By Homer R. Peterson II, P.E., CSP
Introduction
Ironworkers have the fifth highest fatality rate (33.4 per 100,000 workers) of any United States civilian worker classification. (This is according to 2017 data provided by the U.S. Bureau of Labor Statistics.) Ironworkers who fall while tied off suffer dramatically fewer fatalities and serious injuries.
OSHA Requirements – Steel Erection Fall Protection – 29CFR§1926.760
OSHA regulations in section 29CFR§1926.760 provide three thresholds at which fall protection is required for ironworkers. The applicable threshold is determined by categorizing the activity being performed as either connecting activity, metal decking activity in controlled decking zones (CDZ’s), or other steel erection activities.
Other Steel Erection Activities – Ironworker Threshold at 15 Feet – [Summary of 29CFR§1926.760 (a)]
With the exception of connectors and employees working in controlled decking zones, all employees engaged in steel erection activities who are potentially exposed to falls of 15 feet or more must be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems, or fall restraint systems.
Connecting Activities – Threshold at Two Stories or 30 Feet – [Summary of 29CFR§1926.760 (b)]
Connectors must be protected from fall hazards of more than two stories, or 30 feet, whichever is less. Connectors exposed to fall hazards of 15 feet or more must be provided with a personal fall arrest system, positioning device system, or fall restraint system, and must wear personal protective equipment (PPE) to enable them to tie off. However, up to the applicable threshold, each connector has the option not to tie off in order to be able to avoid incoming loads or to jump to safety in case of structural collapse.
Decking Activities in CDZ’s – Threshold at Two Stories or 30 Feet – [Summary of 29CFR§1926.760 (c)]
Where metal decking is initially being installed and forms the leading edge of a work area, a controlled decking zone, or CDZ, may be established at more than 15 feet, and up to 30 feet, above a lower level. Ironworkers working near the leading edge in a CDZ must be protected from fall hazards of more than two stories, or 30 feet, whichever is less. Note that access to CDZ’s must be restricted to only those employees who are actually engaged in the leading edge work.
Ironworker Steel Erection Fatalities in Construction
Prior to the release of the current version of 29 CFR 1926 Subpart R Steel Erection, the Steel Erection Negotiated Rulemaking Advisory Committee (“SENRAC”) studied OSHA statistics to determine the causes of ironworker fatalities over an 11-year period, categorized the fatalities by activity, and sought to create a standard that would reduce ironworker fatalities. For the 11 years studied, decking activity was responsible for 23% of ironworker deaths and connecting activity for 17% of ironworker deaths.
Case Studies – Ironworker Falls – Two case studies of ironworker slip/trip/fall accidents are included below. Case Study # 1 is an example of the consequences that can result from failure to tie off, while Case Study # 2 shows that using 100% tie-off can lower the chances of serious injury in falls from height.
CASE STUDY # 1
I consulted on a case in which Owner UM hired general contractor PC to construct a steel-framed building. PC contracted with fabricator OS and erector FK for fabrication and erection of the steel for a multi-story project. Ironworker connector FL, employed by FK on the project, slipped as he was crossing a roof beam. Although FL was wearing his safety harness and lanyard and had access to a suitable anchorage, he was not tied off when he fell more than 40 feet to the muddy, soft ground below. FL filed a lawsuit seeking compensation from UM, PC, OS, and others for serious injuries resulting from his fall. The case settled in advance of trial after submittal of experts’ reports.
CASE STUDY # 2
I previously served as risk manager for a steel erection specialty contractor that had a 100% tie-off policy for steel erection work performed at 6 feet or more above the ground or protective work surface. The policy did not exempt ironworker connectors or deck installers from 100% tie-off at 6 feet or higher. Over a 16-year period while the tie-off policy was in place, I gathered the following information related to twenty-seven (27) steel erection falls:
Of the 27 ironworkers who fell while performing steel erection work at 6 feet or higher:
89% followed company policy, tied off, and suffered no injury as a result of their falls other than minor cuts and bruises (24 ironworkers).
11% did not follow company policy, were not tied off, and suffered lost time injuries (3 ironworkers).
41% worked in the decking crew (11 ironworkers).
33% worked in the raising gang, or setting crew, as connectors (9 ironworkers).
4% worked in the raising gang, but not as connectors (1 ironworker).
4% worked in the bolting crew (1 ironworker).
4% worked in the welding crew (1 ironworker).
4% worked in the detail crew (1 ironworker).
Crew type was not recorded in 10% of the falls.
Of the 24 ironworkers who were tied off, fell, and suffered no injury except minor cuts and bruises:
88% were not required to tie off per OSHA regulations (21 ironworkers).
12% were required to tie off per OSHA regulations (3 ironworkers).
88% were not pulled off of the steel by their lanyard (21 ironworkers).
8% were pulled off of the steel by their lanyard while performing decking activities (2 ironworkers).
4% were pulled off of the steel by their lanyard while performing connector activities (1 ironworker).
Tie-off of Ironworkers, Connectors, and Metal Deck Installers
Early in my career, I shared the beliefs of most of my ironworker co-workers that ironworkers should not be required to tie off when working at elevation, and that connectors should be allowed the freedom of movement necessary to avoid incoming loads. Subsequently, I conducted several accident investigations of ironworker falls from elevation and recorded details of these falls. Over time, innovative personal fall arrest systems (PFAS) such as sliding anchors were invented, offering new options for ironworker fall protection and gaining acceptance by many steel erectors. Eventually, I changed my mind to the extent that I now favor 100% tie-off of all ironworkers performing steel erection work at height.
In 1996, my company implemented its 100% tie-off policy for ironworkers exposed to falls of 6 feet or more. By requiring tie-off of all ironworkers between 6 and 15 feet, tie-off of connectors between 15 and 30 feet, and tie-off of deck installers in CDZ’s, our policy exceeded OSHA’s tie-off requirements that were issued in 2001. As can be seen from Case Study # 2, twenty-four ironworkers who fell while in compliance with our policy were saved. (Used herein, “saved” means either suffered no injury or suffered only a first aid injury with minor cuts and bruises) Three ironworkers were pulled off the steel by their lanyards while performing their work but did not suffer recordable injuries. While I recognize the possibility of ironworkers being injured or killed in the future while following a policy such as ours, Case Study # 2 has demonstrated that such a policy reduces the likelihood of death or serious injury in a fall.
Ironworkers frequently must tie off to steel structures at the level of their feet. This practice can create a situation in which an ironworker can fall and be injured because of insufficient floor-to-floor clearance distance. While full deployment of a shock-absorbing lanyard will usually require between 12 and 19 feet of clearance, such clearances are not available on many structures. (For example, typical floor-to-floor heights in the United States are usually about 15 feet for hospitals, about 14 feet for office buildings, and about 10 feet for parking garages) Without sufficient clearance an ironworker’s lanyard may not stop him before his feet contact the floor below. However, his lanyard will usually either slow his fall or cause him to land feet first, either of which lowers the probability of a fatality or serious injury. In my opinion this is preferable to no tie-off, which provides additional mobility but minimal protection from fall hazards. Case Study # 2 provides substantial evidence in support of this position. Note that while OSHA may consider contacting the floor below to be a violation of construction regulation 29CFR§1926.502(d)(16)(iii), OSHA should consider such a violation to be a de minimus violation when an ironworker is working below the applicable threshold height at which tie-off is required.
Impact of 100% Tie-Off on Ironworker Safety
Considerations: When I initially considered requiring 100% tie-off for ironworkers, I had four questions regarding its impact on ironworker safety. The answers were found in the data shared in Case Study # 2.
Q1: Will ironworkers who fall into their safety harnesses and lanyards be saved from serious injury?
Answer: Ironworkers who are properly tied off and fall into their harnesses and shock-absorbing lanyards have an excellent chance of escaping injury other than minor cuts and bruises.
Q2: Will the loss of connector freedom of movement while tied off cause more injuries than it prevents?
Answer: While the use of 100% tie-off reduces connector mobility, such use will likely save more ironworkers from death or serious injury than it will harm.
Q3: Will six foot lanyards be too short to allow ironworkers to perform their duties without occasionally being pulled off of the steel because they are “tied to a short leash”?
Answer: In most instances, but not all situations, the use of six-foot lanyards will allow ironworkers to perform their duties without being pulled off of the steel.
Q4: Will ironworkers who are pulled off of the steel by their lanyards suffer serious injuries?
Answer: Ironworkers who are properly tied off and are pulled off of the steel by their harnesses and lanyards are not likely to suffer serious injury as a result.
Impact of 100% Tie-Off on Ironworker Productivity
Having observed ironworkers performing steel erection activities for many years, both before and after implementing a 100% tie-off policy for steel erection work, I have formed the following opinions:
- Productivity of connectors – There is minimal loss of productivity for connectors using 100% tie-off because connectors who use 100% tie-off are usually able to arrive at their next work position before the arrival of the next hoisted load.
- Productivity of ironworkers installing metal floor deck or metal roof deck – 100% tie-off significantly reduces ironworkers’ productivity during metal deck activities. However, it is my opinion that these productivity losses will be more than offset in the long term by the costs of ironworker deaths and serious injuries that will be suffered in the absence of 100% tie-off during decking activities.
100% Tie-Off During Steel Erection is a Best Practice
In construction, a best practice is a practice that goes “above and beyond” industry standard practice. The use of 100% tie-off by all ironworkers working at height should be considered a best practice because such a policy forgoes several OSHA tie-off exemptions for ironworkers and has not been accepted as standard practice by the construction industry. Use of this best practice can save ironworker lives during steel erection activities.
Recommendations
Ironworkers Should Use 100% Tie-Off
Individual ironworkers should weigh the risks discussed herein and forgo the optional tie-off exemptions provided by OSHA for all ironworkers performing steel erection work up to the 15-foot threshold; for connectors up to either the two-story or 30-foot threshold, whichever is less; and for deck installers in CDZ’s up to either the two-story or 30-foot threshold, whichever is less.
Steel Erectors Should Adopt 100% Tie-Off Policies
Steel erectors should weigh the risks discussed herein and establish policies that eliminate the OSHA tie-off exemptions provided for ironworkers in 29CFR§1926.760. Replacing the OSHA tie-off exemptions with a 100% tie-off policy above a threshold that is lower than OSHA’s requirements is not standard practice in the steel erection industry. By exceeding OSHA’s minimum fall protection requirements, such policies can minimize the likelihood of injury or death from ironworker falls during steel erection activities that, when combined, were responsible for 40% of the ironworker deaths studied by SENRAC (23% decking activities + 17% connecting activities = 40% of steel erection activities).
Conclusion
It is the author’s hope that the discussion herein has provided the answer to the question “Why should ironworkers tie off?” If more steel erection specialty contractors and individual ironworkers can be convinced of the benefits of 100% tie-off, any resulting increase in 100% tie-off at 6 feet or more above the ground or nearest work surface should lead to decreases in ironworker injuries and deaths.
About the Author – Homer R. Peterson II, P.E., CSP
Homer R. Peterson II, P.E., CSP serves as President of Peterson Construction Consulting, Inc. He provides consulting services, including expert witness services, to attorneys, insurance carriers, and companies engaged in both construction and general industry. He provides arbitration services through the American Arbitration Association (AAA). Throughout a 40-year career involving construction, steel erection, safety, and fall protection on more than 350 projects located in 21 U.S. states and territories, he has observed the policies, programs, procedures, standard practices, and best practices of more than 80 general contractors and numerous specialty contractors.
More information is available at www.homerpeterson.com.
