Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

April 27, 1999

Mr. Anthony W. Graber
Martin Enterprises, Inc.
4315 Meyer Road
P.O. Box 522
Fort Wayne, IN 46801

Re: 1926.105(a); 1926.750

Dear Mr. Graber:

We are in receipt of your letter, dated October 27, 1998, to the Occupational Safety and Health Administration (OSHA) in which you ask several questions concerning safety provisions for steel erection activities.

Question 1: Is installation of a standing seam metal roofing system on a pre-engineered metal building considered a Steel Erection activity?

Answer: Yes, the installation of a standing seam metal roof on a metal building is considered a Steel Erection activity. When installed on an untiered metal building, fall protection is required for fall distances of 25 feet or more under 29 CFR 1926.105(a). While standing seam metal roofs are primarily used on untiered buildings, if it were installed on a tiered building the fall protection requirements in §1926.750, Subpart R would apply.

Question 2: Does the installation of other "necessary" components of that roofing system also fall under the fall protection rules for steel erection?

Answer: You ask if the following activities, which you state are necessary to complete the installation of an insulated standing seam metal roof system, are considered steel erection activities: (1) installation of the rolled fiberglass insulation (installed above the purlins but below the metal roofing as the leading edge advances); (2) installation of styrofoam thermal blocks that go between the insulation and the metal roof and (3) the stapling or taping together of the seams between the runs of fiberglass insulation.

Typically these activities occur in a repeating sequence of steps: a row of insulation is put down, styrofoam thermal blocks for the row are installed and then a row of metal roof is installed on top. After that row is completed, the next row is started using the same procedure. Because these activities are a necessary part of the installation of the metal roof in an integrated process, they are considered steel erection activities. In untiered metal buildings the §1926.105(a) fall protection requirements apply; in tiered steel structures the requirements of §1926.750, Subpart R apply.

As you may know, the State of Indiana administers its own occupational safety and health program under a plan approved and monitored by Federal OSHA. Under its OSHA-approved State plan, the State is responsible for conducting workplace inspections. Indiana adopts and enforces occupational safety and health standards which are at least as effective as OSHA's standards. Indiana's fall protection standards are identical to those of Federal OSHA. For work within the state, you are required to adhere to the fall protection provisions set forth in Indiana's State plan. If you have any questions on Indiana's policy with regard to this issue, you may contact the Indiana Department of Labor at the following address: Timothy Joyce, Commissioner, Indiana Department of Labor, 402 West Washington Street, Room W195, Indianapolis, Indiana 46204.


Russell B. Swanson, 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.]