Steel Joist Institute v. Occupational Safety & Health Administration

287 F.3d 1165, 351 U.S. App. D.C. 162, 2002 CCH OSHD 32,565, 19 OSHC (BNA) 1849, 2002 U.S. App. LEXIS 8742, 2002 WL 856683
CourtCourt of Appeals for the D.C. Circuit
DecidedMay 7, 2002
Docket01-1184
StatusPublished
Cited by11 cases

This text of 287 F.3d 1165 (Steel Joist Institute v. Occupational Safety & Health Administration) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Steel Joist Institute v. Occupational Safety & Health Administration, 287 F.3d 1165, 351 U.S. App. D.C. 162, 2002 CCH OSHD 32,565, 19 OSHC (BNA) 1849, 2002 U.S. App. LEXIS 8742, 2002 WL 856683 (D.C. Cir. 2002).

Opinions

Opinion for the court filed by Circuit Judge KAREN LeCRAFT HENDERSON.

Concurring opinion filed by Circuit Judge ROGERS.

KAREN LeCRAFT HENDERSON, Circuit Judge:

On August 13, 1998 the Occupational Safety and Health Administration (OSHA) proposed revised “Safety Standards for Steel Erection” based on a consensus document submitted by a rulemaking advisory committee in a negotiated rulemaking. 63 Fed.Reg. 43,452 (1998). After a public hearing, two comment periods and a public consultation meeting, OSHA issued its final rule on January 18, 2001. See 66 Fed.Reg. 5196 (2001). The Steel Joist Institute (Institute) asks the court to invalidate three provisions of the final rule’s safety standard for open web steel joists. The three provisions are codified at 29 C.F.R. § 1926.757(a)(l)(iii), 29 C.F.R. § 1926.757(a)(3) and 29 C.F.R. § 1926.757(a)(8). Because the Institute presented argument against section 1926.757(a)(3) for the first time in its reply brief, its challenge to this provision is waived. See Benkelman Telephone Co. v. FCC, 220 F.3d 601, 607 n. 10 (D.C.Cir.2000) (argument found “waived because ... raised for the first time in the petitioners’ reply brief’) (citing Grant v. United States Air Force, 197 F.3d 539, 543 (D.C.Cir.1999) (citing Fraternal Order of Police v. United States, 173 F.3d 898, 902-03 (D.C.Cir.1999))). As explained below, we reject the Institute’s objections to section 1926.757(a)(l)(iii) and section 1926.757(a)(8), which require “field bolting” of steel joists, because they are authorized by section 6(b) of the Occupational Safety and Health Act of 1970, 29 U.S.C. § 655(b), (Act) and they are supported by substantial evidence.

Each of the two challenged provisions requires that joists be field bolted temporarily during steel erection to protect employees working on and around the joists until the joists are welded permanently in place. Specifically, they provide:

(1) Except as provided in paragraph (a)(2) of this section
(iii) Hoisting cables shall not be released until the seat at each end of the steel joist is field-bolted, and each end [1167]*1167of the bottom chord is restrained by the column stabilizer plate.
(8) Field-bolted joists.
(i) Except for steel joists that have been preassembled into panels, connections of individual steel joists to steel structures in bays of 40 feet (12.2 m) or more shall be fabricated to allow for field bolting during erection.
(ii) These connections shall be field-bolted unless constructibility does not allow.

29 C.F.R. § 1926.757(a)(l)(iii), (a)(8) (footnote added). The Institute challenges the provisions on two grounds.

First, the Institute contends that the provisions constitute an ultra vires attempt to regulate joist design and consequently the off-site joist manufacturers. We disagree. It is true that the Act authorizes OSHA to regulate only the employer’s conduct at the worksite. See 29 U.S.C. § 653(a) (“This chapter shall apply with respect to employment performed in a workplace.... ”); cf. Frank Diehl Farms v. Secretary of Labor, 696 F.2d 1325, 1332 (11th Cir.1983) (§ 653(a) does not authorize OSHA to regulate migrant worker’s living conditions); but the challenged provisions do not exceed OSHA’s statutory authority. Notwithstanding the infelicitous phrasing of section 1926.757(a)(8), which purports to direct how joists “shall be fabricated,” OSHA has made it clear that the challenged provisions are not enforceable, or intended to be enforced, against joist manufacturers.2 Regulation 1926.750 expressly declares that “[t]his subpart sets forth requirements to protect employees from the hazards associated with steel erection activities,” 29 C.F.R. § 1926.750(a) (emphasis added), and includes several examples of what constitutes such activities, see id. § 1926.750(b)(1) (“Steel erection activities include hoisting, laying out, placing, connecting, welding, burning, guying, bracing, bolting, plumbing and rigging structural steel, steel joists and metal buildings; installing metal decking, curtain walls, window walls, siding systems, miscellaneous metals, ornamental iron and similar materials; and moving point-to-point while performing these activities.”); see also id. § 1926.750(b)(2) (enumerating “activities [that] are covered by [the] subpart when they occur during and are a part of steel erection activities”). Further, the final rule carefully limns the scope of the standard, 66 Fed.Reg. at 5200-02, expressly stating that employers in “the fabricated structural metal industry ..., which produces iron and steel for structural purposes such as the construction of bridges and buildings, ... are not affected employers under the ... Act,” id. at 5261 (emphasis added). See also 29 C.F.R. § 5.2(i) (defining “building or work generally [to] include construction activity as distinguished from manufacturing, furnishing of materials, or servicing and maintenance work”); 29 C.F.R. § 1910.12 (safety standards “shall apply, according to the provisions thereof, to every employment and place of employment of every employee engaged in construction work” and defining “construction work” as “work for construction, alteration, and/or repair, including painting and decorating”). Insofar as the challenged provisions regulate the design of the joists used by the steel joist erector, OSHA’s authority to regulate the safety characteristics of tools and materials used at a worksite is well established. See, e.g., 29 C.F.R. § 1926.1053 (setting [1168]*1168requirements for worksite ladders); id. § 1926.550 (setting requirements for work-site cranes and derricks); Alabama Power Co. v. OSHA 89 F.3d 740

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Bluebook (online)
287 F.3d 1165, 351 U.S. App. D.C. 162, 2002 CCH OSHD 32,565, 19 OSHC (BNA) 1849, 2002 U.S. App. LEXIS 8742, 2002 WL 856683, Counsel Stack Legal Research, https://law.counselstack.com/opinion/steel-joist-institute-v-occupational-safety-health-administration-cadc-2002.