|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
July 5, 2001
||Steven F. Witt|
Director, Directorate of Technical Support
||RUSSELL B. SWANSON|
Director, Directorate of Construction
||Jennifer C. Silk|
Director, Office of Technical Programs and Coordination Actvities
||Request for Variance by Corman Construction, Inc.|
This is in response to your memorandum dated March 16, 2001, requesting assistance in evaluating an application for permanent variance, from Corman Construction, Inc., to the provisions in §1926.754(c)(1)(i) of the new Safety Standards for Steel Erection published in the Federal Register on January 18, 2001.
Section 1926.754(c)(1)(i) states,
"Tripping hazards. Shear connectors (such as headed steel studs, steel bars or steel lugs), reinforcing bars, deformed anchors or threaded studs shall not be attached to the top flanges of beams, joists or beam attachments so that they project vertically from or horizontally across the top flange of the member until after the metal decking, or other walking/working surface, has been installed."
DOC's Office of Engineering Services and Office of Construction Standards and Compliance Assistance analyzed the situation described by the applicant, Corman Construction, Inc. The question involves installation of bridge beams. Prior to installation, the contractor proposes to weld a limited number of shear connectors (the minimum needed for fall protection) on flanges. Then, each shear connector is encapsulated by a split collar, a tee joint and line post/anchor post, or a round pipe; either of which is designed to serve as supports for horizontal lifelines in a fall protection system. 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. In sum, the provision does not apply when, (1) all of the shear connector studs are encapsulated by the line post or anchor post prior to erecting the member, and (2) all serve as an integral part of the fall protection system's fixed anchor point.