03/11/2004 - Prohibition of installation of sheer connectors and pour-stop angles to to...

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Standard Interpretations
03/11/2004 - Prohibition of installation of sheer connectors and
pour-stop angles to top flange of steel steel beams prior to
decking.

Standard Interpretations - Table of Contents

• Standard Number: 1926.754(c); 1926.754(c)(1); 1926.754(c)(1)(i)

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.

March 11, 2004

Mr. Mike Mathisen

Plant QA Manager
Central Western Fabricators, Inc.
400 West Second Street
Atlantic, Iowa 50022-1001

Re: Part 1926 Subpart R, §1926.754(c)(1); shop-installed shear connectors; shop-installed

pour-stop angles

Dear Mr. Mathisen:

This is in response to your fax dated December 4, 2003, to the Occupational Safety and
Health Administration (OSHA) in which you ask about a fabricator's responsibility for
compliance with OSHA requirements if it follows design instructions, from the erector or
engineer of record, that do not conform to 29 CFR 1926.754(c). You also ask whether pour-
stop angles are covered by §1926.754(c)(1) and thus prohibited from being shop-installed.
We apologize for the delay in responding.

We have paraphrased your questions as follows:

Question 1a: Scenario: A steel erector requests that a steel fabricator [shop-installed shear
connectors be attached] to the top flange of steel beams, joists and beam attachments. Can
the steel fabricator be cited for a violation of 29 CFR 1926.754(c)(1)(i) if it follows this
request?

Answer
Title 29 CFR 1926.754(c)(1)(i) "Walking/working surfaces" states:

Tripping hazards. Shear connectors (such as headed steel studs, steel bars or
steel lugs), reinforcing bars, deformed anchors or threaded studs shall 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 of the member until
after the metal decking, or other walking/working surface, has been installed.

Shear connectors are prohibited from being installed prior to the decking where they project
either vertically from the top flange of the beam, or horizontally across the top flange of the
beam. As explained in the preamble of the final rule "when attachments, like shear
connectors, are shop-welded to the top flange of beams, the resulting projections can create
a significant tripping hazard."1 These pose a tripping hazard because, during the steel
erection process, the top flanges of the beams serve as a walking surface.

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In OSHA Directive CPL 02-01-034 [formerly CPL 2-1.34] ("Inspection policy and procedures
for OSHA's steel erection standards for construction"), we included the following Question and
Answer:

Question 25: I have beams with shop-installed shear connectors at 20 feet. If

the employer requires the use of fall protection for all workers, including
connectors and deckers, would the presence of the shop-installed shear
connectors on these beams still be a violation under §1926.754(c)(1)?

Answer: No. If an employer requires that all workers, including those engaged in
connecting and in decking (as well as deckers in a CDZ), be protected from falls
by conventional fall protection, then the failure to meet the requirements of
§1926.754(c)(1) would be considered de minimis, and no citation would be
issued.

Therefore, erecting a steel beam (joist or beam attachment) with shop installed connectors is
prohibited unless all exposed workers are protected by fall protection. You ask whether a
fabricator is subject to an OSHA citation for shop-installing shear connectors. Title 29 CFR
1926.750 of the steel erection standard states:

(a) This subpart sets forth requirements to protect employees 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
where steel erection occurs. The requirements of this subpart apply to
employers engaged in steel erection unless otherwise specified ....
[Emphasis added.]
***
(b)(1) Steel erection activities include 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 point-to-point while performing these activities.

Subpart R thus applies only to those engaged in steel erection activities. Steel fabrication by
itself is not considered a "steel erection activity" under §1926.750(a) or (b). Therefore, for
purposes of this standard, unless a fabricator is erecting the beams it has welded the shear
connectors to, or performing some other activity covered by the standard, it is not engaged in
steel erection activities and therefore would not be subject to a citation for violating
§1926.754(c)(1).

However, we must caution you that although the fabricator is not subject to an OSHA citation
under §1926.754(c)(1) for shop-installing shear connectors, whoever is the current erector
(or a replacement erector) is required under the standard to refuse to erect beams that have
shop-installed shear connectors unless all exposed workers, including those engaged in
connecting and in decking (as well as deckers in a CDZ), are protected by conventional fall
protection in accordance with the directive. In your scenario, the original erector requests the
shear connectors to be shop-installed. As long as that erector is willing to comply with the
100-percent fall protection policy described in the directive, it is permitted to erect those
beams. But if that erector were to be replaced, a subsequent erector would be similarly
prohibited from erecting such beams unless it, too, were willing to comply with the 100-
percent fall protection policy.

The issues of the steel fabricator's potential contract or tort liability, should the steel erector
refuse to erect the beams, erect them but not enforce 100-percent fall protection, or in the
event that an accident were to occur as a result of the use of beams with shop-installed shear
connectors, are legal questions that are beyond the purview of this office to answer.

Question 1b: The engineer of record requests that a steel fabricator shop install sheer
connectors to the top flange of steel beams, joists and beam attachments. Will the steel
fabricator be cited for an OSHA violation if it follows this request?

Answer
As explained above, a steel fabricator would not be cited under §1926.754(c)(1) unless it was
engaged in a steel erection activity. However, in many instances the engineer of record is not
affiliated with the steel erector. While the engineer may request shear connectors to be shop-
installed, the erector would be prohibited from erecting those beams unless it was willing to
comply with 100-percent fall protection as detailed in the directive.

As discussed above, it is outside this office's purview to comment on contractual, tort, or

other legal liability issues.

Question 2: Does §1926.754(c)(1) also prohibit the shop welding of a pour-stop angle on
the top flange of a beam as shown in the illustration below?

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Answer
Yes; we addressed this issue in our December 24, 2003, letter to Mr. Ward. Section 1926.754
(c)(1)(i) applies to "shear connectors and other similar devices." [Emphasis added.] Read
as whole, the focus of the standard is on tripping hazards associated with field-installed
attachments.2 The welding of the base of the pour-stop angle to the top flange effectively
extends the width of that flange and becomes part of the walking surface. Since the upturned
angle rises vertically from the (extended) flange, the tripping hazard addressed by §1926.754
(c)(1)(i) is created, and the shop attachment of the pour-stop angle to the beam would
violate the provision. However, as explained in Question 1(a) above, this violation would be
considered de minimis if 100-percent fall protection is used in accordance with Question and
Answer 25 in the steel erection directive. 3

If you need additional information, please contact us by fax (202-693-1689) at: U.S.
Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also
contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and
Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although
there will be a delay in our receiving correspondence by mail.

Sincerely,

Russell B. Swanson, Director

Directorate of Construction

1
See 66: Federal Register, page 5213, January 18, 2001. [ back to text ]

2
As stated in the Preamble to the Final Rule for Safety Standards for Steel Erection at 66 Fed.
Reg. 5213 (January 18, 2001): "Paragraph (c) of the final rule sets forth requirements that
address slipping/tripping hazards encountered when working on steel structures. * * * when
attachments * * * are shop-welded to the top flange of beams* * *. Field installations of
these attachments can significantly reduce exposure to this hazard." [ back to text ]

3
Note that this directive will be updated in the upcoming months. All Questions and Answers
from the original version will be carried over into the revised directive, but will have new
numbers. [ back to text ]

Standard Interpretations - Table of Contents

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