Last Friday a photograph was posted on the IWTRAIN LISTSERV of one of our members  moving point-to-point on a structural member that was shop fabricated with shear-studs on the top flange of the beam. This photograph illustrates a situation that is currently allowed by OSHA and classified as a “de minimis” violation.  We are actively pursuing remedies to restore the integrity of the Subpart R standard that was compromised by a 2002 Compliance Directive issued under the previous Administration.

OSHA Standard 1926.754(c)(1)(i):  “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 that 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.”

Tripping Hazards and Fatality Data:  The International Association and other industry stakeholders reviewed 673 OSHA fatality reports that identified “tripping on shear-studs” as a primary causation factor in many fatalities.  As a result, the 1926.754(c)(1)(i) standard was adopted in 2001 as part of the Final Rule of Subpart R – Steel Erection.

Confusion From OSHA Compliance Directive:  We regret that under the previous Administration, OSHA issued a Compliance Directive in 2002 stating “if an employer requires that all workers, including those engaged in connecting and in decking be protected from falls by conventional fall protection, then the failure to meet the requirements of §1926.754(c)(1)(i) would be considered de minimis and no citation would be issued.”  This misguided OSHA Compliance Directive is contrary to the OSHA Subpart R standard and effectively removed safety provisions for our members.

Position of the International Association:  The International Association has strongly opposed this OSHA Compliance Directive and has met with Agency officials on several occasions to demand consistent interpretation and enforcement of the Subpart R – Steel Standards.  We fought hard to obtain this OSHA standard to protect our members from tripping hazards created by shop installed shear-studs. We regret the previous Administration issued this misguided Compliance Directive in 2002 that has contributed to jobsite incidents, and continues to be the source of confusion in our industry. 

If you have any questions regarding this OSHA Compliance Directive or other information, please contact Steve Rank at (202) 383-4829.

 

Shear-studs installed after metal decking has been installed.