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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.

December 11, 2001

Atorod Azizinamini
W348 Nebraska Hall
Civil Engineering Department
University of Nebraska-Lincoln
Lincoln, Nebraska, 68588-0531

Re: HBS Composite Action System; §1926.754(c)(1)(i)

Dear Mr. Azizinamini:

This is in response to your letter of July 23 requesting an evaluation of the "HBS Composite Action System." You have requested a determination as to whether this system would be in compliance with §1926.754(c)(1)(i) of OSHA's new steel erection standard.

In your letter, you provide a description of the HBS Composite Action System which is designed to be used in lieu of shear connectors and serve the purpose of providing composite action between the steel and the concrete. As we understand it, in general terms, the HBS System consists of a continuous plate shop-welded on edge to and along the top flange of the beam. The continuous plate has holes periodically spaced through which V-shaped reinforcing bars will pass. The reinforcing bars are inserted through the holes after the formwork has been placed. The formwork provides a working surface from which to install the reinforcing bars.

Installation of the HBS Composite Action System's continuous plate prior to erection of the steel member would violate §1926.754(c)(1)(i) of the new steel erection standard. 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.

The purpose of this provision is to prohibit the installation of items that pose tripping hazards on beams prior to erection. The continuous plate in the HBS Composite Action System is similar to reinforcing bars that run horizontally along the top flange of the beam; it projects vertically up from that beam, dissecting the surface and creating a tripping hazard. Therefore, the installation of the continuous plate prior to erection of the beam is prohibited by the standard.

If, however, the continuous plate is installed in the field after the decking or other walking/working surface is installed, then the HBS Composite Action System would be in compliance with §1926.754(c)(1)(i).

If you require any further assistance, please do not hesitate to contact us by fax at 202-693-1689, or by mail at: Directorate of Construction-OSHA, [Office of Construction Standards and Guidance], Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210.


Russell B. Swanson, Director
Directorate of Construction