OSHA's New Steel Erection Standards - Something for Everyone
By Michael W. Dvorak, Esq.
The nation’s iron workers have enhanced workplace safety protections as a result of the Occupational Safety and Health Administration’s (“OSHA”) new steel erection standards in construction.  The new standards address hazards identified as the major causes of injuries and fatalities in the steel erection industry such as: working under loads; hoisting, landing and placing decking; column stability; double connections; landing and placing steel joints; and falls to lower levels. The new standards protect all workers engaged in steel erection activities. 
The new standards will also affect the daily activities of general contractors and construction managers. The previous standards did not assign specific duties for controlling contractors. A controlling contractor is defined in the new standards as "a prime contractor, general contractor, construction manager or any other legal entity which has the overall responsibility for the construction of the project—its planning, quality and completion." 29 CFR § 1926.751 (2002 ed.). The duties of controlling contractors under the new standards include provisions governing construction sequence, column anchorage, falling object protection, and fall protection.
The previous standards  that governed steel erection were also more limited in scope. Those standards covered flooring requirements, structural steel assembly, bolting, riveting, fitting-up, and plumbing-up.
The provisions of the new steel erection standards include site layout and construction sequence; site-specific erection plans; hoisting and rigging; structural steel assembly; column anchorage; beams and columns; open web steel joists; systems-engineered metal buildings; falling object protection; fall protection; and training.
The new standards went into effect January 18, 2002, however, OSHA did not begin conducting general schedule inspections until March 19, 2002.
The new rules are expected to save employers nearly $40,000,000 a year by preventing dozens of fatalities and thousands of injuries. Preventing injuries and fatalities in the steel erection industry and the anticipated employer savings are laudable goals. Additionally, the new standards will have an impact on the day to day activities of persons involved in construction, including contractors, subcontractors, construction managers and owners. This Briefing Paper will analyze the impact the new standards will have on those daily activities. 
Scope of New Standards
The new standards set forth requirements to protect construction industry workers from the hazards associated with steel erection activities involved in the construction, alteration, and/or repair of single and multi-story buildings, bridges, and other structures. Steel erection activities include, but are not limited to, hoisting, laying out, placing, connecting, welding, burning, guying, bracing, bolting, plumbing and rigging structural steel, steel joists and metal buildings; installing metal decking, curtain walls, window walls, siding systems, miscellaneous metals, ornamental iron and similar materials; and moving from point-to-point while performing these activities.
Site Layout and Construction Sequence
The new standards require certification that concrete in footings, piers and walls and the mortar in the masonry piers and walls has attained either 75% of the intended minimum compressive design strength or sufficient strength to support the loads imposed during steel erection. The controlling contractor must notify the steel erector in writing that this requirement has been met before authorizing commencement of steel erection.
The controlling contractor also is required to provide the steel erector with a safe site layout. This includes adequate access roads into and through the construction site for the delivery and movement of derricks, cranes, trucks, other necessary equipment, and the material to be erected. Additionally, it is the controlling contractor's duty to provide a properly graded, drained area, readily accessible to the work with adequate space for the safe storage of materials and the safe operation of the steel erector's equipment.
Site-Specific Erection Plan
The new standards require pre-planning of key erection elements, including coordination with the controlling contractor before steel erection begins. A site-specific erection plan must be created by a "qualified person" and be available at the worksite when employers elect to develop alternate means and methods to provide employee protection due to conditions unique to the worksite. A qualified person is defined as one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the work or the project.
The site-specific conditions include hoisting and rigging safety latches on hooks, steel joist stability where the joists span more than 60 feet and are at or near steel columns, and landing or placing bundles of decking on steel joists before all bridging has been installed and anchored. It is the duty of all employers to ensure that site-specific erection plans provide for the protection of their employees on the worksite.
Hoisting and Rigging
The new standards provide additional crane safety for steel erection, minimize employee exposure to overhead loads through pre-planning and work practice requirements, and prescribe proper procedures for multiple lifts or "Christmas-treeing".
Cranes used in steel erection must be visually inspected before each shift by a competent person. A competent person is defined as one who is capable of identifying existing and predictable hazards in the working conditions which are dangerous to employees and who has authorization to take prompt corrective measures to eliminate the hazards. The visual inspection must include all control mechanisms, drive mechanisms, safety devices such as boom stops and anti-two block devices, pressurized air and hydraulic lines, hooks and latches, wire rope reeving, electrical apparatus, tires, and ground conditions around the hoisting equipment.
The crane operator is responsible for those operations under his or her direct control. The operator has the authority to stop and refuse to handle loads until safety has been assured. Additionally, a rigger, who is also a "qualified person" under the rule, must inspect the rigging before each shift.
The new standards also address working under loads. Routes for suspended loads must be pre-planned to ensure that no employee is required to work directly below a suspended load except for employees engaged in the initial connection of the steel or employees necessary for the hooking or unhooking of the load. When employees are working under suspended loads, the load must be rigged by a qualified rigger.
Multiple lifts or "Christmas-treeing" procedures are strictly governed by the new standards. A multiple lift must meet the following criteria: use of a multiple lift rigging assembly; no more than five members hoisted per lift; only beams or structural members lifted; and the crane's specifications and limitations permit such use. Additionally, the total load must not exceed the rated capacity of the hoisting equipment specified in the load charts or the rigging capacity specified in the rigging rating chart.
Structural Steel Assembly
The new standards provide for safer walking or working surfaces by eliminating tripping hazards and creating new slip resistance requirements. The new standards also provide rules regarding landing deck bundles and interior opening fall hazards.
The placement of shear connectors, such as headed steel studs, steel bars or steel lugs, and other similar devices are regulated to reduce tripping hazards on walking or working surfaces. These devices may not be attached to the top flanges of beams, joists or beam attachments so that they project vertically from or horizontally across the top flange member until after the metal decking, or other such surface, has been installed. Additionally, slip resistance of skeletal structural steel has been addressed by the new standards. Workers are not permitted to walk the top surface of any structural steel member installed after July 18, 2006 that has been coated with paint or a similar material unless that coating has a minimum average slip resistance of .50, based on the appropriate ASTM standard test method. It is important to note that the slip resistance standard does not take effect until 2006, unlike the other requirements under the new standards which took effect at the beginning of this year.
The hoisting, landing and placing of metal decking bundles are regulated by the new standards. Bundle packaging and strapping may not be used for hoisting unless specifically designed for that purpose. Loose items placed on top of metal decking bundles to be hoisted must be secured to the bundles. Further, metal decking bundles must be landed on framing members in such a way that the bundles can be unbanded without dislodging them from the supporting surface.
Interior opening fall hazards are minimized by regulating procedures for installing metal decking at roof and floor holes and openings. The regulating procedures command that framed metal deck openings must have structural members turned down to allow for continuous deck installation. Additionally, roof and floor holes and openings must be decked over or, for openings such as elevator shafts and stair wells which do not allow for decking over, protection by guardrail systems, safety net systems or fall restraint systems must be in place.
Steel column stability is addressed by the new standards. The new standards require four anchor bolts per steel column in addition to other column stability requirements and procedures for ensuring the adequacy of anchor bolts that have been modified in the field.
In addition to requiring four anchor bolts per column, the steel columns must be set on level-finished floors adequate to transfer the construction loads. Finally, all steel columns must be evaluated by a competent person to determine whether guying or bracing is necessary to provide stability.
If anchor bolts are repaired, replaced or modified in the field, the project structural engineer must first approve those actions. Further, if such actions are taken, the controlling contractor must provide written notification to the steel erector before erection of that steel column begins.
Beams and Columns
The new standards minimize the dangerous collapse hazards associated with making double connections at steel columns. When two structural members on opposite sides of a steel column web are connected sharing common connection holes, at least one bolt must remain connected to the first member unless a field-attached seat or equivalent connection device is supplied to secure the first member and prevent the steel column from being displaced.
If a seat or equivalent device is used, the seat must be designed to support the load during the double connection process. It must be adequately bolted or welded to both a supporting member and the first member before the shared bolts are removed to make the double connection.
Open Web Steel Joists
Requirements in the new standards minimize the chance of collapse of lightweight steel joists and the chance of collapse when placing loads on steel joists.
The previous standards required that where steel joists are used and columns are not framed in at least two directions with solid web structural steel members, a steel joist must be field-bolted at the column. The new standards add requirements that a vertical stabilizer plate be provided on each column for steel joists, the bottom chords of steel joists at columns must be stabilized to prevent rotation during erection, and that hoisting cables may not be released until the seat at each end of the steel joist is field-bolted.
The new standards also address placing loads on steel joists. The employer placing a load on steel joists must ensure that the load is distributed so the carrying capacity of any steel joist is not exceeded. Additionally, no construction load is allowed on steel joists until all bridging is installed and anchored and all joist-bearing ends are attached.
Systems-Engineered Metal Buildings
The new standards also address requirements for the construction of systems-engineered metal buildings which account for a major portion of the steel erection in the United States. The requirements minimize the chance of collapse during the erection of these specialized structures.
The requirements include that each structural column must be anchored by at least four anchor bolts, that rigid frames must have 50% of the bolts installed on both sides of the web adjacent to each flange before the hoisting equipment is released, and that construction loads must not be placed on any structural steel framework unless the framework is safely bolted, welded or otherwise adequately secured.
Falling Object Protection
The new standards add a duty for the controlling contractor regarding protection from falling objects during steel erection.
The controlling contractor must eliminate other construction processes below steel erection activities unless overhead protection for the employees below is provided. This requirement is in addition to the previous standards' requirement that all materials, equipment, and tools which are not in use while aloft, must be secured against accidental displacement.
The new standards set forth requirements regarding fall protection for workers in controlled decking zones ("CDZ") and other areas at heights greater than 15 feet. CDZ is an area where certain work, such as the initial installation and placement of metal decking, forms the leading edge of a work area and may take place without the use of guardrail systems, personal fall arrest systems, fall restraint systems, or safety net systems and where access to the area is controlled.
Each employee engaged in a steel erection activity who is on a walking or working surface with an unprotected edge more than 15 feet above a lower level must be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems or fall restraint systems. On multi-story structures, perimeter safety cables must be installed at the final interior and exterior perimeters of the floors as soon as the metal decking has been installed.
Connectors and employees working in a CDZ must be protected from fall hazards as steel erection employees are on a walking or working surface with an unprotected edge more than 15 feet above a lower level. Connectors are employees who, working with hoisting equipment, are placing and connecting structural members and/or components. The boundaries of a CDZ must be designated and clearly marked by the use of control lines or the equivalent. Additionally, final deck attachments and the installation of shear connectors must not be performed in a CDZ.
Finally, fall protection provided by the steel erector may remain in the area where steel erection activity has been completed if the controlling contractor directs the steel erector to do so and has inspected and accepted control of the fall protection area.
The new standards also require training by qualified persons of workers in the areas of fall protection and specialized, high risk activities.
The new standards require employers to provide training for all employees exposed to fall hazards. The training must include the following: the recognition and identification of fall hazards in the work area; the use and operation of fall protection systems; the correct procedures for erecting, maintaining, disassembling, and inspecting fall protection systems; and the procedures to prevent falls to lower levels and through or into holes and openings in walking or working surfaces and walls.
In addition to the training required for employees exposed to fall hazards, employers must provide special training to employees engaged in multiple lift rigging, connecting, and working in a CDZ.
OSHA’s new steel erection standards, Construction Safety and Health Standards, Subpart R, 29 CFR §§ 1926.750-761, became effective earlier this year. Anyone involved in steel erection construction must be familiar with the new requirements. Failure to comply with the new regulations may expose parties to OSHA liability as well as liability for work place injuries.
 OSHA Construction Safety and Health Standards, Subpart R, 29 CFR §§ 1926.750-761 (2002 ed.).
 The new standards do not cover, however, electric transmission towers, communication towers, broadcast towers, water towers or water tanks. Those rules are the first OSHA safety standard developed under the Negotiated Rule Making Act of 1990 and the Department of Labor's Negotiated Rule Making Policy.
 OSHA Construction Safety and Health Standards, Subpart R, 29 CFR §§ 1926.750-.752 (1999 ed.).
 OSHA and the U.S. Department of Labor have issued directive No. CPL2-1.34 regarding the inspection policies and procedures for OSHA’s steel erection standards for construction. A listing of relevant questions and answers regarding the new standards issued by OSHA and the U.S. Department of Labor can be found on OSHA’s web site located at http:// www.osha-slc.gov/pls/oshaweb/owadisp.show.
This discussion is generalized in nature and should not be considered a substitute for professional advice. © FWH&T