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.

 

 

November 3, 2005

Mr. Joseph J. Hunt
General President
International Association of Bridge, Structural, Ornamental and
Reinforcing Iron Workers
1750 New York Avenue, N.W., Suite 400
Washington, D.C. 20006

Re: Slip resistance of skeletal structural steel.

Dear Mr. Hunt:

Thank you for your letter of September 7, 2005. A similar letter was received by Acting Assistant Secretary Jonathan L. Snare. It is my understanding that Mr. Snare will provide a written response to your concerns regarding the shop-installation of shear studs and the requirement for a fully planked or decked floor below steel erection activity.

In addition, you reference a letter dated June 3, 2005, addressed to Acting Assistant Secretary Snare, which discusses the American Institute of Steel Construction's concerns regarding §1926.754(c)(3), slip resistance of skeletal structural steel. As you are aware, on July 15, 2004, the Agency issued a Federal Register Notice reopening the record on §1926.754(c)(3). The Agency sought comments from the industry on the key issues involved in the slip resistance of skeletal structural steel. In this notice, the Agency stated that based on the entire rulemaking record, it would amend, revoke or retain §1926.754(c). The record closed on October 13, 2004. The Agency will issue a final rule announcing whether it will amend, revoke or retain this provision no later than January 18, 2006. We realize this decision is time sensitive for the industry and we will do our best to ensure that the industry is informed as soon as possible.

We appreciate the time and effort your organization has committed to these issues.

Sincerely,



Russell B. Swanson, Director
Directorate of Construction