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.

August 15, 2002

Ms. Rebecca Cartwright
Safety Consultant
Safety Resources Company of Ohio, Inc.
4253 Portage Avenue, NW
North Canton, OH 44720

Dear Ms. Cartwright:

This is in response to your letter of January 7, 2002, to Rob Medlock, Occupational Safety and Health's (OSHA) Area Director in Cleveland, asking for clarification of steel erection joist field bolting requirements in the new steel erection standard, 29 CFR part 1926 subpart R. Your inquiry was forwarded to this office. We apologize for the delay in providing this response.

We have paraphrased your question as follows:

Question: Under the new steel erection standard, joists over 40 feet are required to be field-bolted. With respect to joists over 60 feet, is it permissible to use the following procedure: while the crane continues to support the joist, the joist would be attached with a final weld instead of field-bolting? Would OSHA consider such a procedure to have eliminated the exposure to fall hazards?

Answer: No. Section 1926.757(a)(8) requires that the initial connection of joists in bays of 40 feet be made by field-bolting:

(i) Except for steel joists that have been pre-assembled into panels, connections of individual steel joists to steel structures in bays of 40 feet (12.2 m) or more shall be fabricated to allow for field bolting during erection.
(ii) These connections shall be field bolted unless constructibility does not allow.

Another section - §1926.757 (b) (1) and (2) - sets requirements for the final attachment of joists. The final attachment may be done by bolting or welding, as long as the final attachment criteria are met. However, attaching the joist using final welds is not a substitute for the field-bolting initial attachment requirement.

Keeping the joist supported by the crane during the attachment operation is not a substitute for these requirements. There is a separate, additional provision (§1926.757(c)(2)) that specifically requires joists over 60 feet to be attached at both ends in accordance with the final attachment criteria "before the hoisting cables are released."

We are not aware of a means of eliminating worker exposure to both the fall and collapse hazards during the process you describe. Your questions suggest that your proposed procedure would prevent workers from being exposed to a fall during the process of attaching the joist. Part of the fall hazard comes from the risk that the steel members may collapse during the erection process. The collapse hazard is a risk to both the workers engaged in the attachment process and to other workers in the area.

The purpose of this provision was to minimize these hazards during the erection process. This issue was considered during the rulemaking, and the Agency decided to rely on the Negotiated Rulemaking Committee's recommendation that field-bolting be required.

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.

Sincerely,



Russell B. Swanson, Director
Directorate of Construction