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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.
March 10, 2006
Mr. Drew Langer
DEM Builders—New York
820 Elmont Road
Elmont, New York 11003-4026
Re: Whether the four-bolt requirement in §1926.755(a)(1) applies to a pre-existing column that will be left in place during a renovation/alteration project.
Dear Mr. Langer:
This is in response to your letter dated August 31, 2005 to the Occupational Safety and Health Administration (OSHA). You ask about the application of 29 CFR 1926.755(a)(1) (column anchorage) to renovation and alteration projects. We apologize for the delay in responding.
We have paraphrased your question as follows:
Question: There are columns with two anchor bolts in a renovation/alteration project in which the building will be increased from 1½ to 2 stories. The plans do not call for altering the column bases, which each have two anchor bolts. The existing columns will be left in place but extended in height. The beams will be disconnected, the existing main roof girders will be jacked up, and the new column extensions will be slid in between the roof girder and the existing columns. Workers will perform these tasks from a lift ¿ they will not be on the steel. In this scenario, are we required to first modify the existing column anchorages from two anchor bolts to four?
Answer: No. Section 1926.755(a)(1) states:
All columns shall be anchored by a minimum of 4 anchor rods (anchor bolts).
There is no indication in the regulatory history that this provision was intended to apply retroactively to existing columns that are left in place. Since the column was already erected and is not being moved or replaced, the requirement does not apply in this scenario.
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