How to Survive OSHA’s Steel Erection Standard

1. How to Survive OSHA’s Steel Erection Standard James H. Brown Director of Safety & Health AGC of Indiana

2. 29CFR 1926.750(b)(1) Design Multi-Employer Hoisting Fall Protection Training Rigging Site Issues Placing What Does the Standard Address?

3. 29CFR 1926.750(b)(1) Connecting Welding Bolting Steel Joist Ornamental Iron Decking Curtain Walls What Is Steel Erection?

4. SENRAC was established in 1992 to develop a new steel erection standard. Committee made up of industry, suppliers, unions and OSHA. Controversial language concerning multi-employer. Final rule published in January 2001. History

5. January 18, 2002 Reset to allow more time to get acquainted. Gives more time for steel to be properly designed and fabricated. Grand-fathered Component Requirements Building permits before January 18, 2001. Steel erection begun before September 18, 2001. Important Dates

6. Covers the construction, alteration or repair of steel structures including: Single & multi-story buildings Bridges Other steel structures Includes installation of metal decking and planking. Does not cover communications towers and tanks. Scope

7. The Controlling Contractor A prime contractor, general contractor, construction manager or any other legal entity which has the overall responsibility for the construction of a the project -- its planning, quality and completion. Controlling Contractor

8. The following duties were specifically addressed by SENRAC. 1926.750 - Scope Paragraph (c) provides that the duties of controlling contractors under this rule include, but are not limited to, the duties specified. 1926.752(a) (approval to begin steel erection), 1926.752(c) (site layout) 1926.755(b)(2) (notification of repair, replacement or modification of anchor bolts) 1926.759(b) (protection from falling objects) and 1926.760(a)(2)(i) (perimeter safety cables) Controlling Contractor - Duties

9. This is not an exclusive list of responsibilities. OSHA Multi-Employer Policy. CPL 2-00.124. December 10, 1999. Was not addressed by SENRAC. OSHA stipulates by addressing specific duties of Controlling Employer. It is not their intent to eliminate the Multi-Employer Policy. OSHA Preamble references numerous provisions of reasonable duty of care as per the Multi-Employer Policy. Multi-Employer Issues

10. What are the implications? OSHA has given a false legality to the Policy by making reference to it in the Preamble to a Final Rule. Multi-Employer Issues

11. (a) Approval to begin steel erection. Before authorizing the commencement of steel erection, the controlling contractor shall ensure that the steel erector is provided with the following notifications: 1926.752 - Site layout, site-specific erection plan and construction sequence.

12. The concrete in the footings, piers and walls and the mortar in the masonry piers and walls has attained, on the basis of an appropriate ASTM standard test method of field-cured samples either 75% of the intended minimum compressive design strength or sufficient strength to support the load imposed during steel erection. This section of the final rule sets forth OSHA’s requirements for proper communication between thecontrolling contractor and the steel erector prior to the beginning of the steel erection operation and proper pre-planning by the steel erector to minimize overhead exposure during hoisting operations. Notifications

13. 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? Question

14. The standard does not require any specific entity to perform the test. The controlling contractor must select an entity that has the expertise to perform the test. Testing

15. 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? Question

16. Under 1926.752(a)(1), 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 the 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)(1). Testing/Notification

17. 1926.752(a)(2) - Any repairs, replacements and modifications to the anchor bolts were conducted in accordance with 1926.755(b). Anchor Bolt Modifications

18. Anchor Bolt Modifications • 1926.755(b) - Repair, replacement or field modification of anchor rods (anchor bolts). • (1) Anchor rods(anchor bolts) shall not be repaired, replaced or field-modified without the approval of the project structural engineer of record.

19. Anchor Bolt Modifications • (2) Prior to the erection of a column, the controlling contractor shall provide written notification to the steel erector if there has been any repair, replacement or modification of the anchor rods (anchor bolts) of that column.

20. 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 maintained on site? Question

21. 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 Structural Engineer of Record. 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 Structural Engineer of Record’s approval be maintained at the site. Anchor Bolt Modifications

22. To make a field repair to an anchor rod (anchor bolt), must there be a written order from the project’s engineer of record? Question

23. Section 1926.755(b)(1) prohibits such repairs “withoutthe approval of the project structural engineer of record.” While the standard requires approval, it does not require the approval to be in writing. Approval

24. The requirements in 1926.755(b) apply to the “repair, replacement or field modification of anchor rods (anchor bolts).” Is hitting an anchor bolt with a hammer to line it up with the base plate holes considered a modification? Generally, hitting an anchor bolt with a hammer to line it up with the base plate holes would not be considered a modification, since those minor adjustments do not normally affect the structural integrity of the rod or the concrete. However, unbending a bolt is considered a modification since that will weaken it. Question

25. The controlling contractor shall ensure that the following is provided and maintained: (1) Adequate access roads into and through the site for the safe delivery and movement of derricks, cranes, trucks, other necessary equipment, and the material to be erected and means and methods for pedestrian and vehicular control. 1926.752 (c) - Site Layout

26. Site Layout • (2) A firm, properly graded, drained area, readily accessible to the work with adequate space for the safe storage of materials and the safe operation of the erector’s equipment.

27. What are well maintained access roads, lay down and work areas? Who decides what is well maintained? Can this cause complaints to OSHA over a muddy area? Questions

28. OSHA has concluded that no definition could be created that would encompass all possible site conditions. For this reason, OSHA has left the word adequate in the final rule, and it will be the responsibility of the controlling contractor to determine that a road is properly graded to support equipment without the danger of rollover and properly drained so that equipment can be safely maneuvered. Preamble Note

29. 1926.752(d) Pre-planning of overhead hoisting operations. All hoisting operations in steel erection shall be pre-planned to ensure that the requirements of 1926.753(d) are met. Overhead Hoisting

30. 1926.753(d) Working under loads. (1) Routes for suspended loads shall be pre-planned to ensure that no employee is required to work directly below a suspended load except; (i) Employees engaged in the initial connection of the steel; or (ii) Employees necessary for the hooking or unhooking of the load. Working Under Loads

31. (2) When working under suspended loads, the following criteria shall be met: (i) Materials being hoisted shall be rigged to prevent unintentional displacement; (ii) Hooks with self-closing safety latches or their equivalent shall be used to prevent components from slipping out of the hook; and (iii) All loads shall be rigged by a qualified rigger. Working Under Loads

32. Paragraph (d) Pre-planning of Overhead Hoisting Operations - “pre-planning of overhead hoisting operations” to reflect that 1926.753(d) addresses requirements for the pre-planning of lifts and not the requirements for the actual hoisting and rigging of materials. Commenters stated that there are times when materials being lifted would be required to have a swing area that would cover areas where workers are present. Overhead Hoisting

33. In their view, this requirement would cause the controlling contractor to clear the whole site. This is not what the Committee intended nor is it what the provision requires. In addition, a similar requirement already exists in OSHA’s crane and derrick standard. 1926.500(a)(19) requires that “all employees shall be kept clear of loads about to be lifted and of suspended loads.” The intent of final rule 1926-752(d) is to require employers to pre-plan lifts to facilitate compliance with the overhead load requirements. Preamble Notes

34. 1926.752(e) Guidelines for establishing a site-specific erection plan contained in Appendix A to this subpart are required when: Erection Plans

35. 1926.753(c)(5) - Safety latches on hooks shall not be deactivated or made inoperable except: (i) When a qualified rigger has determined that the hoisting and placing of purlins and single joists can be performed more safely by doing so; or (ii) When equivalent protection is provided in a site-specific erection plan. Erection Plans

36. 1926.757(a)(4) - Where steel joists at or near columns span more than 60 feet (18.3m), the joists shall be set in tandem with all bridging installed unless an alternative method of erection, which provides equivalent stability to the steel joist, is designed by a qualified person and is included in the site-specific erection plan. Erection Plans

37. 1926.757(e)(4) - No bundle of decking may be placed on steel joists until all bridging has been installed and anchored and all joist bearing ends attached, unless all of the following conditions are met: (i) The employer has first determined from a qualified person and documented in a site-specific erection plan that the structure is capable of supporting the decking load . Erection Plans

38. (a) Securing loose items aloft. All materials, equipment, and tools, which are not in use while aloft, shall be secured against accidental displacement. (b) Protection from falling objects other than materials being hoisted. The controllingcontractor shall bar other construction processes below steel erection unless overhead protection for the employees below is provided. 1926.759 - Falling Object Protection

39. One way controlling contractors can reduce the hazards associated with falling objects is by scheduling work in such a way that employees are not exposed. Preamble Note

40. The controlling contractor shall ensure that no other construction processes take place below steel erection unless adequate overhead protection for the employees below is provided. Falling Object Protection

41. The use of the word “ensure” in this standard does not make the controlling contractor liable if it institutes reasonable measures to comply with the requirement. Preamble Note

42. Fall protection provided by the steel erector shall remain in the area where steel erection activity has been completed, to be used by other trades, only if the controlling contractor or its authorized representative: 1926.760(e) - Custody of Fall Protection

43. (1) Has directed the steel erector to leave the fall protection in place; and (2) Has inspected and accepted control and responsibility of the fall protection prior to authorizing persons other than steel erectors to work in the area. Custody of Fall Protection

44. The perimeter columns define the final perimeter where the edges will not be expanded. Definition - Perimeter

45. The perimeter cable provision in the proposal did not specify either the steel erector or the controlling contractor as responsible for installing the perimeter cables. Preamble Note

46. Since the perimeter cable provision does not specify any particular entity as responsible for installing the cables, all employers engaged in steel erection with respect to the project are responsible for compliance with this provision, including the controlling contractor. Preamble Note