OSHA recently rescinded (.pdf file) its de minimis policy in the agency’s steel erection compliance directive regarding tripping hazards and the installation of nets or floors during steel erection. A de minimis violation is one that is considered minor and for which a citation may not be issued.

The directive pertained to OSHA’s steel erection standard (1926.754). By rescinding the policy, OSHA is signaling to employers that they are required to comply with both subsections in the standard: 1926.754(b)(3) and 1926.754(c)(1).

1926.754 (b) (3) The following additional requirements

A fully planked or decked floor or nets shall be maintained within two stories or 30 feet, whichever is less, directly under any erection work being performed.

1926.754 (c) (1) Walking/working surfaces

Shear connectors and other similar devices.

(i) Tripping hazards.  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 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.

(ii) Installation of shear connectors on composite floors, roofs and bridge decks.  When shear connectors are used in construction of composite floors, roofs and bridge decks, employees shall lay out and install the shear connectors after the metal decking has been installed, using the metal decking as a working platform. Shear connectors shall not be installed from within a controlled decking zone (CDZ), as specified in 1926.760 (c) (8).

OSHA’s revision to its enforcement policy regarding de minimis violations is aimed at reducing the number of construction deaths, acting OSHA administrator Jordan Barab said in an agency press release.