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Fall Protection FAQ
Question 1:
In residential construction, when employees are standing on top of concrete formwork with a fall hazard in excess of six feet, is conventional fall protection required?
Answer 1:
In residential construction, under STD 3.1 [superseded by STD 3-0.1A], conventional fall protection is not required for workers working from the top of foundation wall formwork.
See Letter of Interpretation
Question 2:
Answer 2:
Neither the ladder standard (29 CFR 1926, subpart X) nor the fall protection standard (29 CFR 1926, subpart M) requires fall protection for workers while working on portable ladders.
See Letter of Interpretation
Question 3:
In reference to 29 CFR 1926.501(b)(10), can trades other than roofers on low slope roofs use warning lines instead of conventional fall protection.
Answer 3:
OSHA has determined for other trades, work performed in areas that are further back from the distances specified for the warning lines permitted under the standard (1926.502(f), there is a point that is sufficiently far from the edge to warrant the application of a de minimis policy regarding non-conforming guardrails. Specifically, we will consider the use of certain physical barriers that fail to meet the criteria for a guardrail a de minimis violation of the guardrail criteria in 1926.502(b) where all of the following are met:
A warning line is used 15 feet or more from the edge;
The warning line meets or exceeds the requirements in 1926.502(f)(2);
No work or work-related activity is to take place in the area between the warning line and the edge; and
The employer effectively implements a work rule prohibiting the employees from going past the warning line.
In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system.
See Letter of Interpretation
Question 4:
Do vendors supplying roofing materials have to use conventional fall protection when delivering material to roof tops?
Answer 4:
The Agency''s policy was clearly stated in an Advance Notice of Proposed Rulemaking (ANPR), which was published in the Federal Register on July 14, 1999 (volume 64, page 38,077). In the ANPR, OSHA stated that it will not require the vendor's employees to install an anchorage point for fall protection [when distributing roofing materials] regardless of the slope of the roof or the fall distance. However, if an anchorage point is already available on the roof, the employees must use fall protection equipment.
See Letter of Interpretation
Question 5:
Answer 5:
Although the standard does not mention them, we do accept properly utilized fall restraint systems in lieu of fall arrest systems when the restraint system is rigged in such a way that the employee cannot get to the fall hazard. We suggest that, as a minimum, fall restraint systems have the capacity to withstand at least three thousand (3000) pounds of force or twice the maximum expected force that is needed to restrain the person from exposure to the fall hazard. In determining this force, consideration should be given to site-specific factors such as the force generated by a person walking, leaning, or sliding down the work surface.
See Letter of Interpretation
Question 6:
Answer 6:
Paragraph 1926.501(b)(7) requires fall protection around excavations only when the excavations are not readily seen because of plant growth or other visual barrier. Typically in residential construction, plant growth and other visual barriers is not an issue.
See Letter of Interpretation
Question 7:
Do you need a safety monitor when employees are working within the perimeter of the warning line system?
Answer 7:
As addressed in 29 CFR 1926.501(b)(10), individuals involved in roofing work on low-slope roofs must be protected from falling when exposed to unprotected sides and edges 6 feet or more above lower levels. This section gives several means of protection, one of which is the combination of a warning line system and a safety monitoring system. The warning line system is in place to protect those working within its perimeter, and only at the time when workers are required to go beyond this system would the monitor be needed to perform those functions listed in paragraph 1926.502(h).
See Letter of Interpretation
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