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.

April 5, 2005

Frances Youney
C.Y. Concepts, Inc.
10 Vantage Point Drive, Suite 3
Rochester, NY 14624

Re: Whether moving point-to-point on a concrete wall to make initial connections of structural steel is considered "connecting" work, §1926.760; landing loads on a systems-engineered metal building, §1926.758.

Dear Ms. Youney:

This is in response to your letter dated January 11, 2005, to Mr. John Henshaw, formerly the Assistant Secretary for the Occupational Safety and Health Administration. Your letter was forwarded to the Directorate of Construction for response.

We have paraphrased your questions below:

Question 1: Scenario: To install purlins in a systems-engineered metal building, some contractors hoist a bundle of purlins onto the steel framework, shake the purlins out one at a time by hand, and then bring each purlin to its installation point and attach it. Does the steel erection standard prohibit this practice?

Answer: There are no provisions in 29 CFR Part 1926 Subpart R that prohibit shaking out and installing purlins by hand in a systems-engineered metal building. However, there are some provisions in Subpart R which you should be aware of when using this method.

For example, §1926.758 states in part:

* * * * *
(d) Construction loads shall not be placed on any structural steel framework unless such framework is safely bolted, welded or otherwise adequately secured.
* * * * *
(f) Both ends of all steel joists or cold-formed joists shall be fully bolted and/or welded to the support structure before:
(1) Releasing the hoisting cables;
(2) Allowing an employee on the joists; or
(3) Allowing any construction loads on the joists.
(g) Purlins and girts shall not be used as an anchorage point for a fall arrest system unless written approval is obtained from a qualified person.
(h) Purlins may only be used as a walking/working surface when installing safety systems, after all permanent bridging has been installed and fall protection is provided.
(i) Construction loads may be placed only within a zone that is within 8 feet (2.5 m) of the center-line of the primary support member.

Question 2: Scenario: A structural steel erector is setting steel beams directly onto a concrete block wall with the use of a crane. When the erector is walking the concrete walls to set another steel beam is he/she a "connector" under the steel erection standard? What fall protection requirements apply? Is fall protection required for this worker in this scenario under 15 feet?

Answer: Under §1926.751, a connector is defined as:

"an employee who, working with hoisting equipment, is placing and connecting structural members and/or components."

In the scenario you described the steel erector would be considered a connector. As we stated in Question and Answer #43 in the March 22, 2002, Steel Erection Compliance Directive (CPL 02-01-034), the process of connecting includes moving to and from initial and subsequent points at which these connections are made:

Question 43: Does a connector have to be tied off above 15 feet while moving to an initial beam connection location and while moving to or from subsequent beam connection locations if the crane is busy getting the next piece?
Answer: No. The process of connecting includes moving on the steel to and from initial and subsequent points at which these connections are made.

Therefore, while walking the concrete walls to set another steel beam the erector is considered a connector, and the fall protection requirements for a connector under §1926.760 would apply.

With respect to the applicable fall protection requirements, §1926.760(a) states in part:

(a) General requirements. (1) Except as provided by paragraph (a)(13) of this section, each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6 m) above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems or fall restraint systems.
* * * * *
(3) Connectors and employees working in controlled decking zones shall be protected from fall hazards as provided in paragraphs (b) and (c) of this section, respectively.
* * * * *

Section 1926.760(b) states in part:

(b) Connectors. Each connector shall:
(1) Be protected in accordance with paragraph (a)(1) of this section from fall hazards of more than two stories or 30 feet (9.1 m) above a lower level, whichever is less;
* * *
(3) Be provided, at heights over 15 and up to 30 feet above a lower level, with a personal fall arrest system, positioning device system or fall restraint systems and wear the equipment necessary to be able to be tied off; or be provided with other means of protection from fall hazards in accordance with paragraph (a)(1) of this section.

In your scenario, when an employee is considered a connector and is at heights over 15 and up to 30 feet and is walking the concrete walls to set another steel beam, he/she must be provided with a personal fall arrest system and must "wear the equipment necessary to be able to be tied off" (or be provided with other means of fall protection pursuant to paragraph 1926.760(a)(1)). For heights above 30 feet, Subpart R requires that connectors be protected by fall protection. For heights 15 feet and less, under Subpart R, fall protection is not required to be provided, worn, or used by employees.

If you need additional information, please contact us by facsimile at: U.S. Department of Labor -- OSHA, Directorate of Construction Standards and Guidance 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, NW, Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction