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issue#3.osh
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1994-09-05
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ISSUE #3
Safety Erection Plan
At its meeting of August 4, 1987, the ACCSH members
recommended adding provisions that would require steel and other
structural metal erector employers to develop and maintain a safety
erection plan for worker protection. To clarify this discussion,
ACCSH proposed a definition of, and provisions for implementing a
requirement for such a safety erection plan (Tr.8/4/87, p.
126-129). Thus, it recommended to OSHA the following definition:
"Safety erection plan" means written notes
and/or drawings describing provisions for the
safety of employees which specifically address
steel and other structural erection hazards
such as fall protection and the stability of
buildings and structures, including guying and
bracing requirements during the erection
process. Temporary supports such as temporary
guys. braces, falsework, cribbing, stiffening
trusses, or other elements required to assure
lateral stability of long limbered members
during hoisting and after placement shall be
indicated.
OSHA, in proposing to adopt this definition in 1926.750(b),
has deleted the regulatory language in the second sentence from the
definition, as follows:
"Safety erection plan means written instructions or written
notes on drawings describing provisions for the safety of
employees during the process of construction erection that
specifically address hazards such as falling and the
instability of buildings and structures, and which include
requirements for guying and bracing during the construction
erection process and for fall protection."
OSHA proposes to move the language in the underlined second
sentence to the regulatory paragraph .753(e) which addresses the
proposed safety requirements for safety erection plans, as follows:
(e) Safety Erection Plan (1) A qualified person shall
prepare a site specific safety erection plan as defined in
paragraph 1926.750(b) of this section prior to the erection of
structural members.
(2) A qualified person shall approve all changes in the
safety erection plan.
(3) A copy of the erection plan with all approved changes
shall be maintained at the job site.
(4) The implementation of the erection plan shall be under
the supervision of a competent person.
(5) Temporary supports shall be indicated, such as
temporary guys, braces, falsework, cribbing, stiffening
trusses, or other elements required to assure lateral stability of
long limber members during hoisting and after placement.
(6) Fall protection systems to be used shall be indicated,
except where, pursuant to 1926.755(c), such systems are
demonstrated to be infeasible or would create a greater hazard.
(7) When demonstrating that fall protection is not to be
used, the safety erection plan shall contain an explanation why
compliance with fall protection per Subpart M would be infeasible
or would create a greater hazard. Such explanation shall include
a discussion of why the following systems are not feasible or would
create a greater hazard: Safety net systems, scaffolds, ladders,
vehicle mounted work platforms, positioning devices, crane or
derrick suspended personnel platforms, guardrail systems, and
personal fall arrest systems.
(8) When demonstrating that fall protection is not to be
used, the safety erection plan shall identify each location
where fall protection will not be used.
(9) Whenever fall protection is not used, the plan shall
include additional procedures and instructions for each
employee designated to perform such duties and to prevent
exposure of all other employees to the hazard.
(10) The safety erection plan shall include provisions to
certify that all employees have received training for
performing steel erection operations as required per 1926.756 of
this part.
The ACCSH also recommended that additional provisions be
adopted requiring that a safety erection plan be prepared per the
above definition.
Based on the above proposal and the objections presented, OSHA
solicits comment on the definition and provisions for a safety
erection plan set forth in proposed 1926.750(b) and 1926.752(e),
and whether or not such provisions would improve employee safety.
Would such requirements be appropriate for steel and other
structural metal erection projects of all sizes and shapes? Who
should bear the responsibility for developing and implementing the
safety erection plan? Are the specifications and notes currently
found in project drawings adequate for use as a safety erection
plan, or would they need to be supplemented with additional notes
and information? OSHA solicits information concerning the time and
resources required to collect the information and to implement the
safety erection plan. Should the preparation of such a plan be
limited only to the structural metal erection jobs? Does the
development of a plan facilitate the installation of safety devices
during construction erection operations, based on the experience of
firms which currently submit such plans? Specifically, OSHA
solicits comment on the amount of time required to collect such
information and implement the provisions concerning "connecting
activities."