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 https://www.osha.gov.

August 23, 2005

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

Re: Revision of the applicability of the steel erection standard to pre-cast concrete erection work interpretation; §1926.704(e)

Dear Mr. Leadbetter:

This letter is in regard to our response of October 29, 2002, to your March 13, 2002, letter 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. After reviewing the response to Question (1) regarding pre-cast concrete erection work, OSHA has decided to revise its answer to identify a more specific standard that would more appropriately apply to the scenario you presented. We apologize for any confusion or difficulty this change may cause.

The following is a replacement response to your March 27, 2003, inquiry.


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. Instead, Subpart Q, Concrete and Masonry Construction, standards apply to an employer engaged in pre-cast erection work.

Section 1926.704(e) requires that:

No employee shall be permitted under precast concrete members being lifted or tilted into position except those employees required for the erection of those members.

This standard directs an employer who is carrying out this type of work to ensure that only the employees necessary to carry out the erection of pre-cast concrete members be under these during erection work. While pre-planning of the hoist route is not required, planning the lifting or tilting work before beginning erection is likely to be needed to ensure compliance with §1926.704(e).

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 Compliance 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, Director

Directorate of Construction



1 This letter rescinds and replaces our October 29, 2002, letter, Applicability of the steel erection standard to pre-cast concrete erection work; pre-planning of hoisting routes and procedures. Note that we have not changed the answer to Question (2) of the October 29, 2002, letter. [back to text]