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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 8, 2002

Mr. Buddy C. Caples
Assistant Construction Engineer
State of Nebraska
Department of Roads
1500 Highway 2
P.O. Box 94759
Lincoln, NE 68509-4759

Dear Mr. Caples:

This is in response to your letter of March 26, 2002 [and] subsequent telephone discussions with my staff regarding the Occupational Safety and Health Administration's new steel erection standard and compliance directive. You have asked questions about the requirement in the standard that shear connectors be field-installed and our compliance policy regarding that requirement.

Section 1926.754(c)(1)(i) provides:

"Tripping hazards. Shear connectors . . .shall not be attached to the top flanges of beams, joists or beam attachments . . .until after the metal decking, or other walking/working surface, has been installed."

In the recently issued OSHA Instruction, CP: 2-134 ("Inspection policy and procedures for OSHA's steel erection standards for construction"), which became effective March 22, 2002, we included the following Question and Answer:

Question 25: I have beams with shop-installed shear connectors at 20 feet. If the employer requires the use of fall protection for all workers, including connectors and deckers, would the presence of the shop-installed shear connectors on these beams still be a violation under 1926.754(c)(1)?

Answer: No. If an employer requires that all workers, including those engaged in connecting and in decking (as well as deckers in a CDZ), be protected from falls by conventional fall protection, then the failure to meet the requirements of §1926.754(c)(1) would be considered de minimis, and no citation would be issued.

You first ask if the reference in the question to "shear connectors at 20 feet" means shear connectors spaced (horizontally) 20 feet apart. The answer is no; the scenario posed in Question 25 relates to a situation where the height of the shear connectors above ground (or a lower level) is 20 feet. Under this Q&A, as long as all workers are protected by conventional fall protection, the failure to meet therequirements of §1926.754(c)(1) by failing to install all shear connectors in the fabrication shop before placement of the girder on the bridge would be considered de minimis and no citation would be issued.

Your second question relates to the meaning of our statement that this would be considered "de minimis." Under OSHA's de minimis policy, de minimis violations are those which have no direct or immediate relationship to safety or health. Consequently, no citation is issued.

Finally, you raised a question about whether the scenario in Q&A 25 was related to the scenario in Q&A 24, which dealt with encapsulating shear connectors in a horizontal lifeline stanchion. The answer is no; the scenario in Q&A 24 is not related to the scenario in Q&A 25.

If you need additional information, please do not hesitate to contact us by fax at: U.S. Department of Labor, OSHA, [Directorate of Construction, Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction