New OSHA standard for steel erection: an outline

By Jim Patterson

This is not your father's steel erection standard. It is much more extensive than the current standard and it imposes new duties upon the "controlling contractor." Fabricators who hire the erector under "furnish & install" subcontracts may become a "controlling contractor."

Tanks and towers are excluded from the new standard, but materials such as aluminum (non-ferrous metals), composites, glass, and plastics will come under the new standard, when they are related to steel erection.

Construction, alterations, and/or repair of bridges, buildings, and structures where steel erection occurs are covered. The "scope" paragraph lists 73 examples of structures where steel erection may occur, including: curtain walls; window walls; storefronts; lift-slab/tilt-up; oil & gas drill rigs and production facilities; conveyors; stackers/reclaimers; ovens; furnaces; stacks; and stone/masonry architectural materials mounted on steel frames.

This standard, subpart R of the U.S. Occupational Safety and Health Administration's (OSHA) construction standards, 29 CFR 1926, was published in the Federal Register (FR) on Jan. 18, 2001 (Vol. 66, No. 12) and becomes effective on July 18, 2001 (Editors Note: An OSHA spokesman notes that the implementation date – because of a review of the standard by the Bush administration and petitions for review filed in the Fourth District Circuit Court in Richmond, VA, by the Steel Joist Institute and the Resilient Floor Institute and in the Washington, D.C. Circuit Court by the Steel Coalition – "is subject to change.").

A copy of the standard can be found and printed off OSHA's Website, www.osha.gov, or you may pick up a copy of the FR at any OSHA office. If you choose to print it from the Website, it is recommended that you print the "Summary & Explanation of the Final Rule", FR page numbers 5199 - 5253.

An outline of the rule follows:

OUTLINE OF PRIMARY ISSUES, SUBPART R, STEEL ERECTION, 29 CFR 1926, revised Jan. 18, 2001:

SCOPE (1926.750): What is covered.

APPROVAL TO BEGIN STEEL ERECTION 1926.752

• Controlling contractor must notify erector in writing when concrete in footings, piers, and walls has attained sufficient strength.
• Controlling contractor must provide proper access roads and laydown for erector.

WORKING UNDER LOADS 1926.753(d)

• Only connectors may work under a suspended load.
• All loads must be rigged by a qualified rigger. This term is not defined. ANSI A10.42-2000, "Qualified Riggers", may be purchased from Global Engineering Documents, Englewood, CO. (800) 854-7179). Two to three week back order.

CHRISTMAS-TREEING is allowed. 1926.753(e)

SHEAR CONNECTORS 1926.754(c)

• Cannot be installed in the shop.
• The term "shear connectors" includes rebar, deformed anchors, threaded studs.

FRAMED METAL DECK OPENINGS 1926.754(e)(2)

• Angle iron or other frame components must be down-turned.
• Holes can only be cut immediately before the equipment fitting over it is installed.
• Workers cutting holes must be protected against falls (1926.760(a)(1)).
• If openings can not be decked over, they must be covered.

DOUBLE CONNECTIONS 1926.756(c)

• Cannot be made unless at least one installed bolt remains in place, or the fabricator supplies a seat or equivalent.
• See Appendix H, "Double Connection, Illustrations of Clipped End Connection, and a Staggered Connection".

PERIMETER COLUMNS 1926.756(e)

• Must extend at least 48" above finished floor to allow installation of wire rope guardrails (called safety cables by OSHA) before next tier (level) is erected.
• Must have holes (or other devices) to allow installation of wire rope guardrails at 42" - 45" and at midpoint (i.e. approx. 21" - 22.5" above finished floor level.
  NOTE: See discussion about guardrails below under FALL PROTECTION.

OPEN WEB STEEL JOISTS 1926.757

• This is most extensive revision. Existing 1926.751 contains approximately 2.5 column inches about joists, whereas the revision contains approximately 34.5 column inches, plus almost a full page of tables, plus three full pages of illustrations (Appendix C - Illustrations of Bridging Terminus Points).
• The intent of this part of the standard is to minimize collapse of steel joints by specifying bridging, and by controlling weight of construction loads placed on steel joists.
• Joists and joist girders may not be used as anchorage for a fall arrest systems unless a qualified person gives written approval.

METAL BUILDINGS 1926.758: OSHA's first rules regarding metal buildings.

FALL PROTECTION 1926.760

• All employees engaged in steel erection activities (which could include trades which are not considered ironworkers - See 1926.750, "Scope") must have fall protection at heights above 15 feet.
• A controlled decking zone (CDZ) may be established over 15 feet and up to 30 feet, provided not more than 3,000 square feet are in the zone, and a leading edge is being established.
• Connectors between 15 - 30 feet height must wear full arrest system and be provided a means to tie off or be given other protection (guardrail or safety net).
• Perimeter wire rope guardrails (which OSHA calls safety cables) must be installed on all final interior and exterior perimeters of a floor as soon as metal decking has been installed.

TRAINING 1926.761

• Training must be provided by a qualified person. Review "definitions" (1926.751) of "competent" and "qualified." First-line supervisors (foremen) may or may not meet the definition of a qualified person.
• Training must cover both fall hazards and Christmas-Treeing, Connecting, and CDZ procedures.

Discussion
Even though this standard was a negotiated rule, with input from labor, general contractors, erectors, vendors, OSHA etc., there is still controversy associated with it. The Steel Joist Institute filed what amounts to an objection to certain provisions of 1926.757. To review this, go to www.steeljoist.com. Click on "What's New", then click on "..."Safety Standards for Erection." I have not seen any response by OSHA to this objection.

In my opinion, OSHA made a serious mistake in allowing ¼" diameter wire rope guardrails (which they call safety cable) at 1926.760(d), outlined in Appendix G, "Fall Protection Systems Criteria and Practices."

The existing standard (1926.750(b)(1)(iii)) calls for ½" wire rope or equal around temporary-planked or temporary-decked floors of multifloored structures. This was done for a couple of reasons: (1) the existing standard was based upon a 1944 ANSI standard; and (2) the ANSI group had determined that ½" diameter wire rope was necessary, due to potential for physical damage to the wire rope during erection. Ellis states that "Wire rope systems (1/2 in. diameter seems adequate) should be considered where accidental collisions with crane-suspended leads are foreseeable."¹

The risk associated with using ¼" diameter wire rope is that a worker will hook his lanyard to it and use it as a horizontal lifeline (HLL). OSHA warned in a non-mandatory appendix to its fall protection standard (Appendix B, "Guardrail Systems...") to 1926.502(d), published in the Federal Register on Aug. 9, 1994 (Vo. 59, No. 152, page 40745) that "...the strength of the horizontal lifeline and the anchorages to which it is attached should be increased a number of times over the lanyard."

Since the lanyard is rated at 5,000 pounds, then the HLL and its anchorages should be capable of two, three, or perhaps six times 5,000 pounds. In Table H-4, "Rated Capacities for Single Leg Slings, 6x19 and 6x37, Improved Plow Steel Rope with IWRC," part of 1926.251, "Rigging Equipment for Material Handling", we find that a ¼" 6x19 rope in a choker hitch is rated between 0.4 - 0.44 tons, but these values are applicable only when D/d ratio exceeds 10 for Hand tucked Splices and 20 for Mechanical Splice and Swaged or Zinc Poured Splice.

Furthermore, these wire rope guardrails will undoubtedly be installed with U-bolt Crosby clips. According to standard rigging handbooks, when properly installed, clipped eye connections develop approximately 80-90 percent of the rope strength.

You do the arithmetic. I'm confident you'll agree with me that if the "perimeter safety cable" (wire rope) can be misused as a HLL, ½" diameter rope should be installed, and a qualified person should design and supervise installation and use of the system (1926.502(d)(8)).

About the author: James T. Patterson, CSP, is vice president of HRH of Denver (CO). He can be reached by telephone at (303) 765-1551 or by e-mail at jimpatterson@hrhdenver.com. This article was originally written as a service for HRH clients and is reprinted with permission (Back to top)

References
¹ Ellis, Nigel, Introduction to Fall Protection, 2d Edition, (American Society of Safety Engineers: Des Plaines, IL) 1993, p. 110.

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