Standard Interpretations - Table of Contents Standard Interpretations - (Archived) Table of Contents
• Standard Number: 1926.104; 1926.105; 1926.107; 1926.750
• Status: Archived
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.


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.


July 10, 1995
MEMORANDUM FOR: OFFICE OF FIELD PROGRAMS
Regional Administrators

FROM: JAMES W. STANLEY
Deputy Assistant Secretary

SUBJECT: Fall Protection in Steel Erection.


The recent decision by OSHA to delay the application of the new Subpart M--Safety Standards for Fall Protection in the Construction Industry to steel erection activities on non-building structures (it already did not apply to steel erection activities on skeleton steel buildings), and recently expressed confusion about the February 22, 1994 memorandum on steel erection fall protection, have resulted in a need to restate the enforcement policy on fall protection during steel erection activities. Consequently, and in view of the ongoing negotiated rulemaking activities for Subpart R, the February 22, 1994 memorandum is hereby cancelled and the following is a restatement of the interim enforcement policy to be applied to fall hazards in steel erection activities. Effective immediately and until further notice:
  1. New Subpart M does not apply to steel erection activities. The term "steel erection activities" means the movement and erection of skeleton steel members (structural steel) in or on buildings and non-building structures. It includes initial connecting, moving point-to-point, installing metal floor or roof decking, welding, bolting, and similar activities. It does not mean the erection of steel members such as lintels, stairs, railings, curtainwalls, windows, architectural metalwork, column covers, catwalks, and similar non-skeletal items, nor does it mean the placement of reinforcing rods in concrete structures.
    For the purposes of the stay action and this policy, the term "buildings" includes tiered and non-tiered single-story and multi-story buildings, warehouses, gymnasiums, stadiums, power plants, theaters, mill buildings, and similar structures. The term "tiered" means the skeleton steel framework is erected in vertically stacked columns; it is not limited to multi-floored structures. The term "non-building structure" includes bridges, viaducts, overpasses, towers, tanks, billboards, antennas, and similar structures.
  2. Fall protection for steel erection activities shall be provided consistent with the following:

    1. Tiered buildings:

      1. Exterior fall hazards of 25 feet or more are covered by 1926.105(a). Exterior fall protection is not required for fall hazards of less than 25 feet.
      2. Interior fall hazards of 30 feet or more on buildings which have floors or are adaptable to temporary floors are covered by 1926.750(b)(2)(i). Fall protection is not required for fall hazards of less than 30 feet. Temporary floors will generally be practicable in the construction of a typical multi-floored building.
      3. Interior fall hazards of 25 feet or more on tiered buildings which are not adaptable to temporary floors are covered by 1926.750(b)(1)(ii). Fall protection is not required for fall hazards of less than 25 feet.
    2. Non-tiered buildings:
      Exterior and interior fall hazards of 25 feet or more are covered by 1926.105(a). Fall protection is not required for fall hazards of less than 25 feet.
    3. Non-building structures:
      Exterior and interior fall hazards of 25 feet or more are covered by 1926.105(a). Fall protection is not required for fall hazards of less than 25 feet.
  3. Former (i.e. prior to February 6, 1995) paragraphs 29 CFR 1926.104, 1926.105, and 1926.107(b), 1926.107(c), and 1926.107(f) will continue to apply to steel erection activities.

Regional Administrators shall provide a copy of this policy to State Designees and encourage the states to adopt a similar policy. States shall be asked to advise the Region of any citation issued, and the information shall be forwarded to the above address.

[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.]


Archive Notice - OSHA Archive

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.

Standard Interpretations - Table of Contents Standard Interpretations - (Archived) Table of Contents