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, 2004

Zane Keniston
Safety Director
Delhi Steel Corporation
6333 Kirkville Road North
Kirkville, NY 13082-0128

Re: Whether a shop-installed steel angle or bent plate running along the length of the top flange of a perimeter beam (with the upturned angle, reinforced by angle plates, located out from the edge of the beam) violates 29 CFR 1926.754(c)(1)(i)?

Dear Mr. Keniston:

This is in response to your follow-up letter dated December 17, 2003, to the Occupational Safety and Health Administration. On December 11, 2003, we had provided you with a revised interpretation of §1926.754(c)(1)(i) relative to its application to a continuous steel plate that is welded to the top of a perimeter beam and has vertically attached threaded studs. You now ask about the applicability of that provision to a continuous steel angle or bent plate, reinforced by a series of angle plates, that is similarly welded to the top flange.

We have paraphrased your questions as follows:

Question (1): Section 1926.754(c)(1)(i) prohibits the attachment of shear connectors and other similar devices to the top flanges of steal beams prior to the installation of decking or other walking/working surfaces. In OSHA's December 11, 2003, letter to me, you stated that the shop installation of a continuous steel plate (with vertically attached threaded studs) on the top flange of a perimeter beam violates that provision (see illustration below):


Illustration from OSHA's December 11, 2003 Keniston letter:


Exterior edge of steel plate with vertically-projecting threaded studs that poses a tripping hazard

In essence, you said the continuous steel plate extends the width of the top flange and becomes part of the walking surface. Thus, the shop installed threaded studs pose a tripping hazard and are prohibited by §1926.754(c)(1)(i).

In view of that response, we now ask a related two-part question. Does a continuous steel angle or bent plate that is shop installed to the top flange of a perimeter beam similarly extend the walking/working surface? (see "Attachment A" and "Attachment B" illustrations below):


Attachment 1 - perimeter beam section of shop-installed plates placed intermittently extending vertically from the (extended) flange that pose a tripping hazard



Attachment 2 - perimeter beam detail of shop-installed plates extending vertically from the (extended) flange that pose a tripping hazard



This attachment becomes the "pour-stop or edge of a deck." Does the shop installation of the vertical leg of the steel angle or bent plate, which is outside of the outer edge of the top flange, violate §1926.754(c)(1)(i)?

Answer

29 CFR Part 1926 Subpart R (Steel Erection), §1926.754(c)(1)(i) provides:

(c) Walking/working surfaces - (1) Shear connectors and other similar devices -
(i) 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 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.

As you are aware, a new interpretation will be included in a set of questions and answers that will be added to the Steel Erection Directive to address the question you posed in your first letter. The revised directive will address the application of §1926.754(c)(1)(i) to a continuous steel plate (with vertically attached threaded studs) welded to the top flange of the perimeter beam as follows:

This [welded steel plate], in effect, extends the width of the top flange and becomes part of the walking surface. Since the studs project vertically from the (extended) top flange, they pose a tripping hazard to the workers walking on the beam. Therefore, the shop installation of these studs would be a violation of §1926.754(c)(1)(i).

In applying this interpretation to the continuous bent plate/steel angle beam attachment in your latest letter, a similar conclusion is reached. As noted in the above excerpt, the welding of the base of the angle to the top flange effectively extends the width of that flange. The base then becomes part of the walking surface. Since the upturned part of the angle and the gussets rise vertically from the (extended) flange, the tripping hazard addressed by §1926.754(c)(1)(i) is created, and the shop installation of the described bent plate beam (with gussets) violates that standard.

As we explained previously, §1926.754(c)(1)(i) applies to "shear connectors and other similar devices" [Emphasis added]. Read as whole, the focus of the provision is on tripping hazards associated with field-installed attachments.1 Thus, in our December 11, 2003, interpretation, the fact that the "similar device" at issue was used to attach wood blocking rather than to enhance concrete composite action was not relevant to the application of the standard. Similarly, the fact that the device at issue in your latest scenario is used as a form in concrete work also does not affect the application of §1926.754(c)(1)(i). The shop installation of the device similarly creates a tripping hazard and would violate the provision.

Note that your scenario is the same as that which was posed in our December 23, 2003, interpretation letter to Mr. Richard Ward, in which we reached the same conclusion.

Question (2): Does the shop installation of gusset plates or stiffeners that are attached to the angle or bent plate at various intervals for strength violate §1926.754(c)(1)(i)?

Answer

In this scenario, the gusset plates or stiffeners are attached to the base of the steel angle or bent plate which is, in effect, an extension of the top flange or walking surface. As indicated in your letter (see Attachments A and B), these plates are intermittently placed and extend vertically from the (extended) flange. Since the gusset plates rise vertically from the (extended) flange, the tripping hazard addressed by §1926.754(c)(1)(i) is created and the use of these plates violates that provision.

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

 

 


1 As stated in the Preamble to the Final Rule for Safety Standards for Steel Erection at 66 FR 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]