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RE: Re: Plan check submittals and shop drawings

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There are undoutably some good provisions in the proposed OSHA regulations
but what I have a problem with is the role that the SEOR is assigned.

There is no doubt that the SEOR has an obligation to make sure that the
structure is buildable and to inform the Contractor of unusual
circumstances impacting erection when he is aware of them.  The problem
arises when the SEOR, who is hired by the Architect or Owner, is expected

1) Design the structure to withstand inadequate construction loads.  The
300 pounds at 18 inches is miniscule in comparison to other likely erection
loads.  My fear is that when there is an erection accident this provision
will be used to support the claim that the SEOR is responsible since he did
not design for some additional ill-defined erection loads.  The Contractor
is in a position to monitor, and control the construction loads and as such
he should have to responsibility for identifying and accommodating
construction loads.  If he wants to use larger anchor bolts or baseplates
most engineers would accommodate him.

2) Establish the need for guying or bracing of steel when anchor bolts are
replaced or modified.  Is it assumed that such guys or braces are not
needed prior to the modifications?  Most SEOR's are  not in a position to
establish the need for erection guys or bracing since their expertise is
not in the area of erection safety.

3) Establish the number of bolts that must be installed prior to releasing
the member from the hoist.  I do not know the erection sequence or the
actual wind levels.  In my ignorance, my inclination is to say install all
of the bolts before releasing the hoist. It may well be that this actually
creates a hazard by delaying the tying of the building together.  I believe
that this decision should remain with those who control the construction
site and who can monitor and balance the risks. 

4) Help develop and review the site-specific erection plan, the emphasis
being on erection safety.  My assumption is that the reference to the
"project engineer", is referring to the SEOR since the term "project
engineer" is not defined and the SEOR has been referred to as the "Project
Structural Engineer of Record".   For starters I would expect this to cause
some problems with the insurance.

By undertaking the above duties the SEOR would find himself in a situation
where he has no real control over the erection process yet he has
significant liability because of his limited involvement.  In addition such
duties are in conflict with most construction contracts, and if the SEOR
were to undertake them he would potentially expose the Owner to claims for
the cost of additional bracing or reduced productivity.

More fundamentally is the realization that the responsibility for site
safety must remain in the hands of one person who also has the authority to
control the construction site.  This person is not the SEOR.  Until we
address this issue we are not going to improve the safety at the
construction site.  

OSHA's estimation of the number of lives lost because individuals are not
following the existing regulations makes the point that the loss of life is
a reflection of the willingness of the contractors and workers to address
the problem.

Mark Gilligan SE