Steel erection fall protection and temporary floors

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 4, 1992
Mr. Rueben L. Raysor
Area Safety Manager
Bechtel Savannah River, Inc.
[Recipient address omitted]

Dear Mr. Raysor:
This is in response to your letters of July 8 and August 27, concerning the Occupational Safety and Health Administration (OSHA) policy regarding fall protection requirements for steel erection activities. We apologize for the delay in responding to you.

With regard to your questions number 1 through 4, we have been advised by the Office of the Solicitor that Review Commission cases have determined that, other than 29 CFR 1926.105(a), there are no specific fall protection provisions or exemptions, outside Subpart R, that apply to steel erection connection-related activities. Consequently, the general duty clause is the only provision that can be cited for steel erection fall hazards where the fall distance is less than 25 feet. To assist in establishing the existence of the necessary four elements of [an OSHAct 5(a)(1)] citation, the National Office is developing an information package for use by all regions. Although not complete at this time, the information that has been compiled indicates that abatement methods can include the use of properly guarded aerial scaffolds and similar platforms, lifts, ladders, nets, or body belt/harness systems.

With regard to question 5, 29 CFR 1926.750(b)(2)(ii) states that where it is not practical to maintain a "tightly planked" (i.e. temporary) floor within two stories or 30 feet of locations where work is performed, then 29 CFR 1926.750(b)(1)(ii) applies and nets or scaffolds are required. Stated another way, where a temporary floor is maintained within two stories or 30 feet of such locations then 29 CFR 1926.750(b)(1)(ii) does not apply, and nets or scaffolds are not required.

With regard to questions 6 and 7, "scooting" or "cooning" the beam with a lanyard wrapped around the beam is an acceptable practice, as is the practice of wrapping lanyards around beams as tie off points.

With regard to question 8, OSHA Instruction STD 3-3.1 is being reviewed in light of the advice received from the Office of the Solicitor and the policy discussed above in response to questions 1-4.

If you need further assistance, please call [the Directorate of Construction at 202 693-2020].

Sincerely,

Patricia K. Clark, Director
[Directorate of Enforcement Programs]

[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.]

[Requester correspondence reproduced on OSHA page; omitted here.]