- Standard Number:
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.
October 22, 2002
Lee V. Clarbour
Arlington Structural Steel, Company, Inc.
1727 East Davis Street
Arlington Heights, IL 60005
Dear Mr. Clarbour:
This is in response to your February 4, 2002, letter inquiring about OSHA's new steel erection standard and its effect on erecting joists in bays 40 or more feet (12.2 m) long. I apologize for the delay in answering your letter. Part of the delay was due to the fact that mail addressed to the government is first sent to a facility that sanitizes it. We have paraphrased your questions below, and have added additional questions and answers to help clarify the issues you raised.
Question (1): Instead of initially attaching joists 40 feet or longer by field-bolting, we would like to use the following procedure: while the hoisting cable is still attached, we would attach the joist with welding that meets the final weld specifications in §1926.757(b)(1) and (2). The hoisting cable would not be released until this welding was completed. Is this procedure acceptable as an alternative to the field-bolting requirement?
No. Section 1926.757(a)(8) provides:
(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.
These requirements apply to the initial attachment of these joists. The Agency determined in the rulemaking that considerations of safety require that these joists be bolted rather than welded for their initial attachment (see 66 FR 5236, January 18, 2001).
Also, under §1926.757(b)(3), joists must be attached, at least at one end,1 "immediately upon placement in the final erection position and before additional joists are placed." Since the standard requires that these joists be field-bolted immediately upon placement, that initial attachment is required to be made before the hoisting line is released. Therefore, keeping the hoisting line in place while the initial attachment is being made is not a precaution that goes beyond the standard; it is a requirement. Consequently, keeping the hoisting line in place would not be a basis for allowing these joists to be initially attached by welding rather than the required bolting.
Question (2): Section 1926.757(c)(1) states that when installing a joist requiring erection bridging under Tables A and B, the hoisting line must not be released until the joist is attached at one end. Does that mean that other joists do not have to be attached at one end before releasing the hoisting line?
No; all joists must be attached, at least at one end (both ends for some) before the hoisting line used to place them is released. As explained in Question (1) above, this is required by §1926.757(b)(3), which states that joists must be attached, at least at one end (both ends for joists over 60 feet), "immediately upon placement in the final erection position and before additional joists are placed."
Section 1926.757(c)(1) states that joists that require erection bridging under Tables A and B must be attached at one end before the hoisting cables are released. As explained in the Preamble to the Final Rule (volume 66 of the Federal Register at page 5238), the purpose of this provision is to provide that joists raised in a bundle need not be attached before the hoist line attached to the bundle was released. Joists raised in a bundle, which typically are those that do not require erection bridging, are often spread to their final attachment points by hand. The Preamble states:
This clarification will allow smaller lighter joists (that do not require bridging and can be landed in bundles) to be placed by hand. Once the joists have been placed in their final position, however, they must be attached in accordance with paragraph (b)(3) of this section [66 FR 5238].
So, if the joist is spread by hand to its final erection position rather than by hoisting line, it simply needs to be attached as soon as it is placed.
Summary of Answers to Questions (1) and (2)
In sum, under §1926.757(b)(3), all joists must be attached immediately upon placement in the final erection position and before additional joists are placed. If hoisting equipment is used to place them in their final attachment position, the hoisting line cannot be released until at least one end (and both ends for joists over 60 feet) is attached. Under §1926.757(c)(1), joists hoisted in bundles need not be attached before the hoisting line releases the bundle. However, as explained in the Preamble (66 FR 5237-5238), once a joist is removed from the bundle, it must be immediately attached in its final erection position before additional joists are placed.
Joists in bays of 40 feet or more must be field bolted. Where these joists are placed with a hoisting line, they must be attached by field bolting at least at one end (at both ends for joists over 60 feet) before the hoisting line is released.
Question (3): May joists 40 feet or longer be bolted and not welded for final attachments?
Yes. Section 1926.757(b)(1) and (2) set out requirements for the final attachment of steel joists and steel joist girders. Under these provisions, employers may elect to make the final attachments by either bolting or welding -- there are specifications in the standard for both options. Either option may be chosen irrespective of whether the joist is required to be initially attached by field bolting. So, if a joist is required by §1926.757(a)(8) to be initially attached by field bolting, the employer may elect to make the final attachment by bolting using bolts that meet the §1926.757(b) criteria for bolted final connections. Alternatively, the final attachment can be made by welding, as long as the final attachment criteria in §1926.757(b) for welded final connections are met.
Question (4): May joists 40-feet or longer be welded for final attachments and then have the field-bolting removed?
Yes. The field-bolting requirement in §1926.757(a)(8) applies to the initial attachment of the joist. If the employer elects to make the final connection by welding, the initial attachment bolts may be removed after the final attachment welding has been done.
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 Assistance], 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
1 At both ends for joists over 60 feet (18.3 m), pursuant to §1926.757(c)(2). [ back to text ]