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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 https://www.osha.gov.
December 19, 2002
R. Donald Murphy
Managing Director
Steel Joist Institute
3127 10th Avenue North Ext.
Myrtle Beach, SC 29577-6760
Re: Errors in Tables A & B of 29 CFR Part 1926 Subpart R (steel erection standard)
Dear Mr. Murphy:
This is in response to your letter of October 4, 2002, in which you ask that OSHA make several corrections to erection bridging Tables A and B in the new steel erection standard (29 CFR Part 1926 Subpart R). You note that in several instances the Tables erroneously indicate that certain joists require erection bridging. You also point out that the definition of the abbreviation "NM" is incorrect.
Response: We agree that there are several errors in Tables A and B. The Tables were originally designed for the proposed rule, which required bridging on all joists over 40 feet long. However, the final rule differs from the proposed rule in that only certain joists over 40 feet are required to have erection bridging. Errors were made in adjusting the Tables for the final rule; some spans in the tables were incorrectly identified and the note under the tables was not revised. There are also two typographical errors.
In addition, the definition of the abbreviation "NM" is incorrect; the correct definition is: "NM = diagonal bolted bridging not mandatory." The correct tables are printed below with the changes identified.
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We anticipate making these changes through a technical correction to the standard, and also noting the changes in our upcoming revision to the steel erection directive [CPL 02-01-034 (formerly CPL 2-1.34)].
We appreciate your bringing these problems to our attention. We value our cooperative relationship with SJI and appreciate the extraordinary amount of time and effort your organization has provided throughout the steel erection rulemaking process.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, [Office of Construction Standards and Guidance], fax # 202-693-1689. You can also contact us by mail at the above office, 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
[Corrected 6/2/2005]