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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 29, 2002

Gary Leadbetter, VP-Operations
Century Steel Erectors
PO Box 490
210 Washington Avenue
Dravosburg PA 15034

Dear Mr. Leadbetter:

We are writing in response to your letter of March 13, 2002, to the Harrisburg, Pennsylvania Occupational Safety and Health Administration (OSHA) Area Office, regarding the protection of workers in a one-story addition to an existing four-story parking garage. As explained in their March 27 letter to you, OSHA's Regional Office forwarded your letter to us and sent a preliminary response to you.

We apologize for the delay in providing this response. We understand from our recent telephone conversation with you that you are facing the same issue in another, upcoming project.

Your letter states that your company's role in the addition project involves erecting precast "double-T" members weighing 54,000 lbs. You indicate that you are concerned about the safety of the occupants of three offices located in the bottom floor of the garage during the hoisting of these very heavy pre-cast materials. The occupants are not engaged in construction and are not your employees, but rather are employees of other employers. We have paraphrased your questions below.

Question (1): Do the requirements of the steel erection standard apply if a steel erector is doing pre-cast erection work? When erecting pre-cast concrete members, is there a requirement that hoisting routes be pre-planned to ensure that the loads are not suspended above employees?

The steel erection standard (29 CFR part 1926 Subpart R) does not apply to the erection of pre-cast concrete members. The requirement that applies to the hazard of overhead hoisted loads during pre-cast erection is in Subpart N, specifically, §1926.550(a)(19): "All employees shall be kept clear of loads about to be lifted and of suspended loads." Although there is no specific requirement in Subpart N for pre-planning to ensure that employees will be kept clear of overhead loads, as a practical matter the employer will typically need to do some pre-planning to enable it to comply with §1926.550(a)(19).

Question (2): In the scenario above, the following precautions are taken by the pre-cast erector: (a) a schedule is given to the workers in the building that indicates when the pre-cast members will be overhead; (b) the pre-cast erector establishes a communication system (radio or telephone) by which the erector informs the workers in the building that a pre-cast member is about to be hoisted, and they now need to exit the building to a safe area; (c) the workers exit the building to a safe area; then the pre-cast member is hoisted; (d) once the pre-cast member is in place, the all-clear is given to the building workers.

Is this procedure sufficient to meet whatever OSHA obligations the pre-cast erector may have with respect to the hazards of overhead loads posed to the office workers in the bottom floor of the garage

Yes. In addition, note that the employers of the office workers have OSHA obligations under section 5(a)(1) of the Occupational Safety and Health Act to protect their employees from recognized hazards for which there is a feasible means of correction.

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