Eric Waterman doesn't mince words when giving his opinion of OSHA's original steel erection standard: "The old standard was probably one of the most poorly written, misunderstood standards that OSHA has ever had."
Waterman should know because he is vice president of membership for the National Erectors Association, which represents steel erector companies. If ever a standard needed to be revised, he says, the steel erection rule was it.
Requirements of the standard, 29 CFR 1926 Subpart R, were vague, and the 1974 rule contained no scope on what work was covered, Waterman contends. Thus, some construction workers were not sure if the standard applied to them or, if so, in what way.
OSHA determined that the old standard, which had been in place with little change for 20 years, needed a complete revision to provide greater protection and eliminate ambiguity and confusion. Most stakeholders agreed, prompting the agency in 1994 to use the Negotiated Rulemaking Act of 1990 for the first time to establish the Steel Erection Negotiated Rulemaking Advisory Committee (SENRAC). Twenty stakeholders, including Waterman, from government, industry and labor met 11 times over 18 months to rewrite Subpart R, "Safety Standards for Steel Erection."
The agency charged SENRAC with reorganizing the standard's requirements into a more logical sequence that would help employers understand better how to protect their employees from the hazards associated with steel erection. More importantly, a revised standard could help reduce the number of injuries and fatalities at construction sites.
On Jan. 18, 2001, five years after SENRAC finished its task, OSHA published a revised rule that addresses the major causes of fatalities and injuries in steel erection. The new rule went into effect exactly a year later.
OSHA will not begin general schedule inspections of steel erection, however, until March 19 to allow additional time for outreach. All other types of inspections (referral, complaint, etc.) are not subject to the 60-day delay, which will give employers more time to get up to speed on the revision and provide OSHA additional time for outreach and training.
OSHA estimates that full compliance with the revised standard will prevent 30 fatalities and 1,142 injuries annually among an exposed population of approximately 56,840 steel erectors. Among construction trades, ironworkers have the highest fatality rate at 92.9 deaths per 100,000 full-time equivalents (FTEs), according to 1999 figures from the Center to Protect Workers' Rights. The overall average for construction is 14 deaths per 100,000 FTEs. One FTE equals 2,000 hours worked annually.
In With the New
SENRAC member John Molovich of the United Steelworkers of America notes that new requirements in the revised standard will help prevent many serious problems with steel erection, such as falls and structure collapses. Molovich, formerly with OSHA, recalls several instances brought up during SENRAC meetings related to fatalities due to structure collapses caused by buildings columns not properly bolted and anchor bolts damaged or modified. The new rule requires four anchor bolts for each column (1926.755).
The 1974 rule only covered flooring requirements; structural steel assembly; bolting, riveting, fitting up and plumbing up; and safety nets. The new rule, which SENRAC will review in three years, sets performance-oriented criteria, where possible, to protect employees from steel erection-related hazards such as working under loads; hoisting, landing and placing decking; double connections; hoisting, landing and placing steel joists; and falls to lower levels.
The major sections of the rule:
The standard sets forth requirements to protect employees associated with steel erection activities involved in the construction, alteration or repair of single- and multistory buildings, bridges and other structures, including the installation of metal decking and all planking used where steel erection occurs. Subpart R does not cover electrical transmission towers, communication and broadcast towers, or tanks. Sections 1926.750(b) and (c) detail what specific steel erection activities are covered.
Parts of the rule apply to more than steel erectors. SENRAC member Bill Brown, president and CEO of Ben Hur Construction Co., a union general contractor and steel erector in St. Louis, points out that Subpart R includes several requirements that apply to general or controlling contractors, including safe site conditions for activities such as routes for hoisted loads, preplanning of the erection process and certifying concrete foundations (1926.752).
"It's not like we're putting a new burden on the general contractor," Brown says, "because that's part of the controlling contractor's responsibility to make sure the work was done properly."
Subpart R also affects steel fabricators, which must produce steel that is in compliance. An example is double connections designed with a seat, clip or other safety device (1926.756).
- From anchored bridging to unprotected sides and edges, the standard for the first time provides 46 definitions.
Hoisting and Rigging (1926.753)
- Provides additional crane safety for steel erection.
- Minimizes employee exposure to overhead loads through preplanning and work practice requirements.
- Prescribes the proper procedure for multiple lifts (Christmas-treeing).
Structural Steel Assembly (1926.754)
- Provides safer walking/working surfaces by eliminating trip hazards and minimizes slips with new slip-resistance requirements.
- Provides specific work practices regarding safely landing deck bundles and promoting the prompt protection from fall hazards in interior openings.
Beams and Columns (1926.756)
- Eliminates extremely dangerous collapse hazards associated with making double connections at columns.
Open-Web Steel Joists (1926.757)
- Establishes requirements minimizing collapse of lightweight steel joists by addressing the need for erection bridging and method of attachment.
- Establishes requirements for bridging terminus anchors with illustrations and drawings in a nonmandatory appendix (provided by the Steel Joist Institute).
- Adds requirements to minimize collapse in placing loads on steel joists.
- Systems-Engineered Metal Buildings (1926.758)
- Provides requirements to minimize collapse in the erection of these specialized structures, which account for a major portion of steel erection in the United States.
Falling Object Protection (1926.759)
- Establishes performance provisions that address hazards of falling objects in steel erection.
Fall protection (1926.760)
- Establishes controlled decking zone (CDZ) provisions to prevent decking fatalities.
- Requires deckers in a CDZ and connectors to be protected at heights greater than two stories or 30 feet. Connectors between 15 and 30 feet must wear fall arrest or restraint equipment and be able to be tied off or be provided another means of fall protection. They are not required to use the equipment until 30 feet. Connectors are employees who, while working with hoisting equipment, are placing and connecting structural members or components.
- Requires fall protection for all others engaged in steel erection at heights greater than 15 feet.
- Requires a qualified person to train exposed workers in fall protection.
- Requires a qualified person to train exposed workers engaged in special, high-risk activities.
Six, 15 or 30 Feet?
By far, fall protection has been the most controversial part of the revised standard, especially during SENRAC negotiations. Many on the committee believe that not only is the 30-foot fall trigger height for connectors too high, but so is the 15-foot requirement for all other steel erectors. The Steelworkers' Molovich believes that if the 6-foot requirement in 1926's Subpart M is good enough for construction workers, it should be good enough for steel erectors (see diagram).
The National Erector Association's Waterman counters that ironworkers prefer flexibility of movement when they are connecting structural members because of hazards when heavy pieces of steel are being moved with hoisting equipment.
Compromise on fall protection and other sections was required because all 20 SENRAC members had to agree to every part of the revision before the standard could be finished. By agreeing to a higher fall trigger height, Molovich and others were able to get concessions on other parts of the rule, such as structural stability. If companies comply with the standard, he says, structural collapse should not be an issue, so there should be little danger in tying off to a structure.
SENRAC member Rocky Turner, president of L.P.R. Construction, a Loveland, Colo.-based steel erector, also believes connectors should have been required to tie off between 15 and 30 feet. In fact, Turner requires all of his steel erectors - connectors or not - to use fall protection beginning at 6 feet.
"Anytime you get a group of ironworkers together, they'll tell a story about how they were on a building that collapsed, and had their people been tied to the building, they would have been killed or injured," Turner says. "There are going to be people in the future who get injured because they are tied off to a structure that becomes unstable, but I think there will be many more saved because they fall and get caught [by fall arrestors]. The tradeoff is obvious. It's the same argument from people who don't want to wear seat belts because they don't want to get trapped in a car."
For most companies in industrial and heavy construction, the trigger height will not be an issue, according to Brown. Many steel erectors, such as Ben Hur, and their clients demand more stringent requirements than Subpart R, such as connectors using fall protection at 6 feet.
Turner agrees. "I think the industry will drive fall protection [requirements] tighter and tighter," he says. "Those using fall protection at 6 feet might be in the minority, but there's an awful lot more of us doing it now."
Early Success Stories
Most steel erector companies in OSHA's Region 8, specifically in Colorado, have been adhering to requirements of Subpart R for a few years, according to Turner. L.P.R. Construction renewed its focus on safety after a worker fell to his death in 1990. The employee was working at about 40 feet on a sloped roof while installing a roof deck and fell through a skylight.
Bart Chadwick, a former Region 8 administrator and the agency's SENRAC representative, spearheaded efforts to convince Colorado steel erectors to adopt stricter safety guidelines in the 1990s. In the past two years, Chadwick says, the region has experienced 21 documented saves of steel erectors who fell but were saved because of using required fall arrest systems or where structures probably would have come down, but did not, because they incorporated engineering principles required in the revised rule. In addition, 38 steel erectors in the state now have fatality rates that average six times below the national rate.
SENRAC members believe that companies complying with the revised steel erection standard will have similar success in providing safer working conditions for their workers. Because the rulemaking was negotiated, Chadwick says, it "reflects a lot of good, practical judgment and common sense with regard to compliance issues."