250.50 Grounding Electrode System.
All grounding electrodes as described in 250.52(A)(1) through (A)(7) that are present at each building or structure served shall be bonded together to form the grounding electrode system. Where none of these grounding electrodes exist, one or more of the grounding electrodes specified in 250.52(A)(4) through (A)(8) shall be installed and used.
(2) Metal Frame of the Building or Structure. The metal frame of the building or structure that is connected to the earth by any of the following methods:
(1) 3.0 m (10 ft) or more of a single structural metal member in direct contact with the earth or encased in concrete that is in direct contact with the earth
(2) Connecting the structural metal frame to the reinforcing bars of a concrete-encased electrode as provided in 250.52(A)(3) or ground ring as provided in 250.52(A)(4)
(3) Bonding the structural metal frame to one or more of the grounding electrodes as defined in 250.52(A)(5) or (A)(7) that comply with 250.56
(4) Other approved means of establishing a connection to earth
does your metal structural members meet the requirements above if not it is not a grounding electrode.
however it must still meet 250.104 (C)
(C) Structural Metal. Exposed structural metal that is interconnected to form a metal building frame and is not intentionally grounded and is likely to become energized shall be bonded to the service equipment enclosure, the grounded conductor at the service, the grounding electrode conductor where of sufficient size, or the one or more grounding electrodes used. The bonding jumper(s) shall be sized in accordance with Table 250.66 and installed in accordance with 250.64(A), (B), and (E). The points of attachment of the bonding jumper(s) shall be accessible.
Likely to become energized is open to interpretation.