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.

January 23, 2003

Mr. John J. Robinson, Jr.
Assistant Chief Counsel
Commonwealth of Pennsylvania
Department of Transportation
Office of the Chief Counsel
P.O. Box 8212
Harrisburg, Pennsylvania 17105-8212

Re:  Whether the steel erection standard requires shear connectors to be removed during bridge repair work; §§1926.750, 1926.754(c)(1)

Dear Mr. Robinson:

This is in response to your letter dated August 1, 2002, to the Occupational Safety and Health Administration (OSHA) regarding the application of shear connector requirements in the steel erection standard, 29 CFR 1926.754(c)(1), to bridge repair/rehabilitation. We apologize for the delay in providing this response.

We have paraphrased your questions as follows:

Question (1)(a): Scenario: a bridge is being refurbished.  Part of the work involves removing a beam, refurbishing it, and reinstalling it.  The beam has shear studs on it. Does Subpart R apply to the removal and reinstallation of this beam?  Specifically, does §1926.754(c)(1) (prohibition against shop-installed shear connectors) apply to this beam during the removal process?

Answer: No. Under §1926.750(a), Subpart R applies to construction work involving "repair," so the standard applies to steel erection work covered under §1926.750(b)(1) or (2) done in the course of repairs.  Section 1926.754(c)(1) requires shear connectors to be installed after the beam and decking have been installed.  However, at the time a beam is to be removed for repair, the installation process of the shear connectors has been long completed.  Therefore, §1926.754(c)(1) has no application to the removal of the beam.

Question (1)(b): Does §1926.754(c)(1) prohibit the reinstallation of this beam since the shear studs were installed in the factory?

Answer: Yes, §1926.754(c)(1) does prohibit the reinstallation of the beam, since the requirement prohibits a beam from being installed after the shear connectors have been attached.  However, in accordance with Question and Answer #25 in our compliance directive1, the refurbished beam with its shear connectors still on may be re-installed as long as all workers, including connectors and deckers, are protected by conventional fall protection.

This document was edited on 01/12/2010 to strike information that no longer reflects current OSHA policy.

Question (2):  In some cases the refurbishing work involves removing and replacing the concrete deck, but the existing beams (which have shear connectors on them) are left in place.  The shear connectors on the beams become completely exposed when the deck material is removed.  Under §1926.754(c)(1) (prohibition against shop-installed shear connectors), are these shear connectors required to be removed?

Answer: No.  Section 1926.754(c)(1) requires shear connectors to be installed after the beam and decking have been installed.  At the time a beam and its attached shear connectors are exposed, the installation process of the shear connectors has been long completed.  Therefore, §1926.754(c)(1) has no application where the concrete is removed but the beam is left in place.

If you need any further clarification on this subject, please contact us by fax at:  U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202693-1689.  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

1 Question and Answer #25 in the compliance directive, CPL 2-1.34, states:

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. [ back to text ]

This document was edited on 01/12/2010 to strike information that no longer reflects current OSHA policy.