- 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.
January 23, 2003
Michael A. McCarroll, CSP
PROSAFE Solutions, Inc.
P.O. Box 606
Villa Rica, GA
Re: Whether 1926 Subpart R permits an extensible boom forklift to be used to lift joists up for spreading by hand; whether OSHA requirements limit the number of joists that may be lifted by an extensible boom forklift.
Dear Mr. McCarroll:
This is in response to your telephone request of December 12, 2002,1 in which you ask for guidance regarding the use of an extensible boom forklift to lift joists up for spreading by hand on a structure. We have paraphrased your questions below:
Question (1)(a): Scenario: several steel joists are lifted by an extensible boom forklift (such as a Lull). The forklift is maneuvered so that the forklift tongs bring the joists to the area where the first joist is to be attached. Two workers remove the first joist from the forklift, place it at its final attachment point and attach it to the structure. The forklift then moves to the area where the second joist is to be attached, and the process is repeated. Is this procedure prohibited by the steel erection standard? If not, do the requirements in §1926.757 apply to this procedure?
The steel erection standard, 29 CFR Part 1926 Subpart R, does not prohibit this method of erecting joists. The procedure is similar to using a forklift or crane to hoist a bundle of joists up to the structure, and then manually spreading each joist to its final attachment point and attaching it. The only difference in the method you describe is that the joist is brought near to the final attachment point with a forklift before the joist is manually removed and taken to its final attachment point. There are no provisions in the standard that prohibit either procedure.
Since this procedure is for the erection of steel joists, the requirements of Subpart R apply, including those in §1926.757. Note that the only requirements in this section that do NOT apply to the procedure you have described are certain prohibitions regarding releasing the hoisting line -- since the joists in your scenario are spread and placed by hand.
The other requirements in the section DO apply. These vary with the joists' length, type, and location. There are requirements for immediate attachment, specified types of initial attachment, maximum number of workers allowed on a joist, bridging requirements, and final attachment specifications. 2 We have attached a CD PowerPoint demonstration that explains the 1926.757 requirements. If you have questions about these and how they would apply to your scenario, please let us know.
Question (1)(b): Is there a limit on the number of joists that may be loaded on the extensible boom forklift when using this procedure for erecting joists?
The steel erection standard does not contain specific limitations on the number of joists that may be loaded on the forklift. However, requirements that pertain to material handling equipment include 29 CFR 1926.602(c) (Lifting and hauling equipment (other than equipment covered under Subpart N...). One of the requirements in that section is the following:
- (1) Industrial trucks shall meet the requirements of §1926.600 and the following: (i) Lift trucks, stackers, etc. shall have the rated capacity clearly posted on the vehicle.... These ratings shall not be exceeded. [Emphasis added.]
Therefore, the maximum number of joists that are permitted to be loaded on the forklift depends on their combined weight relative to the rated capacity of the forklift.
If you need additional information, please 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
1You had originally written to us by letter dated January 3, 2001, and we included Question and Answer #31 in the steel erection compliance directive (CPL 2-1.34) to address your question. The purpose of this letter is to respond to your request for more specific guidance. [back to text]
2Some of these apply only to the longer joists, which are not typically spread by hand due to their weight. [back to text]