The result was an up to date, practical standard that was acceptable to the steel erection community and uniformly enforceable by compliance personnel.
In about 1992 there was an acknowledgment by the erectors that the safety record, insurance costs, and reputation of their industry needed fixing. This coincided with Region VIII OSHA taking steps to enforce the current OSHA standards more aggressively. There were some that felt they should fight OSHA, as it was apparent to some that the Regional Administrator was applying a weak federal law to steel erectors inappropriately. But, other forward thinking contractors that sincerely wanted to make a difference, voluntarily banded together to form a non-profit safety association specifically created to address the industry-wide safety issues and to allow all members to learn from one another and move toward improving safety and health records. The loose agreement with the OSHA Regional Administrator was that they would work with him to improve safety if he worked with them to get OSHA enforcement branches to understand the industry, make the existing laws better and more fairly enforced, and to apply the law equally to this trade. The contractors felt that they could assist OSHA in identifying the most hazardous activities instead of trivial laws that were antiquated and many times less relevant to improving safety. This loose agreement opened the door to many opportunities for OSHA to learn from the contractors, as well as allowed the contractors to successfully convince the Regional Administrator that certain practices are safer than others and that certain old interpretations by OSHA were potentially wrong and might even be more harmful, given modern technology and needs of the industry. Some of these newer understandings by OSHA found their way into the new Subpart R, Steel Erection Safety Standard, through a relatively new rulemaking process known as negotiated rulemaking. Several SESAC members as well as industry professionals and OSHA representatives from Colorado took part in this process known as SENRAC, the Steel Erection Negotiated Rulemaking Advisory Committee. In all, twenty representatives from across the Country served on this historic committee. The result was an up to date, practical standard that was acceptable to the steel erection community and uniformly enforceable by compliance personnel.