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OSHA 1926SubpartRAppF

Perimeter column safety guidelines

Subpart R

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.756(e), where should column splices be placed when holes in the column web are used for perimeter safety cables?

Place the column splice high enough so it does not interfere with attachments used for perimeter safety cables or other necessary column attachments.

  • The non-mandatory guideline in Appendix F to Subpart R explains that when holes in the column web are used for perimeter safety cables, "the column splice must be placed sufficiently high so as not to interfere with any attachments to the column necessary for the column splice." See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e).

Under 1926.756(e), are there recommended vertical spacing intervals for column splices in multi-story steel erection?

Yes — Appendix F recommends placing column splices at every other level or at every fourth level, as the design allows.

Under 1926.756(e), why should column splices at the third level be avoided?

Because third-level splices can be detrimental to the erection process and may interfere with temporary or permanent attachments needed for safe erection and fall protection.

  • Appendix F explicitly states that "column splices at third levels are detrimental to the erection process and should be avoided if possible." Avoiding these mid-range splice locations helps prevent conflicts with perimeter safety cable attachments and other erection hardware. See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e).

Under 1926.756(e), what does "sufficiently high" mean practically when locating a column splice to avoid interference with attachments?

Practically, "sufficiently high" means placing the splice above the highest permanent or temporary attachment point (such as perimeter cable anchor holes, brackets, decking connections, or brace connections) so those attachments and their fasteners are not obstructed by the splice.

Under 1926.756(e), what are examples of column attachments that a splice could interfere with?

Common column attachments that could be interfered with include perimeter safety cable anchor points (holes in the web), temporary erection brackets, decking connections, bracing or guy attachment points, and anchor-bolt or clip angles used for floors.

Under 1926.756(e), who is responsible for ensuring the splice location will not interfere with attachments for perimeter safety systems?

The employer (including designers, erectors, and general contractors) is responsible for planning and coordinating splice locations so they do not interfere with safety attachments or erection operations.

  • Appendix F provides non-mandatory guidance for complying with 1926.756(e). Employers must implement measures to protect workers on walking/working surfaces, and coordinating splice placement is part of that obligation under the construction standards in 1926.

Under 1926.756(e), can a splice be placed at a third level if engineering constraints require it?

Yes — a splice can be placed at a third level if design or site constraints require it, but it should be avoided when possible and only used after evaluating and controlling the resulting hazards.

  • Appendix F recommends avoiding third-level splices because they can disrupt erection, but it does not outright ban them; instead, employers should plan to control any risks created by atypical splice locations. See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e). Employers should document their hazard assessment and protective measures as part of their safety plan; OSHA emphasizes the need for workplace hazard assessments in practice (see OSHA’s PPE hazard assessment guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

Under 1926.756(e), do column splice locations affect fall protection or perimeter cable systems required during steel erection?

Yes — splice locations can directly affect the installation and effectiveness of perimeter safety cables and other fall-protection attachments, so splices must be located to avoid interfering with those systems.

Under 1926.756(e), when should splice-location coordination occur in the project timeline?

Splice-location coordination should occur during design and erection planning so splice heights, hole locations, and attachment details are resolved before fabrication and field erection.

  • Appendix F recommends planning splice placement (for example, at every other or every fourth level as design allows) to avoid interference with safety attachments. Early coordination reduces field changes that could compromise fall-protection or erection operations. See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e).

Under 1926.756(e), are the Appendix F perimeter column guidelines mandatory or advisory?

The Appendix F perimeter column text is non-mandatory guidance; it offers recommended practices to help comply with the mandatory requirement in [1926.756(e)].

Under 1926.756(e), what inspection checks should be performed on perimeter columns and splices before erecting safety cables?

Inspect column splices to confirm they are at the planned elevation, verify that web holes or attachments for perimeter cables are unobstructed, and ensure no splice components block or weaken attachment points.

  • Recommended checks include verifying splice height vs. attachment locations, confirming hole alignment and clearance for cable anchors, and ensuring splices are fully assembled per design before installing perimeter safety cables. These steps follow the Appendix F guidance to prevent interference with attachments and support compliance with 1926.756(e) and the broader 1926 construction standards.

Under 1926.756(e), if holes in the column web cannot be used for perimeter cables due to splice location, what alternative attachment methods can be used?

Alternatives include using temporary clamp-on anchors or brackets, welded or bolted anchor plates placed clear of the splice, perimeter guardrail systems, or other engineered fall-protection anchors that do not rely on web holes obstructed by the splice.

  • Any alternative must provide equivalent or better protection and be installed per the equipment/manufacturer instructions and applicable fall-protection rules. Appendix F highlights the problem of web-hole interference and implies the need to plan for alternate attachment methods when splice placement conflicts with cable holes. See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e). Also review fall-protection requirements found in OSHA guidance on suspended/scaffold fall protection at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

Under 1926.756(e), how should an employer document the decision to place splices at non-recommended levels (for example, third level)?

Document the decision with an engineering justification, a written hazard assessment, and a description of the controls or alternate anchorage methods used to protect workers.

  • OSHA emphasizes completing hazard assessments and documenting PPE and control decisions in practice (see OSHA's PPE hazard assessment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28). Although Appendix F is non-mandatory, keeping written records showing why a non-recommended splice location was necessary and how hazards were controlled supports compliance with 1926.756(e) and good safety management. See the Perimeter Columns guidelines (Appendix F to Subpart R).

Under 1926.756(e), does placing splices at different floor levels change the sequence or methods of steel erection operations?

Yes — splice placement can affect erection sequencing, access, and connection methods, so splice location should be considered during erection planning to avoid disrupting the erection process.

  • Appendix F warns that certain splice placements (for example, at third levels) are "detrimental to the erection process." Employers and erectors should plan splice heights to minimize rework, avoid blocked attachment points for safety systems, and maintain safe access and connection sequences. See the Perimeter Columns guidelines (Appendix F to Subpart R) and 1926.756(e).

Under 1926.756(e), who should be involved in selecting splice locations to ensure both structural and safety needs are met?

Designers, structural engineers, erectors, and safety professionals should collaborate to select splice locations that meet structural requirements while preserving attachment points for perimeter safety systems.

  • Appendix F's recommendations reflect the need for coordination between design and erection trades to avoid interference with safety cable holes and other attachments; involving safety staff early supports compliance with 1926.756(e) and good construction safety practice. See the Perimeter Columns guidelines (Appendix F to Subpart R).