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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 http://www.osha.gov.
July 2, 2002
Mr. Joe Bratcher
H B Training and Consulting
84-A Jopenea Boulevard
Hoschton, GA 30548
Re: Subpart Q; §1926.750(a); tilt-up concrete construction; lift-slab
Dear Mr. Bratcher:
This is in response to your May 1, 2002, letter to the Occupational Safety and Health Administration (OSHA) and follow-up conference call with yourself, Doug Ester, Mark Hornbuckle, and Steve Stock of my staff on June 10. Mr. Stock, during the conference call, addressed your questions regarding the application of the steel erection standards to precast concrete and lift slab structures. However, you requested that OSHA comment on the note in the scope section of subpart R that mentions lift slab/tilt-up structures.
We have paraphrased your question below:
Question: In the note to §1926.750(a) reference is made to lift slab/tilt-up structures. Is OSHA trying to include lift slab/tilt-up such as a concrete parking structure in subpart R?
Answer: No, it was not the intent for these types of structures to be covered under subpart R, "Steel Erection." These types of structures are covered under subpart Q, "Concrete and Masonry Construction."
The referenced note in the subpart R, §1926.750 scope paragraph states in part:
"Examples of structures where steel erection may occur include but are not limited to the following: Single and multi-story buildings; systems-engineered metal buildings; lift slab/tilt-up structures...."
This note is included in the scope section of subpart R to list examples of structures where steel erection activities might be included during the construction of the structure. These examples are not offered to suggest that OSHA steel erection standards govern all activities on such projects. Employers would need to comply with subpart R only for covered steel erection activities. Those activities are listed in §1926.750(b)(1) and (2) and include things like the erection of steel joists and metal decking that might be used for roofs on structures created using lift slab/tilt-up processes.
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