Does OSHA require a JHA for steel erection?

OSHA does not require a written JHA for steel erection. The steel erection standard does require written notifications before steel is erected and pre-planned hoisting (29 CFR 1926.752(a) and (d)), and a site-specific erection plan where the employer chooses certain alternate methods (29 CFR 1926.752(e)). A JHA can feed that planning.

What goes in a steel erection JHA?

Include approvals and site layout, anchorage, hoisting, setting and connecting, fall protection, falling object control and training. Name the competent person, the crane operator and the connectors.

When must connectors have fall protection?

Connectors must be protected from fall hazards of more than two stories or 30 feet above a lower level, whichever is less (29 CFR 1926.760(b)(1)). Other steel erection employees must be protected at more than 15 feet.

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FREE JHA TEMPLATE

Steel erection job hazard analysis (JHA) template

Steel erection puts crews at height with heavy members overhead, so falls, struck-by loads and structural collapse are the main hazards. OSHA requires fall protection for steel erectors on surfaces with an unprotected side or edge more than 15 feet above a lower level (29 CFR 1926.760(a)(1)), and columns anchored by at least four anchor rods. Plan the sequence early.

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JHA template

Steel erection

Step	Hazard	Controls
1. Get approval and plan the site and sequence	Steel is erected on foundations not ready…	Do not erect steel until the steel erector has…
2. Set and check column anchorage	Column falls or collapses when loaded	Anchor every column with at least four anchor rods.
3. Inspect the crane and plan the hoist	Load falls or crane fails during hoisting	Have a competent person visually inspect cranes used…

The task

Erecting columns, beams and connections on a multi-story steel frame, including anchor checks, hoisting, connecting, bolting up and fall protection.

Steps, hazards and controls

Controls run from most effective to least. A citation beside a control means an OSHA paragraph requires it; with no citation it is good practice.

Step	Hazard	Controls
1. Get approval and plan the site and sequence	Steel is erected on foundations not ready for the loads	Administrative control: Do not erect steel until the steel erector has written notice that the concrete in the footings, piers and walls has reached 75 percent of its intended minimum compressive design strength, or enough strength to carry the erection loads. (29 CFR 1926.752(b)) Administrative control: Provide the written notifications before erection is authorized. (29 CFR 1926.752(a)) Administrative control: Pre-plan all hoisting operations so the working-under-loads rules are met. Lay out laydown areas and travel routes as good practice. (29 CFR 1926.752(d))
2. Set and check column anchorage	Column falls or collapses when loaded	Engineering control: Anchor every column with at least four anchor rods. (29 CFR 1926.755(a)(1)) Engineering control: Set columns on level finished floors, pre-grouted leveling plates, leveling nuts or shim packs adequate to transfer construction loads. (29 CFR 1926.755(a)(3)) Administrative control: Confirm the anchor rods match the drawings before the first column is set.
3. Inspect the crane and plan the hoist	Load falls or crane fails during hoisting	Administrative control: Have a competent person visually inspect cranes used in steel erection before each shift. (29 CFR 1926.753(c)(1)(i)) Administrative control: Pre-plan the routes for suspended loads so that no employee is required to work directly below one, except for the permitted tasks. (29 CFR 1926.753(d)(1)) Administrative control: Use multiple lift rigging only if the criteria in the standard are met. (29 CFR 1926.753(e)(1))
4. Set beams and columns	Member shifts or is released before it is secured	Engineering control: Do not release the load from the hoisting line until the member is secured with at least two bolts per connection, as the standard requires. (29 CFR 1926.756(a)(1)) Engineering control: Keep the structure stable at all times during erection. (29 CFR 1926.754(a)) Administrative control: Use a tag line to control the load, and keep the area below clear.
5. Connect the steel at height	Connector falls at the leading edge	Eliminate: Pre-assemble sections on the ground to reduce work at height. Engineering control: Protect connectors from fall hazards of more than two stories or 30 feet, whichever is less, and others from more than 15 feet. (29 CFR 1926.760(b)(1)) Engineering control: Use guardrails, safety nets, personal fall arrest, positioning device or fall restraint systems for others over 15 feet. (29 CFR 1926.760(a)(1)) PPE: Use fall protection equipment that meets the criteria in 1926.502, such as a full-body harness tied off to a rated anchor, and plan for prompt rescue. (29 CFR 1926.760(d)(1))
5. Connect the steel at height	Tripping over studs or shear connectors	Engineering control: Do not attach shear connectors or similar devices to the top flanges until the metal decking or other walking surface is installed. (29 CFR 1926.754(c)(1)) Administrative control: Keep the walking surface clear and mark hazards.
6. Secure tools and materials aloft	Dropped tools and bolts strike people below	Engineering control: Secure all materials, equipment and tools not in use against accidental displacement. (29 CFR 1926.759(a)) Engineering control: Bar other construction processes below steel erection unless overhead protection is provided. (29 CFR 1926.759(b)) Administrative control: Use tool lanyards and bolt bags. PPE: Wear a hard hat with a chin strap in wind.
7. Train the crew and communicate	Crew does not understand the fall hazards or the plan	Administrative control: Have a qualified person train each employee exposed to a fall hazard, as the standard requires. (29 CFR 1926.761(b)) Administrative control: Hold a daily huddle on the erection plan, the sequence and the changes since yesterday.
8. Inspect, close out and plan the next lift	Hidden defects remain after a shift	Administrative control: Walk the erected steel at the end of the shift for loose bolts, unsecured members and missing protection. Administrative control: Tag any unsafe steel and keep people off until a competent person releases it.

Required PPE

Hard hat
Full-body harness with energy-absorbing lanyard (29 CFR 1926.760(d)(1))
Safety glasses
Cut-resistant gloves
Steel-toe boots

What the standard says

Fall protection is required above 15 feet. (29 CFR 1926.760(a)(1))
“each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6 m) above a lower level shall be protected from fall hazards”
Connectors are protected at more than two stories or 30 feet. (29 CFR 1926.760(b)(1))
“Be protected in accordance with paragraph (a)(1) of this section from fall hazards of more than two stories or 30 feet (9.1 m) above a lower level, whichever is less”
Anchor every column with at least four rods. (29 CFR 1926.755(a)(1))
“General requirements for erection stability. (1) All columns shall be anchored by a minimum of 4 anchor rods (anchor bolts).”
Secure members with at least two bolts before releasing the load. (29 CFR 1926.756(a)(1))
“During the final placing of solid web structural members, the load shall not be released from the hoisting line until the members are secured with at least two bolts per connection”
Secure materials and tools aloft. (29 CFR 1926.759(a))
“Securing loose items aloft. All materials, equipment, and tools, which are not in use while aloft, shall be secured against accidental displacement.”
Cranes must be inspected before each shift by a competent person. (29 CFR 1926.753(c)(1)(i))
“Cranes being used in steel erection activities shall be visually inspected prior to each shift by a competent person”
Pre-plan routes for suspended loads so no one is required to work directly below one, except for the permitted tasks. (29 CFR 1926.753(d)(1))
“Working under loads. (1) Routes for suspended loads shall be pre-planned to ensure that no employee is required to work directly below a suspended load except for:”

Training

Training for steel erection is provided by a qualified person (29 CFR 1926.761(a)). The employer must train each employee exposed to a fall hazard in the program the standard sets out (29 CFR 1926.761(b)).

Frequently asked questions

Does OSHA require a JHA for steel erection?: OSHA does not require a written JHA for steel erection. The steel erection standard does require written notifications before steel is erected and pre-planned hoisting (29 CFR 1926.752(a) and (d)), and a site-specific erection plan where the employer chooses certain alternate methods (29 CFR 1926.752(e)). A JHA can feed that planning.
What goes in a steel erection JHA?: Include approvals and site layout, anchorage, hoisting, setting and connecting, fall protection, falling object control and training. Name the competent person, the crane operator and the connectors.
When must connectors have fall protection?: Connectors must be protected from fall hazards of more than two stories or 30 feet above a lower level, whichever is less (29 CFR 1926.760(b)(1)). Other steel erection employees must be protected at more than 15 feet.

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