Clarification of "Controlling Contractor" duties under the Steel Erection Standard (1926 Subpart R)

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 https://www.osha.gov.

January 30, 2002

The Honorable Dennis Moore
U.S. House of Representatives
Washington, DC 20515-1603

Dear Mr. Moore:

I am writing in response to your October 31, 2001, letter. I apologize for the long delay in responding. As a result of government mail delivery delays due to the anthrax decontamination process, we did not receive your letter until December 31, 2001.

Written notification of ASTM strength test for mortar in masonry piers/walls prior to steel erection.

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 https://www.osha.gov.

May 21, 2003

Rashod R. Johnson
Director of Engineering
Mason Contractors Association of America
33 S. Roselle Road
Schaumburg, Illinois 60193

Re: Requirement in 29 CFR 1926.752 for steel erector to obtain written notification of strength test for mortar in masonry piers/walls prior to steel erection.

Dear Mr. Johnson:

Mortar testing requirements and controlling contractor responsibilities under the Steel Erection Standard

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 https://www.osha.gov.

December 27, 2002

Sean Purcell
Safety Officer
RPCarbone Company
5885 Landerbrook Drive, Suite 110
Cleveland, OH 44124-4031

Re: What are an employer's obligations under Part 1926 Subpart R with respect to testing mortar? What OSHA responsibilities does a controlling contractor have under Subpart R when it subcontracts duties placed by Subpart R on the controlling contractor? §1926.752(a)(1); mortar testing requirements; contracting-out duties of controlling contractor

Dear Mr. Purcell:

Field-cured concrete sample cylinders must be subjected to similar conditions as the footings/walls; acceptable use of the Windsor Probe/Pin testing method.

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 https://www.osha.gov.

October 27, 2003

Andrew G. Forrest, Jr.
Safety Coordinator
Lincoln Construction Inc.
4790 Shuster Road
Columbus, OH 43214-1997

Re: Whether a controlling contractor may heat concrete cylinder samples in performing concrete strength testing under 29 CFR 1926.752(a)(1); whether a controlling contractor may use a Windsor Probe and Pin test to meet the requirements for testing concrete footings, piers, and walls prior to authorizing commencement of steel erection under 29 CFR 1926.752(a)(1).

Requirements for compressive-strength testing of concrete and mortar in a masonry wall during steel erection.

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 https://www.osha.gov.

August 23, 2004

Dennis Vance
Dennis Vance Safety, LLC
711 Low Gap Road
Princeton, WV 24740-2236

Re: Employer's obligations in the steel erection standard (29 CFR Part 1926 Subpart R) under §1926.752(a)(1) with respect to testing concrete and/or mortar in a masonry wall.

Dear Mr. Vance:

Whether the notification required in §1926.752(a)(1) (attained concrete strength) must be given where steel will be erected on a long-existed concrete slab.

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 https://www.osha.gov.

March 10, 2006

Jamie Stevenson
James Construction
243 E. Main Street, Suite 203
Carnegie, PA 15106

Re: Whether the notification required in §1926.752(a)(1) (attained concrete strength) must be given where steel will be erected on a long-existed concrete slab.

Dear Mr. Stevenson:

Notification requirements for concrete compressive strength and anchor bolt modifications.

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 https://www.osha.gov.

December 23, 2005

Mr. Skinner
[By e-mail]

Re: Notification requirements for concrete compressive strength and anchor bolt modifications.

Dear Mr. Skinner,

This is in response to the e-mail correspondence you sent to this office on November 17, 2005. Your questions have been paraphrased as follows: