|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 24, 1981
||ACTING REGIONAL ADMINISTRATOR|
||JOHN B. MILES|
||BRUCE HILLENBRAND, DEPUTY DIRECTOR|
[Directorate of Cooperative and State Programs]
||Fall Hazards in Steel Erection|
||Memorandum dated May 14, 1981.|
In answer to your first question regarding fall hazards in steel erection, we do accept, as a general proposition, the premise that connectors need not be tied off when initially connecting steel members together. However, occasionally there are situations in which connectors are in one location for an extended period of time and are not in danger of being struck by suspended steel. In such situations, the connector should tie off as per 29 CFR 1926.105 or 1926.28. Although we do not believe that connectors ordinarily ought to be required to tie off, they must be protected from falling hazards by other means in many situations. On a multi-story building for example, there must be either a tightly decked floor or a safety net directly below them in the interior of the building within two floors or thirty feet, whichever is less, (25 feet if nets are being used) or the employer should be cited for violation of 29 CFR 1926.750. In a non-tiered building, connectors performing work other than connecting must be protected from falls in excess of 25 feet by 29 CFR 1926.105.
If ironworkers, including connectors, performing work other than connecting are exposed to more than a two story or 25 foot fall to the outside of the building they should be protected as required by 29 CFR 1926.750(b)(1)(iii) or 1926.105(a) and 1926.105(c)(1), where it is possible to do so and when the rigging of such nets does not create greater hazards than allowing employees to work unprotected from the falling hazards.
The answer to your second question is that 29 CFR 1926.105(a) and 1926.105(c)(1) require that employees performing work other than connecting be protected from perimeter falls exceeding 25 feet regardless of whether decking or netting is being used to protect employees from interior fall decking is being used on the interior we would not recommend issuance of a citation if the employer complies with 29 CFR 1926.750(b)(1)(iii) or 1926.105(a) and 1926.105(c)(1) for exterior fall protection of ironworkers performing other than connecting work if the fall distance is between 25 and 30 feet above the ground.
In response to your third question falling hazards with regard to distances of less than 25 feet are addressed by 29 CFR 1926.28(a). Essentially, employers are required to enforce the use of tied off safety belts when their employees are exposed to a hazard and it is possible to use safety belts without creating greater hazards. Additionally, a Fifth Circuit U.S. Court of Appeals decision, which may be applicable in all or part of your Region, (the courts are redistricting at this time) would allow us to enforce the use of tied off safety belts for falls of less than 25 feet only in those situations in which industry custom and practice is to use tied off safety belts. It is customary in the industry to use tied off safety belts in situations in which employees are stationary, for example, when they are doing structural welding and bolting-up.
[Correction 6/20/2005. See OSHA Directive CPL 02-01-034 "Inspection policy and procedures for OSHA's steel erection standards for construction" published on 3/22/2002 for the current policy on OSHA's steel erection standards (1926 Subpart R) for construction.]