- Standard Number:
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 https://www.osha.gov.
October 4, 1983
Mr. Frank G. Goldenberg
P.O. Box 11929
Lynchburg, Virginia 24506
Dear Mr. Goldenberg:
This is in response to your letter of September 8, 1983, requesting a further clarification of standards applicable to the erection of structural steel.
Falling hazards involving distances of less than 25 feet are addressed by 29 CFR 1926.28(a). Essentially, employees are required to enforce the use of tied-off safety belts without creating greater hazards. However, within the jurisdiction of the U.S. Court of Appeals for the 5th and 11th Circuits, OSHA may enforce the use of the tied-off safety belts for falls under 29 CFR 1926.28(a), only in those situations in which industry custom and practice is to use tied-off safety belts. It is customary in the construction industry for iron workers to use tied-off safety belts in situations in which employees are stationary; for example, when they are doing structural welding, bolting-up, riveting, etc.
We do accept, as a general proposition, the premise that connectors need not be tied-off when initially connecting steel members together. However, occasionally there are situations in which connectors are in one location for an extended period of time and are not in danger of being struck by suspended steel. In such situations, the connector should tie-off. Although we do not believe that connectors ordinarily ought to be required to tie-off, they must be protected from falling hazards by other means when it is possible to do so without creating greater hazards. On a multi-story building, for example, there must be either a tightly decked floor or a safety net directly below them in the interior of the building within two floors or 30 feet, whichever is less (25 feet if nets are being used), or the employer should be cited for violation of 29 CFR 1926.750. In a non-tiered building, connectors must be protected from falls in excess of 25 feet as required by 29 CFR 1926.105.
If employees, including connectors, are exposed to more than a two-story or 25-foot fall to the outside of the building they should be protected as required by 1926.105(a) and 1926.105(c)(1), where it is possible to do so and when the rigging of nets does not create greater hazards than allowing employees to work unprotected from falling hazards.
If I may be of further assistance, please feel free to contact me.
Bruce Hillenbrand, Director
[Directorate of Cooperative and State Programs]
[Correction 6/20/2005. See OSHA Directive CPL 02-01-034 "Inspection policy and procedures for OSHA's steel erection standards for construction" published on 3/22/2002 for the current policy on OSHA's steel erection standards (1926 Subpart R) for construction.]