigging
suppliers?
Answer: Yes. In §1926.751, "Multiple lift
rigging" is defined as "a rigging assembly manufactured by wire rope
rigging suppliers . . . ." The use of the plural "suppliers" reflects
that an assembly may be made from components from more than one
manufacturer. This is also reflected in the fact that §1926.753(e)(2)
allows a qualified rigger to certify the capacity of an assembly instead
of a manufacturer: "Components of the multiple lift rigging assembly
shall be specifically designed and assembled with a maximum capacity for
total assembly and for each individual attachment point. This capacity,
certified by the manufacturer or a qualified rigger, shall be based on
the manufacturer's specifications with a 5 to 1 safety factor for all
components." [Emphasis added].
The preamble to the final rule
also shows that an assembly may be either put together from separately
produced manufactured components, or obtained as a single, manufactured
unit: "[t]he rigging must be certified by the qualified rigger who
assembles it or the manufacturer who provides the entire assembly to
ensure that the assembly can support the whole load . . . ." (Volume 66
of the Federal Register at page 5211). The provision, then, permits a
qualified rigger to assemble the multiple lift rigging from manufactured
components. These may be from either a single or multiple suppliers.
Question 19: How often must the multiple lift rigging
assembly be inspected?
Answer: In §1926.753(c)(2), the
standard requires a qualified rigger to inspect the rigging before every
shift in accordance with §1926.251, Rigging equipment for material
handling. Additional inspections of the rigging assembly where
service conditions warrant are required under §1926.251(a)(6).
Question 20: Section 1926.753(c)(1)(i) requires a
pre-shift visual inspection of cranes to be done by a competent person.
Section 1926.753(c)(1)(iv) states that "the [crane] operator shall be
responsible for those operations under the operator's direct control.
Whenever there is any doubt as to safety, the operator shall have the
authority to stop and refuse to handle loads until safety has been
assured."
Scenario: The crane is rented, and the
operator is supplied by the crane rental company. The steel erector
designates the operator as the competent person for purposes of the
pre-shift inspection requirements. Is the steel erector still
responsible for compliance with the pre-shift inspection requirements?
Is the steel erector responsible for crane operations under the direct
control of the operator?
Answer: Under §1926.750(a),
"the requirements of [subpart R] apply to employers engaged in steel
erection unless otherwise specified." Section 1926.753 (c)(1)(iv)
specifies the operator as responsible for operations that are "under the
operator's direct control." However, those are only operations involving
the actual operation of the crane.
While an operator may be
designated as a competent person for purposes of the pre-shift
inspection, §1926.753(c)(1)(i) does not specify who is responsible for
compliance with the pre-shift inspection requirements. Therefore, a
designation by the steel erector of the crane owner's operator as the
competent person would not absolve the steel erector of responsibility
for making sure that the pre-shift inspection was done (Note, though,
that the steel erector is not expected to have the same level of
expertise regarding those inspections as either the crane owner or the
competent person).
Question 21: Does §1926.753(e) permit
beams of different sizes to be lifted in a multiple lift?
Answer: Yes.
Question 22: Section 1926.753(e)(2)
requires that the capacity of each multiple lift rigging component and
the total assembly be certified by the manufacturer or qualified rigger.
Does that certification have to be in writing?
Answer:
Yes, a certification is a written document.
- SECTION 1926.754-STRUCTURAL STEEL
ASSEMBLY.
Question 23: Section 1926.754 (b)(3)
requires a "fully planked or decked floor or nets" within two stories or
30 feet, whichever is less. Can an employer's requirement that workers
be protected by fall arrest equipment at all times above 15 feet (or
less) take the place of nets and temporary floors?
Answer: Yes. Where an employer establishes, communicates and
enforces a requirement to be protected by fall arrest equipment at all
times above 15 feet (or less), the failure to comply with
§1926.754(b)(3) is considered a de minimis violation and
will not be cited.
Question 24: Prior to installation of a
bridge girder, a contractor welds a limited number of shear connectors
(the minimum needed for a fall protection system) on the top flange of
the girder. Each shear connector is encapsulated by a split collar, a
tee joint and line post/anchor post (or a round pipe). These are
designed to serve as supports for horizontal lifelines in a fall
protection system. Is this a violation of §1926.754(c)(1)(i)?
Answer: In this scenario, the spacing and height requirements
for the supports would essentially eliminate the tripping hazards. Since
the shear studs will be encapsulated by a fall protection anchor device,
prior to the beam being erected, the provision in §1926.754(c)(1)(i)
regarding shear connectors does not apply. Section 1926.753(c)(1)(i)
does not apply when: (1) the shear connector studs are encapsulated by
the line post or anchor post prior to erecting the member; and (2) the
encapsulated studs serve as an integral part of the fall protection
system's fixed anchor point.
Question 25: I have beams
with shop-installed shear connectors at 20 feet. If the employer
requires the use of fall protection for all workers, including
connectors and deckers, would the presence of the shop-installed shear
connectors on these beams still be a violation under
1926.754(c)(1)?
Answer: No. If an employer requires that
all workers, including those engaged in connecting and in decking (as
well as deckers in a CDZ), be protected from falls by conventional fall
protection, then the failure to meet the requirements of §1926.754(c)(1)
would |