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OSHA 1926.752

Steel erection requirements

1926 Subpart R

17 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.752(a)(1), when may steel erection begin with respect to concrete or masonry strength?

Steel erection may begin only after the controlling contractor provides written notification that the concrete or mortar has reached the required strength. Specifically, the notification must state that testing of field-cured samples by an appropriate ASTM test method shows either 75 percent of the intended minimum compressive design strength or sufficient strength to support the loads imposed during steel erection (Requirement in 1926.752(a)(1)).

Under 1926.752(b), can a steel erection contractor start erecting steel without written notification about concrete strength?

No. A steel erection contractor must not erect steel unless it has received written notification that the concrete or mortar has attained the required strength based on appropriate ASTM field-cured sample testing. This is a direct requirement of 1926.752(b).

Under 1926.752(a)(2), what are the requirements for repairs, replacements, or modifications to anchor bolts before steel erection starts?

Any repairs, replacements, or modifications to anchor bolts must be done in accordance with 1926.755(b) before steel erection begins. The controlling contractor must notify the steel erector in writing that any such work was conducted per 1926.755(b) as required by 1926.752(a)(2).

Under 1926.752(c)(1), what site access must the controlling contractor provide for safe steel erection operations?

The controlling contractor must provide and maintain adequate access roads into and through the site for safe delivery and movement of derricks, cranes, trucks, other necessary equipment, and erection materials, plus means for pedestrian and vehicular control (this does not apply to roads outside the construction site). See 1926.752(c)(1).

Under 1926.752(c)(2), what are the site conditions required for material storage and equipment operation?

The controlling contractor must provide and maintain a firm, properly graded, drained area that is readily accessible to the work and has adequate space for safe material storage and safe operation of the erector's equipment, as required by 1926.752(c)(2).

Under 1926.752(d), what does "pre-planning of overhead hoisting operations" require?

All hoisting operations in steel erection must be pre-planned to ensure they meet the requirements of 1926.753(d). In other words, before lifting starts you must have a plan that complies with the hoisting requirements in 1926.753(d), as stated in 1926.752(d).

Under 1926.752(e), when is a site-specific erection plan required and who must prepare it?

A site-specific erection plan is required when employers choose alternate means and methods (due to site-specific conditions) that provide employee protection in accordance with 1926.753(c)(5), 1926.757(a)(4), or 1926.757(e)(4). That plan must be developed by a qualified person and be available at the work site, per 1926.752(e) and the cross-referenced provisions (1926.753(c)(5), 1926.757(a)(4), 1926.757(e)(4).

Under 1926.752, who is responsible for providing the written notifications required before steel erection starts?

The controlling contractor is responsible for ensuring that the steel erector is provided with the required written notifications (concrete/mortar strength and anchor-bolt work) before steel erection begins, as stated in 1926.752(a).

Under 1926.752(c)(1), does the access-road requirement apply to roads outside the construction site?

No. The requirement to provide adequate access roads into and through the site does not apply to roads outside the construction site; that exception is explicitly stated in 1926.752(c)(1).

Under 1926.752(e), where can I find guidelines for developing a site-specific erection plan?

Guidelines for establishing a site-specific erection plan are contained in appendix A to the subpart referenced in 1926.752(e), and the plan itself must be developed by a qualified person and available at the work site.

Under 1926.752(d) and 1926.753(d), what is the practical purpose of requiring pre-planning for hoisting operations in steel erection?

The practical purpose is to ensure every overhead lift is planned so it meets the hoisting safety requirements in 1926.753(d), reducing hazards from dropped loads, crane movement, and worker exposures. Pre-planning identifies lift capacity, pick points, rigging, exclusion zones, and communications before hoisting begins, as required by 1926.752(d).

Under 1926.752(a)(1), must the concrete strength determination rely on ASTM field-cured sample tests?

Yes. The standard explicitly requires the strength determination to be based on an appropriate ASTM standard test method of field-cured samples, as stated in 1926.752(a)(1).

Under 1926.752 and related provisions, if an employer wants to use alternative methods to meet fall protection during erection, what documentation and qualifications are required?

If an employer elects alternate means and methods to provide employee protection (for example, alternative fall protection methods referenced in 1926.753(c)(5) or 1926.757(a)(4)), a site-specific erection plan must be developed by a qualified person and be available at the work site, per 1926.752(e).

Under 1926.752, what should the controlling contractor do if anchor-bolt repairs are performed offsite or by a different employer?

The controlling contractor must still ensure the steel erector is provided written notification that any repairs, replacements, or modifications to anchor bolts were conducted in accordance with 1926.755(b), regardless of who performed the work or where it was done (1926.752(a)(2) and 1926.755(b)).

Under 1926.752 and the PPE hazard assessment LOI (2024-03-28), must employers performing steel erection complete a PPE hazard assessment and written certification?

Yes. Employers must assess the workplace to determine whether PPE is required and, if PPE is required, produce a written certification of that hazard assessment consistent with OSHA's PPE requirements discussed in the PPE hazard assessment Letter of Interpretation (see PPE hazard assessment requirements). Employers performing steel erection should follow that assessment process in addition to meeting the steel erection site and planning requirements in 1926.752.

Under 1926.752(d) and the scaffold/fall protection LOI (2023-12-05), how do scaffold and suspended conveyance fall-protection rules relate to steel erection hoisting operations?

Hoisting operations that create suspended platforms or conveyances may meet the definition of a suspended scaffold and therefore must meet the scaffold fall protection and falling-object protection requirements before use; pre-planning required by 1926.752(d) helps ensure compliance with those rules. OSHA's Letter of Interpretation on scaffold and fall protection clarifies that conveyances using temporary suspension means can be considered suspended scaffolds and must meet the fall protection and falling object requirements in 29 CFR 1926.451(g) and (h).

Under 1926.752, if site conditions change during erection, does the controlling contractor need to update notifications or plans?

Yes. Because 1926.752 requires written notifications and, when used, a site-specific erection plan developed by a qualified person, any change in site conditions that affects concrete strength, anchor bolts, hoisting, or the protections relied upon should prompt updates to the written notifications and the site-specific plan so the steel erector is working with current, accurate information.