- 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.
June 7, 1985
Mr. O.K. Estes
Combustion Engineering, Inc.
1000 Prospect Hill Road
Post Office Box 500
Windsor, Connecticut 06095
Dear Mr. Estes:
This is in response to your letter of May 21, 1895, concerning Occupational Safety and Health Administration (OSHA) standards applicable during the erection of structural steel.
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 would tie off, they must be protected from falling hazards. On a 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, 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 the falling hazards.
Falling hazards involving distances of less than 25 feet are addressed by 29 CFR 1926.28(a). Essentially, employers are required to enforce the use of tied-off safety belts when their employees are exposed to a hazard and it is possible to use safety belts without creating greater hazards. 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.
I have enclosed a copy of OSHA Instruction STD 3-3.1 for your additional information.
[This document was edited on 6/20/2005 to strike information that no longer represents current OSHA policy.]
If we can be of further assistance, please let us know.
John B. Miles, Jr., Director
[Directorate of Construction]
[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.]