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OSHA 1926SubpartRAppE

Steel erection training guidelines

Subpart R

12 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.761, does completing a Bureau of Apprenticeship–approved steel erection course satisfy the training requirement?

Yes. Completing a steel erection training course that has been approved by the U.S. Department of Labor Bureau of Apprenticeship will be deemed to meet the training requirements of 1926.761. See the non‑mandatory guideline in Appendix E to Subpart R which states that employees who complete such an approved course — including instruction in the provisions of the steel erection standard — are considered to have met the training requirement.

Under 1926.761, what specific content must a Bureau‑approved steel erection course include to be considered compliant?

A Bureau‑approved course must include instruction in the provisions of the steel erection standard. Appendix E explains that the training requirement of 1926.761 will be deemed met when employees "have completed a training course on steel erection, including instruction in the provisions of this standard," and that such courses should be approved by the U.S. Department of Labor Bureau of Apprenticeship (Appendix E to Subpart R).

Under 1926.761, is the guidance in Appendix E mandatory or optional for employers?

The guidance in Appendix E is non‑mandatory; it provides a way to meet the training requirement but does not create a separate legal obligation. Appendix E is titled "Training: Non‑mandatory Guidelines for Complying with 1926.761" and explains that completing a Bureau‑approved course will be deemed to meet the requirement, but it does not prevent employers from meeting 1926.761 through other compliant training approaches (1926.761 and Appendix E to Subpart R).

Under 1926.761, can employers use an in‑house steel erection course that is not Bureau‑approved to meet the training requirement?

Yes — but only if the in‑house course actually provides the instruction required by the steel erection standard. Appendix E states that completion of a Bureau‑approved course "will be deemed to have been met," which means the approved course is an accepted method to satisfy 1926.761, but Appendix E is non‑mandatory and does not prohibit other training that effectively teaches the provisions of the standard (Appendix E to Subpart R). Employers choosing an alternative must ensure their training covers the standard’s requirements in practice.

Under 1926.761, who approves the training course that Appendix E references?

The U.S. Department of Labor Bureau of Apprenticeship (also called the Office of Apprenticeship) is the approving authority referenced in Appendix E. Appendix E states that the training requirement of 1926.761 will be deemed met if employees have completed a steel erection course that "has been approved by the U.S. Department of Labor Bureau of Apprenticeship" (Appendix E to Subpart R). Employers can contact that Bureau to confirm whether a course is approved.

Under 1926.761, does Appendix E replace the employer’s responsibility to ensure workers understand the standard?

No. Appendix E provides a recognized way to meet the training requirement but does not remove the employer’s obligation to ensure employees are trained and understand the standard. Appendix E states that completing an approved course will be deemed to satisfy 1926.761, but it is a non‑mandatory guideline and employers remain responsible for compliance with the steel erection standard (Appendix E to Subpart R).

Under 1926.761, does Appendix E specify who must teach the approved course (trainer qualifications)?

No. Appendix E does not specify trainer qualifications; it focuses on acceptance of a course approved by the U.S. Department of Labor Bureau of Apprenticeship. Appendix E explains that completion of a Bureau‑approved steel erection course "including instruction in the provisions of this standard" will be deemed to meet 1926.761, but it does not lay out specific instructor credentials or teaching methods (Appendix E to Subpart R). Employers choosing alternate training should ensure instructors are competent to teach the standard’s provisions.

Under 1926.761, does Appendix E tell employers how to document that employees completed the Bureau‑approved course?

No. Appendix E states that completion of a Bureau‑approved course will be deemed to meet the training requirement but does not prescribe specific documentation steps. Appendix E notes the acceptance of an approved course for 1926.761 compliance (Appendix E to Subpart R). Employers should retain course completion records or certificates from the approving Bureau to demonstrate compliance during inspections or audits.

Under 1926.761, if a course is not Bureau‑approved, how can an employer demonstrate that their training still meets the standard?

An employer can demonstrate compliance by showing that the training provided covers the provisions of the steel erection standard and that employees received and understood that instruction. Appendix E offers a Bureau‑approved course as a recognized way to meet 1926.761, but because Appendix E is non‑mandatory (Appendix E to Subpart R), employers may use other training approaches provided they can document course content, attendance, and evidence that workers are competent in the standard’s provisions.

Under 1926.761, does Appendix E apply to all steel erection employers covered by Subpart R?

Yes, Appendix E’s guidance is directed to employers covered by Subpart R as a non‑mandatory way to comply with the training aspect of the steel erection standard. It explains that training requirements of 1926.761 will be deemed met if employees complete a Bureau‑approved steel erection course that includes instruction on the standard’s provisions (Appendix E to Subpart R).

Under 1926.761, does Appendix E change the substantive requirements of Subpart R (steel erection) beyond training?

No. Appendix E is limited to non‑mandatory guidance on training to help employers comply with 1926.761; it does not change or add substantive requirements elsewhere in Subpart R. Appendix E simply states that completion of a Bureau‑approved course that includes instruction in the standard’s provisions will be deemed to meet the training requirement (Appendix E to Subpart R). Employers must still follow all other mandatory provisions of Subpart R.

Under 1926.761, where can I find the exact OSHA language that explains the Bureau‑approved course option?

You can read the non‑mandatory guideline and the exact wording in Appendix E to Subpart R, which states that the training requirements of 1926.761 "will be deemed to have been met if employees have completed a training course on steel erection, including instruction in the provisions of this standard, that has been approved by the U.S. Department of Labor Bureau of Apprenticeship." See Appendix E to Subpart R for the full text.