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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.
September 17, 2007
Mr. Barton Foreman
Providence Engineering Corporation
117 S. West End Avenue
Lancaster, PA 17603
Re: Distinction between "column" and "post" in the Safety Standards for Steel Erection, 29 CFR 1926 Subpart R
Dear Mr. Foreman:
This is in response to your fax transmittal dated June 28, 2007, to the Occupational Safety and Health Administration (OSHA). You asked for information regarding the terms "column" and "post" under the Steel Erection Safety Standards, 29 CFR Part 1926 Subpart R.
We have paraphrased your questions as follows:
Question: Subpart R of part 1926 has different anchorage requirements for certain steel support members depending on whether they are classified as "columns" or "posts." At what point is a vertical supporting member considered a "column" instead of a "post"? Under Subpart R, does a support member classified as "post" become a "column" when the member exceeds a specified length or carries more than a specified load?
Answer: In 29 CFR 1926 Subpart R (Steel Erection), 1926.751 defines the terms "column" and "post" as follows:
Column means a load-carrying vertical member that is part of the primary skeletal framing system. Columns do not include posts.
* * *
Post means a structural member with a longitudinal axis that is essentially vertical, that: (1) weighs 300 pounds or less and is axially loaded (a load presses down on the top end), or (2) is not axially loaded, but is laterally restrained by the above member. Posts typically support stair landings, wall framing, mezzanines and other substructures.
Under Subpart R, therefore, a vertical structural member can be considered a "post" only under two specific circumstances, i.e., that it weigh 300 pounds or less and is axially loaded, or that it is not axially loaded but is laterally restrained by the structural member above it. Neither the magnitude of load applied to the member nor the height of the member has any effect on whether that member is classified as a "post" or "column" under Subpart R.1
If you need additional clarification on this subject, please contact us by fax at: U.S. Department of Labor, 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.
Steven F. Witt, Director
Directorate of Construction
1 For background on the development of the anchorage requirements for posts and columns under Subpart R, refer to the rule preamble at 66 Federal Register 5221-23 (January 18, 2001). [ back to text ]