June 1, 2012
Mr. Eddie Campbell
Accelerated Building Solutions, Inc.
105 Fieldstone Dr. Suite 105
Milledgeville, GA 31061
Dear Mr. Campbell:
Thank you for your September 13, 2011 fax to the Occupational Safety and Health Administration (OSHA) Directorate of Construction. You have asked a specific question about steel erection under OSHA standard § 1926.756(a)(1).
Question: Does OSHA standard § 1926.756(a)(1) stipulate the use of double connections at beams not framing into columns in spite of the clarification given in OSHA's May 9, 2006 letter to Mr. Doug Brown?1
Response: No, 29 CFR § 1926.756(a)(1) does not stipulate the use of double connections at beams not framing into columns. Instead, it requires the ironworker or connector to secure at least two bolts per connection at all initial connections on a structural member before the hoisting line may be removed. The letter you reference in your fax, OSHA's May 9, 2006 letter to Mr. Brown, discusses OSHA standard § 1926.756(c). The requirements of § 1926.756(a)(1) and § 1926.756(c)(1) are separate and distinct, and OSHA's letter to Mr. Brown does not address the requirements of § 1926.756(a)(1).
Section 1926.756(a)(1) establishes beam and column connection requirements during the hoisting and placing of solid web structural members. These requirements must be met before the hoisting line may be removed from structural members, thereby transferring the weight of the structural members from the hoisting device to the structure itself. Section 1926.756(a)(1) does not distinguish between double connections and other kinds of connections. It applies generally to all initial connections, regardless of whether the structural members frame into columns. Section 1926.756(a)(1) states:
During the final placing of solid web structural members, the load shall not be released from the hoisting line until the members are secured with at least two bolts per connection, of the same size and strength as shown in the erection drawings, drawn up wrench-tight or the equivalent as specified by the project structural engineer of record, except as specified in paragraph (b) of this section [emphasis added].
On the other hand, § 1926.756(c), entitled "Double connections at columns and/or beam webs over a column," establishes specific procedural requirements to ensure that structural stability is maintained during beam attachment under circumstances "[w]hen two structural members on opposite sides of a column web, or a beam web over a column, are connected sharing common connection holes." OSHA also defines the term "double connection" under § 1926.751 (definitions) as "an attachment method where the connection point is intended for two pieces of steel which share common bolts on either side of a central piece." The use of a double connection is determined by the structural engineer designing the structure and is never "required" by an OSHA standard. However, when double connections are made, the connections must be made in compliance with § 1926.756(c).
In OSHA's letter to Mr. Brown, we stated that "[s]ection 1926.756(c) by its terms does not apply to double connections made at a beam away from a column." This is clear from the plain language of the standard. We explained in our letter that § 1926.756(c) "addresses the injuries and deaths of workers caused by the collapse of double connected steel members which occur when the beam ends being connected are not supported by the column at all times." The preamble for the steel erection standard published in Volume 66 of the Federal Register, published January 18, 2001, at 5225-27 also provides a detailed description of the specific erection process which §1926.756(c) concerns, and the types of hazards created by this process.2
In sum, § 1926.756(a)(1) and § 1926.756(c) are separate requirements for steel erection, and OSHA's May 9, 2006 letter to Mr. Doug Brown concerning § 1926.756(c) does not limit or impact the requirements of § 1926.756(a)(1).
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction
1 As your letter notes, OSHA's May 9, 2006 letter to Mr. Doug Brown is available at http://www.osha.gov/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25357. [Return to Text]
2 66 FR 5225-27 is available online at http://www.osha.gov/FedReg_osha_pdf/FED20010118.pdf. [Return to Text]