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OSHA Auditing: Federal Compliance: Construction:
The Complete Safety and Health Audit Checklist

www.stpub.com
OSHA Auditing:
Federal Compliance
Guide – Construction

© STP
OSHA Auditing:
Federal Compliance
Guide – Construction
A tool for assessing a
facility’s compliance with
the Occupational Safety and
Health Administration (OSHA)
regulations at 29 CFR 1926
and the general recordkeeping requirements of
29 CFR 1904

© STP
Users of This Guide
Include
• General construction and
demolition contractors
• Specialty construction
contractors and developers
• Construction and state
inspectors
• Engineering consultants
• Utility and larger
corporations
• And many more…
© STP
Features of This Guide
• Field-tested by recognized
experts
• Helps ensure compliance
• Helps avoid citations and
fines
• Allows experienced auditors
to expedite their assessment
• Allows less experienced
auditors to review detailed
instructions

© STP
Features of This Guide
• Saves time and reduces
compliance and audit costs
• Demonstrates due diligence
• Customizable to site-specific
requirements
• Applicability Tables
• Pre-audit Preparation
• Rulebooks
• Scoresheets

© STP
Comprehensive Topic
Areas
• General safety and health
• General recordkeeping and
posting
• Occupational exposures and
environmental controls
• Hazardous waste operations
and emergency response
• Process safety
• Personal protective and life
saving equipment
© STP
Comprehensive Topic
Areas
• Fire protection and
prevention
• Signs, signals and barricades
• Materials handling
• Hand and power tools
• Welding and cutting
• Electrical
• Scaffolds
• Fall protection
• Demolition
© STP
Features –
Applicability Tables
Use multi-level questions to
quickly determine which
regulations and sections of
the rulebooks apply to
specific facilities or
operations

© STP
Sample Applicability
Table
BLASTING AND USE OF EXPLOSIVES.
.
PART 1: INTRODUCTION
Applicability of This Module
Use the following General Applicability Checklist to determine whether a rulebook and its sections
apply to your operation.
If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for a
rulebook exemption.
Once you determine that the rulebook does apply to your operation, you must answer the section
questions. If a section question does not exist, then that section applies if the rulebook applies. If you
answer YES to a section question, that section applies to you unless you answer YES for an exemption
from that section. If you answer YES to a rulebook or section exemption, then the rulebook or section
does not apply.
.

.

.

.

Applies
.

Exempt

.

GENERAL APPLICABILITY CHECKLIST

.

.

.
.

Rulebook: Blasting and Use of Explosives
.
.

RULEBOOK: Do you handle, transport, use, or store explosives in construction activities?

Y

N

q

q

Y

N

q

q

Y

N

q

q

Y

N

q

q

Y

N

q

q

.

..............................................................................................................................................................................................................................................................

Section 2: Do you have employees who are blasters?

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

Section 3: Do your operations involve surface transportation of explosives?

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

Section 4: Do your operations involve underground transportation of explosives?

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

Section 5: Do your operations include storage of explosives or blasting agents at construction
sites?
.

...........................

...........................

.

..............................................................................................................................................................................................................................................................

Section 6: Do your operations include loading or preparing explosive or blasting agents for
use?
.

...........................

Y

q

...........................

N

q

.

..............................................................................................................................................................................................................................................................

Section 7: Do your operations include initiating explosives charges with electricity?

...........................

Y

q

q

Y

N

q

q

Y

N

q

...........................

N

q

.
.

..............................................................................................................................................................................................................................................................

Section 8: Do your operations include initiating explosives charges with safety fuse?

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

Section 9: Do your operations include initiating explosives charges with detonating cord?

...........................

...........................

.
.

© STP
Features – Pre-audit
Preparation
Lists materials to be
reviewed or prepared before
conducting an audit

© STP
Sample Pre-audit
Preparation
.

SCAFFOLDS.
.
PART 2: PRE–AUDIT PREPARATION.
.

Items to consider getting in advance:
•

Access to the information in 29 CFR 1926 Subpart L.

•

Access to the information in OSHA Directive CPL 02-01-023, “Inspection Procedures for
Enforcing Subpart L, Scaffolds Used in Construction,” available online at www.osha.gov/pls
/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1528.
OSHA has also adopted the following third party standards. We have listed the standards that are
cited in the regulations. We have provided contact information for each of the referenced third
parties in the appendix to the general introduction (located at the beginning of this manual).

•

The following standards of the American National Standard Institute (ANSI) and the Scaffolding
Industry Association (SIA) (as provided in Appendix C to Subpart L):
– ANSI/SIA A92.2-1990, “Vehicle Mounted Elevating and Rotating Aerial Devices,” including
Appendix.
– ANSI/SIA A92.3-1990, “Manually Propelled Elevating Aerial Platforms.”
– ANSI/SIA A92.5-1992, “Boom-Supported Elevating Work Platforms.”
– ANSI/SIA A92.6-1990, “Self-Propelled Elevating Work Platforms.”
– ANSI/SIA A92.7-1990, “Airline Ground Support Vehicle-Mounted Vertical Lift Devices.”
– ANSI/SIA A92.8-1993, “Vehicle-Mounted Bridge Inspection and Maintenance Devices.”
– ANSI A92.9-1993, “Mast-Climbing Work Platforms.” (Note: This Standard is not currently
available.)

•

The following Standards of the American Welding Society (AWS):
– AWS B3.0-41, “Welding Procedure and Performance Qualification.”
– AWS D8.4-61, “Recommended Practices for Automotive Welding Design.” (Note: This
Standard has been withdrawn and has not been replaced.)
– AWS D10.9-69, “Standard Qualification of Welding Procedures and Welders for Piping and
Tubing.”
– AWS D2.0-69, “Specifications for Welding Highway and Railway Bridges.” (Note: This
Standard is not currently available.)
© STP
Features – Rulebooks
Provide a comprehensive set
of regulatory requirement
statements, plus detailed
guidance on compliance
issues and inspection
procedures

© STP
Sample Rulebook
.

SCAFFOLDS.

.
PART 3: RULEBOOK
The requirements of this rulebook do not apply to crane or derrick suspended personnel
platforms. The criteria for aerial lifts are set out exclusively in 29 CFR 1926.453
(see section 34).
All dimensions are nominal sizes as provided in the American Lumber Standards, except that
where rough sizes are noted, only rough or undressed lumber of the size specified will satisfy
minimum requirements.
NOTE: OSHA has determined that standing on the guardrails of lifting equipment such as
aerial lifts or scissor lifts is not a suitable substitute for the use of scaffolding, even if the
employee is wearing fall protection. There may be specific prohibitions in some regulations,
but even in the absence of such regulations, the guardrails would have to meet all
requirements for scaffolding, including load requirements, and it is unlikely that these could be
met (OSHA Interpretation Letter, 10/23/02).

1.

Scaffold Capacity

1.1

Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a))

.

Guide Note
• Review the design of each scaffold and scaffold component to ensure it is capable of supporting, without
failure, its own weight and at least four times the maximum intended load applied or transmitted to it, except
as provided in 29 CFR 1926.451(a)(2) – (a)(5) and (g) (see section 7) (29 CFR 1926.451(a)(1)).
• Review the design to verify that direct connections to roofs and floors, and counterweights used to balance
adjustable suspension scaffolds are capable of resisting at least four times the tipping moment (the tendency to
cause a tip) imposed by the scaffold operating at the rated load of the hoist, or at least 1.5 times the tipping
moment imposed by the scaffold operating at the stall load of the hoist, whichever is greater (29 CFR
1926.451(a)(2)).
• Verify that each suspension rope, including connecting hardware, used on nonadjustable suspension scaffolds
is capable of supporting, without failure, at least six times the maximum intended load applied or transmitted
to that rope (29 CFR 1926.451(a)(3)).
• Verify that each suspension rope, including connecting hardware, used on adjustable suspension scaffolds is
capable of supporting, without failure, at least six times the maximum intended load applied or transmitted to
that rope with the scaffold operating at either the rated load of the hoist, or at least two times the stall load of
the hoist, whichever is greater (29 CFR 1926.451(a)(4)).
• Ensure that the stall load of any scaffold hoist does not exceed three times its rated load (29 CFR
1926.451(a)(5)).
• Ensure that all scaffolds are designed by a qualified person and are constructed and loaded in accordance with
that design (see Key Compliance Definitions in the Introduction to this module for the definition of a
“qualified person”) (29 CFR 1926.451(a)(6)).
NOTE: Non-mandatory Appendix A of this Subpart contains examples of construction, loading, and design
criteria for scaffolds.

© STP
Features –
Scoresheets
Enable quick recording of a
facility’s compliance status
for each requirement
Scoresheets are
customizable

© STP
Sample Scoresheet
.

SCAFFOLDS.

.
PART 4: SCORESHEET
SITE:

DATE:

1.

Scaffold Capacity

N/A

Complies

Does not
comply

1.1

Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a))

q

q

q

2.

Scaffold Platform Construction

N/A

Complies

Does not
comply

2.1

Scaffold platforms must be fully planked or decked according to specific
requirements. (29 CFR 1926.451(b)(1))

q

q

q

2.2

Scaffold platforms and walkways must be a certain width. (29 CFR 1926.451(b)(2))

q

q

q

2.3

The front edge and ends of platforms must be certain distances from the work and
from their supports. (29 CFR 1926.451(b)(3) – (b)(5))

q

q

q

2.4

Certain requirements must be met on scaffolds where planks are abutted and where
platforms are overlapped. (29 CFR 1926.451(b)(6) – (b)(7))

q

q

q

2.5

Scaffold platforms that change direction must meet certain requirements. (29 CFR
1926.451(b)(8))

q

q

q

2.6

The coating used on wood platforms must be in accordance with specific
requirements. (29 CFR 1926.451(b)(9))

q

q

q

2.7

Different scaffold components may be used only under certain circumstances.
(29 CFR 1926.451(b)(10) – (b)(11))

q

q

q

3.

Supported Scaffolds

N/A

Complies

Does not
comply

3.1

Supported scaffolds must meet certain criteria. (29 CFR 1926.451(c))

q

q

q

4.

Suspension Scaffolds

N/A

Complies

Does not
comply

4.1

Resting surfaces for suspension scaffold support devices must meet certain
requirements. (29 CFR 1926.451(d)(1))

q

q

q

.
.
.
.
.

.
.
.
.
.

.
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© STP
Formats
• Online single-user
• Online multi-user
• Loose-leaf
• CD
• Loose-leaf & CD
• Multi-user through risk
management systems

© STP
Up to 4 updates per
year
Sample Release Notes
OSHA Auditing: FederAl
COmpliAnCe guide:
COnStruCtiOn
Release #158
July 2012

new And nOtewOrtHy
•	 The Occupational Health and Safety Administration (OSHA) has issued a
direct final rule that modifies the requirements for head protection contained
in 29 CFR 1926.100(b). This change removes the 1969 edition of ANSI Z89.1
“Safety Requirements for Industrial Head Protection,” and allows compliance
with the 1997, 2003, or 2009 editions of the ANSI Standard. This rule will
become effective on September 20, 2012.

HigHligHtS OF tHiS releASe
•	 Personal Protective and Life Saving Equipment (Module E) Rulebook
section 3 has been updated to reflect the OSHA change indicated in “New
and Noteworthy” above.
•	 All sections of this Guide are being reviewed to ensure that the supplemental
information which is included to assist customers in applying regulations
is current, relevant, and clearly worded. Towards this end, the notes in the
rulebooks that refer the user to OSHA Letters of Interpretation and Compliance
Directives are being edited. Modules are also being edited to improve the clarity
of the information they contain, the wording of the cross-references for users of
paper editions of the publication, and the linking function for users of electronic
versions.
© STP
Please enjoy this sample of
OSHA Auditing:
Federal Compliance Guide –
Construction

© STP
FALL PROTECTION.
.
PART 1: INTRODUCTION
Applicability of This Module
Use the following General Applicability Checklist to determine whether a rulebook and its sections
apply to your operation.
If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for a
rulebook exemption.
Once you determine that the rulebook does apply to your operation, you must answer the section
questions. If a section question does not exist, then that section applies if the rulebook applies. If you
answer YES to a section question, that section applies to you unless you answer YES for an exemption
from that section. If you answer YES to a rulebook or section exemption, then the rulebook or section
does not apply.
.

GENERAL APPLICABILITY CHECKLIST
.

.

.

Applies
.

Exempt

.

.

.

.

.

Rulebook: Fall Protection
.
.

RULEBOOK: Do you have situations at your construction site where employees may be
exposed to a significant fall?
RULEBOOK Exemption: Do you meet any of the following exceptions:
• employees making an inspection, investigation, or assessment of workplace conditions
prior to the actual start of construction work or after all construction work has been
completed;
• employees work on scaffolds (see Scaffolds (Module M) Applicability Checklist);
• employees work on certain cranes and derricks (see Cranes and Derricks in Construction
(Module CC) Applicability Checklist);
• employees perform steel erection work (except towers and tanks) (see Steel Erection
(Module R) Applicability Checklist);
• employees work on certain types of equipment used in tunneling operations (see
Underground Construction (Module S) Applicability Checklist);
• employees are engaged in the erection of tanks and communication and broadcast towers
(see Personal Protective and Life Saving Equipment (Module E) Applicability Checklist);
• employees are engaged in construction of electric transmission and distribution lines and
equipment (see Power Transmission and Distribution (Module V) Applicability
Checklist); or
• employees work on stairways and ladders (see Stairways and Ladders (Module X)
Applicability Checklist)?
.

.

..............................................................................................................................................................................................................................................................

Section 3: Do you utilize personal fall arrest systems for fall protection?

Y

N

q

q
Y

...........................

Y

q

Y

q

Y

N

q

q

Y

N

q

q

...........................

N

q

q

N

q

N

q

.
.

..............................................................................................................................................................................................................................................................

Section 4: Do you utilize positioning systems for fall protection?

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

Section 5: Do you conduct roof work requiring the use of warning lines around roofs for fall
protection?
.
.

..............................................................................................................................................................................................................................................................

Section 6: Do you utilize a controlled access zone as part of your fall protection system?

...........................

...........................

...........................

...........................

.
.

..............................................................................................................................................................................................................................................................

COA 3/12 ©STP

...........................

...........................

FL/Part 1 - 1
Fall Protection Introduction
.

GENERAL APPLICABILITY CHECKLIST
.

.

Applies

Exempt

.

.

.

.

Section 7: Do your construction activities involve the use of safety monitoring systems for
fall protection?

.
.

NOTE: Employees engaged in roofing activities on low-slope roofs, with unprotected
sides and edges 6 feet (1.8 m) or more above lower levels must be protected from falling
by guardrail systems, safety net systems, personal fall arrest systems, or a combination of
warning line system and guardrail system, warning line system and safety net system, or
warning line system and personal fall arrest system, or warning line system and safety
monitoring system. Or, on roofs 50 feet (15.25 m) or less in width (see 29 CFR 1926
Subpart M Appendix A), the use of a safety monitoring system alone (i.e. without the
warning line system) is permitted (29 CFR 1926.510(b)(10)).

..............................................................................................................................................................................................................................................................

Section 8: Do your construction activities involve the use of covers on holes located in
roadways or vehicle aisles?
.
.

..............................................................................................................................................................................................................................................................

Section 9: Do your construction activities require the use of protection from falling objects?

.

Y

q

.

N

q

...........................

Y

q

q

Y

N

q

...........................

N

q

...........................

...........................

.
.

.

FL/Part 1 - 2

COA 3/12 ©STP
Fall Protection Introduction
Regulatory Summary
This module covers fall protection regulations found in 29 CFR 1926 Subpart M, which includes
29 CFR 1926.500 – 1926.503 and 29 CFR 1926 Appendix A – Appendix E. The federal regulations
that apply are organized into the following major sections:
• 29 CFR 1926.500 Scope, Application, and Definitions
• 29 CFR 1926.501 Duty to Have Fall Protection
• 29 CFR 1926.502 Fall Protection Systems Criteria and Practices
• 29 CFR 1926.503 Training Requirements
The following non-mandatory appendices to 29 CFR 1926 Subpart M serve as guidelines to assist
employers in complying with the appropriate requirements of this subpart:
• 29 CFR 1926 Appendix A, “Determining Roof Widths – Non-Mandatory Guidelines for
Complying with 29 CFR 1926.501(b)(10),” provides illustrations of roof plans and indicates where
each roof or roof area is to be measured to determine its width for fall protection purposes.
• 29 CFR 1926 Appendix B, “Guardrail Systems – Non-Mandatory Guidelines for Complying with
29 CFR 1926.502(b),” serves as a guideline and starting point to assist employers who are
designing guardrail systems.
• 29 CFR 1926 Appendix C, “Personal Fall Arrest Systems – Non-Mandatory Guidelines for
Complying with 29 CFR 1926.502(d),” provides test methods and other guidelines for personal fall
arrest systems and positioning device systems. Guidelines for positioning device systems are also
covered in 29 CFR 1926 Appendix D.
• 29 CFR 1926 Appendix D, “Positioning Device Systems – Non-Mandatory Guidelines for
Complying with 29 CFR 1926.502(e),” provides testing methods and inspection considerations for
positioning device systems.
• 29 CFR 1926 Appendix E, “Sample Fall Protection Plan – Non-Mandatory Guidelines for
Complying with 29 CFR 1926.502(k),” provides sample fall protection plans for
precast/prestressed concrete structures, residential construction, and leading edge work.
These federal regulations address fall protection requirements in construction work in states that
follow the federal Occupational Safety and Health Administration (OSHA) program and in states that
have their own programs but have adopted the federal regulations. They also apply to federal
employees and any construction work performed on federally owned property, no matter where it
occurs.
Some states and local agencies impose requirements in addition to those listed in this module. Since
employers must meet all applicable requirements, it is important to review regulations at the state and
local level as well.
OSHA frequently adopts third party standards by incorporating them by reference into the regulations.
These standards are provided by other governmental, non-profit, or trade organizations (such as the
American National Standards Institute [ANSI]). Many of these third party standards have been revised
since they were first incorporated into the regulations; however, because OSHA frequently has not
adopted the updates, it typically cannot enforce the requirements contained in the most recent version
of the standard (unless imminent danger is present). Throughout this module, we refer to the third
party standards that are cited in the regulations, even though in many cases these standards have been
revised, replaced, and/or deleted. We have provided contact information for each of the referenced
third party standards so that you can obtain the most recent information.
COA 3/12 ©STP

FL/Part 1 - 3
Fall Protection Introduction
Key Compliance Definitions
The following definitions are derived from 29 CFR 1926.500(b) unless otherwise noted. The
definitions of some general terms discussed in this module may be found in module C, “General
Safety and Health.”
Anchorage – A secure point of attachment for lifelines, lanyards, or deceleration devices.
Body belt (Safety belt) – A strap with means both for securing it about the waist and for attaching it to
a lanyard, lifeline, or deceleration device.
Body harness – Straps that, when secured about the employee, will distribute the fall arrest forces
over at least the thighs, pelvis, waist, chest, and shoulders and that have means for attaching the
harness to other components of a personal fall arrest system.
NOTE: This definition does not require nor does it exclude the use of a waist or chest strap as part of
a full body harness, as long as the harness properly distributes the fall arrest forces (OSHA
Interpretation and Compliance Letter 09/23/1999).
Buckle – Any device for holding the body belt or body harness closed around the employee’s body.
Connector – A device that is used to couple (connect) parts of the personal fall arrest system and
positioning device systems together. A connector may be an independent component of the system
(such as a carabiner) or it may be an integral component of part of the system (such as a buckle or
dee-ring sewn into a body belt or body harness, or a snap-hook spliced or sewn to a lanyard or selfretracting lanyard).
Controlled access zone (CAZ) – An area to which access is controlled and in which certain work (e.g.,
overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest
systems, or safety net systems.
Dangerous equipment – Equipment (such as pickling or galvanizing tanks, degreasing units,
machinery, electrical equipment, and other units) that, because of form or function, may be hazardous
to employees who fall onto or into such equipment.
Deceleration device – Any mechanism that serves to dissipate a substantial amount of energy during a
fall arrest or otherwise limit the energy imposed on an employee during fall arrest. Deceleration
devices include but are not limited to rope grabs, rip-stitch lanyards, specially woven lanyards, tearing
or deforming lanyards, and automatic self-retracting lifelines/lanyards.
Deceleration distance – The vertical distance a falling employee travels before stopping, excluding
lifeline elongation and free fall distance, from the point at which the deceleration device begins to
operate. Deceleration distance is measured as the distance between the location of an employee’s
body belt or body harness attachment point at the moment of activation (at the onset of fall arrest
forces) of the deceleration device during a fall, and the location of that attachment point after the
employee comes to a full stop.
Equivalent – Alternative designs, materials, or methods that protect against a hazard and that the
employer can demonstrate will provide an equal or greater degree of safety for employees than the
methods, materials, or designs specified in the standard.

FL/Part 1 - 4

COA 3/12 ©STP
Fall Protection Introduction
Failure – The occurrence of load refusal, breakage, or separation of component parts. (Load refusal is
the point where the structural members lose their ability to carry the load.)
Free fall – The act of falling before a personal fall arrest system begins to apply force to arrest the
fall.
Free fall distance – The vertical displacement of the fall arrest attachment point on the employee’s
body belt or body harness between onset of the fall and the time that the system begins to apply force
to arrest the fall. This distance excludes deceleration distance and lifeline/lanyard elongation, but
includes any deceleration device slide distance or self-retracting lifeline/lanyard extension that occurs
before the fall arrest forces begin.
Guardrail system – A barrier erected to prevent employees from falling to lower levels.
Hole – A gap or void that is 2 inches (5.1 cm) or more in its least dimension and that is located in a
floor, roof, or other walking/working surface.
Infeasible – Impossible to perform the construction work using a conventional fall protection system
(i.e., guardrail system, safety net system, or personal fall arrest system) or technologically impossible
to use any conventional fall protection system to provide fall protection.
Lanyard – A flexible rope, wire rope, or strap that generally has a connector at each end for
connecting the body belt or body harness to a deceleration device, lifeline, or anchorage.
Leading edge – The edge of a floor, roof, or formwork for a floor or other walking/working surface
(such as the deck) that changes location as additional floor, roof, decking, or formwork sections are
placed, formed, or constructed. A leading edge is considered an unprotected side and edge during
periods when it is not actively and continuously under construction.
Lifeline – A flexible line that connects either to an anchorage at one end to hang vertically (vertical
lifeline) or anchorages at both ends to stretch horizontally (horizontal lifeline), and that serves to
connect other components of a personal fall arrest system to the anchorage.
Low-slope roof – A roof with a slope less than or equal to 4 to 12 (vertical to horizontal).
Lower levels – Those areas or surfaces to which an employee can fall. Such areas or surfaces include,
but are not limited, to ground levels, floors, platforms, ramps, runways, excavations, pits, tanks,
material, water, equipment, structures, or portions thereof.
Mechanical equipment – All motor or human propelled wheeled equipment used for roofing work,
except wheelbarrows and mopcarts.
Opening – A gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide that is
located in a wall or partition through which employees can fall to a lower level.
Overhand bricklaying and related work – The process of laying bricks and masonry units such that
the surface of the wall to be jointed is on the opposite side of the wall from the mason, requiring the
mason to lean over the wall to complete the work. Related work includes mason tending and electrical
installation incorporated into the brick wall during the overhand bricklaying process.

COA 3/12 ©STP

FL/Part 1 - 5
Fall Protection Introduction
Personal fall arrest system – A system used to arrest an employee in a fall from a working level.
Personal fall arrest systems consist of an anchorage, connectors, and a body belt or body harness and
may include a lanyard, deceleration device, lifeline, or suitable combinations of these. As of
January 1, 1998, the use of a body belt for fall arrest is prohibited.
Positioning device system – A body belt or body harness system rigged to allow an employee to be
supported on an elevated vertical surface, such as a wall, and work with both hands free while
leaning.
Roof – The exterior surface on the top of a building. The term roof does not include floors or
formwork that, because a building has not been completed, temporarily become the top surface of a
building.
Roofing work – The hoisting, storage, application, and removal of roofing materials and equipment,
including related insulation, sheet metal, and vapor barrier work, but not including the construction of
the roof deck.
Rope grab – A deceleration device that travels on a lifeline and automatically, by friction, engages the
lifeline and locks to arrest the fall of an employee. A rope grab usually employs the principle of
inertial locking, cam/level locking, or both.
Safety belt – See Body belt above.
Safety-monitoring system – A safety system in which a competent person is responsible for
recognizing and warning employees of fall hazards.
Self-retracting lifeline/lanyard – A deceleration device containing a drum-wound line that can be
slowly extracted from, or retracted onto, the drum under slight tension during normal employee
movement, and that, after onset of a fall, automatically locks the drum and arrests the fall.
Snaphook – A connector comprised of a hook-shaped member with a normally closed keeper, or
similar arrangement, that may be opened to permit the hook to receive an object and, when released,
automatically closes to retain the object. Snaphooks are generally one of two types:
• the locking type, with a self-closing, self-locking keeper that remains closed and locked until
unlocked and pressed open for connection or disconnection; or
• the non-locking type, with a self-closing keeper that remains closed until pressed open for
connection or disconnection.
NOTE: As of January 1, 1998, the use of a non-locking snaphook as part of personal fall arrest
systems and positioning device systems is prohibited.
Steep roof – A roof having a slope greater than 4 to 12 (vertical to horizontal).
Toeboard – A low protective barrier that will prevent the fall of materials and equipment to lower
levels and provide protection from falls for personnel.
Unprotected sides and edges – Any side or edge (except at entrances to points of access) of a
walking/working surface (e.g., a floor, roof, ramp, or runway) where there is no wall or guardrail
system at least 39 inches (1.0 m) high.

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Fall Protection Introduction
Walking/working surface – Any surface, whether horizontal or vertical, on which an employee walks
or works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concrete
reinforcing steel, but not including ladders, vehicles, or trailers on which employees must be located
in order to perform their job duties.
Warning line system – A barrier erected on a roof that warns employees that they are approaching an
unprotected roof side or edge and that designates an area in which roofing work may take place
without the use of guardrail, body belt, or safety net systems to protect employees in the area.
Work area – That portion of a walking/working surface where job duties are being performed.

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Fall Protection Introduction
Appendices
Appendix 1: OSHA Compliance Letters
OSHA’S Enforcement Policy - Residential Construction
OSHA’s Standard Interpretation, 05/25/00, contains a memorandum from the Director, Directorate of
Construction clarifying a number of questions regarding residential construction. (See also OSHA’s
related Standard Interpretation, 08/10/00.)
Q1: Is apartment construction considered residential construction?
Only if the apartment complex is constructed using the same materials and methods as are
traditionally used for wood framed single-family houses and townhouses (i.e., raising stick framed
walls, installing wood trusses and floor joists, etc.) would its construction be considered residential.
An apartment constructed with precast concrete floors, structural steel, or other materials that are not
traditionally used in stick frame home construction would not be considered residential construction
and would be beyond the scope of STD 3-0.1A.
Q2: If residential construction materials and techniques are used for something other than a
residence, is the project considered residential construction? (Example: It looks like a house but
will be used as a dentist’s office.)
Yes. Note the answer to the next question.
Q3: Can you clarify the definition of residential construction?
This was a common request prior to the issuance of STD 3-0.1A. Section VIII of the new plain
language directive more thoroughly depicts what would constitute residential construction. It states
that where the working environment, materials, methods, and procedures are essentially the same as
those used in building a typical single-family home or townhouse, the employer would be considered
engaged in residential construction. Wood framing (not steel or concrete), wooden floor joists and
roof structures are characteristic of the materials used, and traditional wood frame construction
techniques are the methods used in residential construction. OSHA also recognizes metal studs as one
for one substitutions for the 2X4 wooden studs used in modern residential construction. Structures that
use metal studs are considered residential construction if they meet the other criteria for residential
construction.
Q4: How do the appendices for the fall protection standard relate to residential construction?
The appendices are non-mandatory — there is no requirement that they be followed. However, in
specified circumstances, an employer that follows them will be considered to be in compliance with
the standard. When a residential contractor can demonstrate that conventional fall protection either is
infeasible or creates a greater hazard, section 1926.501(b)(13) permits the use of a fall protection plan,
as outlined in 1926.502(k). Appendix E provides sample fall protection plans that contain the required
elements.

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Fall Protection Introduction
Q5: What are the spacing requirements for slide guards on roofs?
The spacing requirements are listed in STD 3-0.1A, Section D. “Alternative Procedures for Group 1
and Section G. – Alternative procedures for Group 4.” If an employer elects to follow STD 3-0.1A, or
is operating under the Roof Sheathing Operations section of Appendix E (59 FR 40753), it must
follow the spacing requirements in the Directive or the Appendix (they are the same). For a full
explanation of these guidelines, refer to the June 18, 1999 directive.
Q6: If the slide guards are not properly spaced, what should we cite?
If an employer (engaged in residential construction) does not provide conventional fall protection, the
compliance officer must determine if STD 3-0.1A provides alternative procedures for the activity in
question. If alternative procedures are available, the compliance officer must then determine whether
they have been properly implemented. If they have not, cite 1926.501(b)(13). No other provision may
be cited for a fall hazard addressed by .501(b)(13). Deficiencies in training required by 1926.20 may
be cited where appropriate.
Q7: What fall protection is required when trusses and rafters are being placed?
For employers operating under STD 3-0.1A (or Appendix E), the procedures are listed in STD 30.1A, Section VIII, paragraph D.
Q8: In light of the fact that devices (such as the “Truss-T”) have been developed, can residential
construction employers still claim that it is infeasible or creates a greater hazard to use
conventional fall protection equipment when performing this work? Will we continue to allow
employees to walk the walls, trusses, etc. without conventional fall protection equipment?
As long as STD 3-0.1A is in effect, employers may use the alternative procedures in the Directive for
the specified operations without showing that conventional fall protection is infeasible. The issue of
whether this policy should continue is being examined through the Advanced Notice of Proposed
Rulemaking (ANPR) for subpart M. The ANPR sought public comment on many of the questions you
have asked.

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Fall Protection Introduction
Appendix 2: Suggestions for Fall Protection During Installation of Roof Framing, Trusses, and
Components
OSHA Standard Interpretation, 08/03/99, offers employers the following control suggestions to protect
employees during residential construction and installation of roof framing, trusses, and components.
Additional information for residential construction may be found in the OSHA Directive, STD 30.1A, “Plain Language Revision of OSHA Instruction STD 3.1, Interim Fall Protection Compliance
Guidelines for Residential Construction” (effective June 18, 1999). (NOTE: STD 3-0.1A replaced
STD 3.1, “Interim Fall Protection Compliance Policy For Certain Residential Construction Activities,”
published December 8, 1995.)
One method is to assemble the roof as a unit on the ground and then raise it by crane.
Another method involves the use of both roof anchors (permanent as well as removable anchors are
available) and reusable truss braces. The reusable truss braces allow the trusses to be braced without
being on them. In this type of system, one end of the device is attached to the truss on the ground; the
other end has a rope attached to it. The truss is then erected either by crane or manually. Two
methods are commonly used to erect them manually. In both approaches workers at either end of the
truss work from ladders or platforms. In one approach the workers directly lift and place the truss on
the top plates. In the other approach, the truss is first placed upside down between the exterior walls.
The workers then rotate it up into place on the top plates. In either case, one or more roof anchors are
also attached to one or more strategically located trusses before those trusses are erected.
Once the truss is raised, a worker on the floor level pulls the rope that is attached to the other end of
the brace, which brings that end of the brace down onto the adjoining truss. At that point the brace is
locked onto both trusses. The process is repeated as each truss is erected. Depending on the size of the
truss, two or more braces are used per truss.
With all the braces locked in place, the trusses can now be sheathed. The initial courses of sheathing,
beginning at the eaves, are installed by workers who are on the inside of the structure on platforms.
They remove the braces one at a time, as each sheet of sheathing is installed.
Some employers will install all but the last (top) course from platforms on the inside. The last course
is then sheathed by workers on the roof who are tied-off to the previously installed roof anchor(s).
Others install added (wood) bracing sufficient to support a roof anchor so that the almost all of the
sheathing courses can be installed by workers on the roof while tied-off. Once the sheathing is done,
the weatherproofing material and roof-mounted equipment can be installed with workers tied-off to
the previously installed roof anchor(s).
There are a number of different types of roof anchors available for use during sheathing. Many are
made of metal and attach by screws or nails to a truss or framing members. Another type is comprised
of a D-ring attached to a fabric strap. The strap is nailed to and wrapped around one or more roof
trusses. The anchor is removed by cutting the D-ring from the strap or using double-headed nails to
allow the nails and the strap to be removed.

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FALL PROTECTION.
.
PART 2: PRE–AUDIT PREPARATION

Items to consider getting in advance:
•
•

•

Access to the information in 29 CFR 1926 Subpart M.
Access to the information in OSHA Directive STD 03-00-001, “Fall Protection Requirements for
Residential Construction,” available online at www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=DIRECTIVES&p_id=2288.
Access to the information on OSHA’s Construction Fall Protection webpage at
www.osha.gov/SLTC/fallprotection/construction.html.
Items to have facility personnel prepare or gather in advance:

•

Written certifications of fall protection training.

•

Fall protection training curriculum.

•

Equipment inspection and repair records. The next page has been removed from this sample.

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Fall Protection Pre–audit Preparation
Acronyms and Abbreviations Used in This Module
ANPR
ANSI
CAZ
CFR
cm
ft

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Advanced Notice of Proposed
Rulemaking
American National Standards
Institute
controlled access zone
Code of Federal Regulations
centimeter(s)
foot/feet

kg
kN
lb
m
N
OSHA
STD

kilogram(s)
kilonewtons
pound(s)
meter(s)
newton(s)
Occupational Safety and Health
Administration
Standard

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FALL PROTECTION.

.
PART 3: RULEBOOK
1.

Duty to Have Fall Protection

1.1

Walking/working surfaces must have the strength and structural integrity to support employees
safely. (29 CFR 1926.501(a)(2))

.

Guide Note
• Review procedures and interview employees to ensure that the walking/working surfaces on which employees
are to work have the strength and structural integrity to support employees safely (29 CFR 1926.501(a)(2)).
• Verify that employees are allowed to work only on those surfaces that have the requisite strength and
structural integrity (29 CFR 1926.501(a)(2)).

1.2

Employees on a walking/working surface must be protected from falling under certain
circumstances. (29 CFR 1926.501(b)(1))
Guide Note
• Verify that each employee on a walking/working surface (horizontal and vertical) with an unprotected side or
edge that is 6 ft (1.8 m) or more above a lower level is protected from falling by the use of guardrail systems,
safety net systems, or personal fall arrest systems (29 CFR 1926.501(b)(1)).
NOTE 1: The edge of a completed swimming pool not yet filled with water is considered an unprotected side
or edge of a walking/working surface and conventional fall protection would be required if workers were
exposed to a fall of 6 ft or more (OSHA Standard Interpretation, 06/08/98).
NOTE 2: This requirement also applies to fall protection during construction activities when employees are
working 6 ft or more above water (OSHA Standard Interpretation, 09/28/99).

1.3

Employees who are constructing leading edges or working nearby must be protected from
falling. (29 CFR 1926.501(b)(2))
Guide Note
• Verify that each employee who is constructing a leading edge that is 6 ft (1.8 m) or more above lower levels is
protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems
(29 CFR 1926.501(b)(2)(i)).
NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these
systems, the employer must develop and implement a fall protection plan that meets the requirements of
29 CFR 1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will
not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly,
the burden of proof is on the employer to establish that it is appropriate to implement the fall protection plan
only.
• Verify that each employee on a walking/working surface 6 ft (1.8 m) or more above a lower level where
leading edges are under construction, but who is not engaged in the leading edge work, is protected from
falling by a guardrail system, safety net system, or personal fall arrest system (29 CFR 1926.501(b)(2)(ii)).
NOTE: If a guardrail system is chosen to provide the fall protection, and a controlled access zone (CAZ) has
already been established for leading edge work, the control line may be used in lieu of a guardrail along the
edge that parallels the leading edge.

1.4

Employees in a hoist area must be protected from falling. (29 CFR 1926.501(b)(3))
Guide Note
• Verify that each employee in a hoist area is protected from falling 6 ft (1.8 m) or more to lower levels by
guardrail systems or personal fall arrest systems (29 CFR 1926.501(b)(3)).

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Fall Protection Rulebook
•

1.5

Review work practices to verify that if chains, gates, guardrail systems, or portions thereof are removed to
facilitate the hoist (e.g., during landing of materials), and if an employee must lean through the access opening
or out over the edge (e.g., to receive or guide materials), then each employee is protected from fall hazards by
a personal fall arrest system (29 CFR 1926.501(b)(3)).
NOTE: When all or part of a guardrail has been removed, all employees must be protected by a personal fall
arrest system, not just the employee(s) that must lean through the access (OSHA Standard Interpretation, Clips
used for wire rope guardrails; required fall protection in hoist area Question 2., 08/28/00).

Employees on walking/working surfaces with holes must be protected from falling. (29 CFR
1926.501(b)(4))
Guide Note
• Verify that each employee on walking/working surfaces is protected from falling through holes (including
skylights) more than 6 ft (1.8 m) above lower levels by personal fall arrest systems, covers, or guardrail
systems erected over or around such holes (29 CFR 1926.501(b)(4)(i)).
• Verify that each employee on a walking/working surface is protected from tripping in or stepping into or
through holes (including skylights) by covers (29 CFR 1926.501(b)(4)(ii)).
NOTE 1: This provision does not specify a minimum depth for this requirement to apply (OSHA Standard
Interpretation, 11/17/98).
NOTE 2: OSHA clarifies the terms “hole” versus “unprotected sides or edges” in their Standard Interpretation,
08/14/00.
• Verify that each employee on a walking/working surface is protected from objects falling through holes
(including skylights) by covers (29 CFR 1926.501(b)(4)(iii)).
NOTE: OSHA will treat a skylight as a cover if it is capable of supporting, without failure, at least twice the
weight of employees, equipment, and materials that may be imposed on it at any one time (OSHA Standard
Interpretation, 12/20/07).

1.6

Employees on the face of formwork or reinforcing steel must be protected from falling.
(29 CFR 1926.501(b)(5))
Guide Note
• Verify that each employee on the face of formwork or reinforcing steel used in concrete structures is protected
from falling 6 ft (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or
positioning device systems (29 CFR 1926.501(b)(5)).
NOTE: Fall protection is not necessary for employees climbing or moving on built-in-place rebar assemblies at
heights below 24 ft above lower levels, as the multiple hand holds and foot holds on rebar assemblies provide
protection similar to that of a fixed ladder. However, once employees have reached their work stations, or have
moved to points at least 24 ft above lower levels, fall protection is required (OSHA Standard Interpretation,
05/19/97). On formwork, employees must be protected at all times where the fall distance is 6 ft or more
above lower levels, including when employees are moving from point to point (OSHA Standard Interpretation,
08/28/00).

1.7

Employees on ramps, runways, and other walkways must be protected from falling. (29 CFR
1926.501(b)(6))
Guide Note
• Verify that each employee on ramps, runways, and other walkways is protected from falling 6 ft (1.8 m) or
more to lower levels by guardrail systems (29 CFR 1926.501(b)(6)).

1.8

Employees at the edge of excavations must be protected from falling. (29 CFR 1926.501(b)(7))
Guide Note
• Verify that each employee at the edge of excavations 6 ft (1.8 m) or more in depth is protected from falling by
guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or
other visual barrier (29 CFR 1926.501(b)(7)(i)).
• Verify that each employee at the edge of a well, pit, shaft, and similar excavation 6 ft (1.8 m) or more in depth
is protected from falling by guardrail systems, fences, barricades, or covers (29 CFR 1926.501(b)(7)(ii)).

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Fall Protection Rulebook
1.9

Employees above dangerous equipment must be protected from falling. (29 CFR
1926.501(b)(8))
Guide Note
• Verify that each employee less than 6 ft (1.8 m) above dangerous equipment is protected from falling into or
onto the equipment by guardrails systems or by equipment guards (29 CFR 1926.501(b)(8)(i)).
• Verify that each employee 6 ft (1.8 m) or more above dangerous equipment is protected from fall hazards by
guardrail systems, personal fall arrest systems, or safety net systems (29 CFR 1926.501(b)(8)(ii)).

1.10 Employees performing overhand bricklaying and related work must be protected from falling.
(29 CFR 1926.501(b)(9))
Guide Note
• Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee
performing bricklaying and related work 6 ft (1.8 m) or more above lower levels is protected from falling by
guardrail systems, safety net systems, or personal fall arrest systems or that the work is in a CAZ (29 CFR
1926.501(b)(9)(i)).
• Review work practices to verify that employees reaching more than 10 inches (25 cm) below the level of the
walking/working surface on which they are working are protected from falling by a guardrail system, safety
net system, or personal fall arrest system (29 CFR 1926.501(b)(9)(ii)).
NOTE: Bricklaying operations performed on scaffolds are regulated under 29 CFR 1926 Subpart L (see
module L, “Scaffolding”).

1.11 Employees engaged in roofing activities on low-slope roofs must be protected from falling.
(29 CFR 1926.501(b)(10))
Guide Note
• Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee
engaged in roofing activities on low-sloped roofs, with unprotected sides and edges 6 ft (1.8 m) or more above
lower levels is protected from falling by any of the following (29 CFR 1926.501(b)(10)):
– guardrail systems;
– safety net systems;
– personal fall arrest systems;
– a combination of a warning line system and guardrail system;
– a combination of a warning line system and safety net system;
– a combination of a warning line system and personal fall arrest system; or
– a combination of a warning line system and safety monitoring system.
NOTE 1: On roofs 50 ft (15.25 m) or less in width (see Appendix A to this subpart), the use of a safety
monitoring system alone (i.e., without the warning line system) is permitted. (See also OSHA Standard
Interpretation, 01/16/01).
NOTE 2: An employer may use a combination of warning lines 6 ft (and in some cases 10 ft) back from
the edge in combination with monitors in place of personal fall protection equipment or guardrails (OSHA
Standard Interpretation, 08/01/00).

1.12 Employees on a steep roof must be protected from falling. (29 CFR 1926.501(b)(11))
Guide Note
• Verify that each employee on a steep roof with unprotected sides and edges 6 ft (1.8 m) or more above lower
levels is protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest
systems (29 CFR 1926.501(b)(11)).

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Fall Protection Rulebook
1.13 Employees engaged in the erection of precast concrete members must be protected from falling.
(29 CFR 1926.501(b)(12))
Guide Note
• Verify that each employee engaged in the erection of precast concrete members (including but not limited to
the erection of wall panels, columns beams, and floor and roof “tees”) and related operations (such as grouting
of precast concrete members) who is 6 ft (1.8 m) or more above lower levels is protected from falling by any
of the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 – 1.16] provides for an alternative fall
protection measure) (29 CFR 1926.501(b)(12)):
– guardrail systems;
– safety net systems; or
– personal fall arrest systems.
NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these
systems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR
1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not create
a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burden
of proof is on the employer to establish that it is appropriate to implement the fall protection plan only.

1.14 Employees engaged in residential construction must be protected from falling. (29 CFR
1926.501(b)(13))
Guide Note
• Verify that each employee engaged in residential construction who is 6 ft (1.8 m) or more above lower levels
is protected from falling by any of the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 to 1.16]
provides for an alternative fall protection measure) (29 CFR 1926.501(b)(13)):
– guardrail systems;
– safety net systems; or
– personal fall arrest systems.
NOTE 1: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these
systems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR
1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not create
a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burden
of proof is on the employer to establish that it is appropriate to implement the fall protection plan only.
NOTE 2: OSHA Instruction STD 03-00-001, “Interim Fall Protection Compliance Guidelines for Residential
Construction,” modifies the above requirements. It permits employers engaged in certain residential
construction activities (e.g., homebuilders and roofing contractors) to use alternative procedures routinely
instead of conventional fall protection. Different alternate procedures are specified for different activities. Such
employers do not have to demonstrate the infeasibility of conventional fall protection as a precondition to
using the STD 03-00-001 alternative procedures. They also do not have to put their fall protection plan in
writing, nor does the plan have to be site-specific .
NOTE 3: See the Appendix in the introduction to this module for an OSHA Standard Interpretation, 05/25/00,
providing further interpretation on OSHA’s enforcement policy for residential construction.

1.15 Employees working on, at, above, or near wall openings must be protected from falling.
(29 CFR 1926.501(b)(14))
Guide Note
• If there are wall openings (including those with chutes attached) where the outside bottom edge of the wall
opening is 6 ft (1.8 m) or more above lower levels and the inside bottom edge of the wall opening is less than
39 inches (1.0 m) above the walking/working surface, then verify that each employee working on, at, above, or
near such openings is protected from falling by any of the following (29 CFR 1926.501(b)(14)):
– guardrail systems;
– safety net systems; or
– personal fall arrest systems.

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Fall Protection Rulebook
1.16 Employees must be protected from falling on walking/working surfaces not otherwise
addressed in this section. (29 CFR 1926.501(b)(15))
Guide Note
• Except as provided in 29 CFR 1926.500(a)(2) (see the Introduction to this module) or in 29 CFR
1926.501(b)(1) – (b)(14) (see paragraphs 1.2 – 1.15), verify that each employee on a walking/working surface
6 feet (1.8 m) or more above lower levels is protected from falling by any of the following (29 CFR
1926.501(b)(15)):
– guardrail systems;
– safety net systems; or
– personal fall arrest systems.

1.17 Employers must provide protection from falling objects. (29 CFR 1926.501(c))
Guide Note
• Verify that when employees are exposed to falling objects, the employer has each employee wear a hard hat
and implements one of the following actions (29 CFR 1926.501(c)):
– erects toeboards, screens, or guardrail systems to prevent objects from falling from higher levels;
– erects a canopy structure and keeps potential fall objects far enough from the edge of the higher level
so that objects will not go over the edge if they are accidentally displaced; or
– barricades the area to which objects could fall, prohibits employees from entering the barricaded area, and
keeps objects that may fall far enough away from the edge of the higher level so that those objects will
not go over the edge if they are accidentally displaced.
NOTE: Additional provisions for protection from falling objects are found in 29 CFR 1926.502(j) (see section
9).

2.

Fall Protection Systems Criteria and Practices

.

All fall protection systems must be designed according to these requirements and installed
before employees begin the work requiring fall protection (29 CFR 1926.502(a)(2)).
2.1

Top edge height of top rails, or equivalent guardrail system members, must meet certain
requirements. (29 CFR 1926.502(b)(1))
Guide Note
• Verify that the top edge height of top rails, or equivalent guardrail system members, is 42 inches (1.1 m) .
± 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may
exceed the 45 inch limit, provided the guardrail system meets all other criteria of 29 CFR 1926.502(b) (see
also paragraphs 2.2 – 2.7) (29 CFR 1926.502(b)(1)).
NOTE: When employees are using stilts, the top edge height of the top rail, or equivalent member, must be
increased an amount equal to the height of the stilts.

2.2

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural
members must be installed according to certain requirements. (29 CFR 1926.502(b)(2))
Guide Note
• Verify that midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural
members are installed between the top edge of the guardrail system and the walking/working surface when
there is no wall or parapet wall at least 21 inches (53 cm) high (29 CFR 1926.502(b)(2)). When midrails are
used, verify that they are installed midway between the top edge of the guardrail system and the
walking/working level (29 CFR 1926.502(b)(2)(i)).
• Verify that screens and mesh, when used, extend from the top rail to the walking/working level and along the
entire opening between top rail supports (29 CFR 1926.502(b)(2)(ii)).
• Verify that intermediate members (such as balusters), when used between posts, are no more than 19 inches
(48 cm) apart (29 CFR 1926.502(b)(2)(iii)).
• Verify that other structural members (such as additional midrails and architectural panels) are installed so that
there are no openings in the guardrail system more than 19 inches (48 cm) wide (29 CFR 1926.502(b)(2)(iv)).

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Fall Protection Rulebook
2.3

Guardrail systems must be able to withstand a specified amount of force and pressure. (29 CFR
1926.502(b)(3) – (b)(4))
Guide Note
• Verify that all guardrail systems are capable of withstanding, without failure, a force of at least 200 lb (890 N)
applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the
top edge (29 CFR 1926.502(b)(3)).
• Verify that when the 200 lb (890 N) test load is applied in a downward direction, the top edge of the guardrail
does not deflect to a height less than 39 inches (1.0 m) above the walking/working level (29 CFR
1926.502(b)(4)).
NOTE: Guardrail system components selected and constructed in accordance with Appendix B to this subpart
meet this requirement.

2.4

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural
members must be able to withstand a specified amount of force. (29 CFR 1926.502(b)(5))
Guide Note
• Verify that midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural
members are capable of withstanding, without failure, a force of at least 150 lb (666 N) applied in any
downward or outward direction at any point along the midrail or other member (29 CFR 1926.502(b)(5)).

2.5

Guardrail systems must be properly constructed to prevent injury. (29 CFR 1926.502(b)(6) –
(b)(10) and (b)(14))
Guide Note
• Verify that guardrail systems are surfaced to prevent injury to an employee from punctures or lacerations and
to prevent snagging of clothing (29 CFR 1926.502(b)(6)).
• Verify that the ends of all top rails and midrails do not overhang the terminal posts, except where the overhang
does not constitute a projection hazard (29 CFR 1926.502(b)(7)).
• Verify that steel banding and plastic banding are not used as top rails or midrails (29 CFR 1926.502(b)(8)).
• Verify that top rails and midrails are at least 1/4 inch (0.6 cm) nominal diameter or thickness to prevent cuts
and lacerations (29 CFR 1926.502(b)(9)).
• If wire rope is used for top rails, verify that it is flagged at not more than 6-ft intervals with high-visibility
material (29 CFR 1926.502(b)(9)).
• When guardrail systems are used at hoisting areas, verify that a chain, gate, or removable guardrail section is
placed across the access opening between guardrail sections when hoisting operations are not taking place
(29 CFR 1926.502(b)(10)).
• Verify that guardrail systems used on ramps and runways are erected along each unprotected side or edge
(29 CFR 1926.502(b)(14)).

2.6

Guardrail systems around holes must meet certain requirements. (29 CFR 1926.502(b)(11) –
(b)(13))
Guide Note
• When guardrail systems are used at holes, verify that they are erected on all unprotected sides or edges of the
hole (29 CFR 1926.502(b)(11)).
• When guardrail systems are used around holes used for the passage of materials, verify that no more than two
sides of the hole are provided with removable guardrail sections to allow the passage of materials (29 CFR
1926.502(b)(12)).
• When the hole is not in use, verify that it is closed over with a cover or that a guardrail system is provided
along all unprotected sides or edges (29 CFR 1926.502(b)(12)).
• When guardrail systems are used around holes that are used as points of access (such as ladderways), verify
that they are provided with a gate, or are so offset that a person cannot walk directly into the hole (29 CFR
1926.502(b)(13)).

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2.7

Manila, plastic, or synthetic rope must meet certain strength requirements. (29 CFR
1926.502(b)(15))
Guide Note
• Verify that manila, plastic, or synthetic rope being used for top rails or midrails is inspected as frequently as
necessary to verify that it continues to meet the strength requirements of 29 CFR 1926.502(b)(3) (see
paragraph 2.3) (29 CFR 1926.502(b)(15)).
NOTE: The OSHA standard does not specify a minimum number of clips when using wire rope as a guardrail.
However, as a practical matter, it is unlikely you could meet the specific requirements under 29 CFR
1926.502(b) unless you follow the manufacturer’s recommendations for the number of clips to be used on wire
ropes of different diameters (OSHA Interpretation Letter, 08/28/00).

2.8

Safety net systems must be installed and used according to certain requirements. (29 CFR
1926.502(c)(1) – (c)(3))
Guide Note
• Inspect safety nets to ensure they are installed as close as practicable under the walking/working surface on
which employees are working, but no more than 30 ft (9.1 m) below such level (29 CFR 1926.502(c)(1)).
• When nets are used on bridges, verify that the potential fall area from the walking/working surface to the net is
unobstructed (29 CFR 1926.502(c)(1)).
• Inspect safety nets to ensure they extend outward from the outermost projection of the work surface as
indicated in Table 1 (29 CFR 1926.502(c)(2)).
• Verify that safety nets are installed with sufficient clearance under them to prevent contact with the surface or
structures below when subjected to an impact force equal to the drop test specified in 29 CFR
1926.502(c)(4)(i) (see paragraph 2.9) (29 CFR 1926.502(c)(3)).
Table 1: Horizontal Extension of Safety Nets from Work Surface
Vertical distance from working level to
horizontal plane of net

Minimum required horizontal distance of outer
edge of net from the edge of the working surface

Up to 5 ft

8 ft

5 ft – 10 ft

10 ft

More than 10 ft

13 ft
Source: 29 CFR 1926.502(c)(2)

2.9

Safety nets and safety net installations must be drop-tested. (29 CFR 1926.502(c)(4))
Guide Note
• Verify that safety nets and their installations are capable of absorbing an impact force equal to that produced
by the drop test specified in 29 CFR 1926.502(c)(4)(i) (29 CFR 1926.502(c)(4)).
• Verify that safety nets and safety net installations are drop-tested at the jobsite at the following times (29 CFR
1926.502(c)(4)(i)):
– after initial installation and before being used as a fall protection system;
– whenever they are relocated;
– after major repair; and
– at six-month intervals if left in one place.
• Review procedures to ensure that the drop-test consists of a 400 lb (180 kg) bag of sand 30 inches ± 2 inches
(76 cm ± 5 cm) in diameter dropped into the net from at least 42 inches (1.1 m) above the highest
walking/working surface at which employees are exposed to hazards (29 CFR 1926.502(c)(4)(i)).
• When the employer can demonstrate that it is unreasonable to perform the drop-test, verify that the employer
certifies that the net and net installation is in compliance with the provisions of 29 CFR 1926.502(c)(3) and
(c)(4)(i) (see paragraph 2.8) by preparing a certification record prior to the net being used as a fall protection
system. The most recent certification record for each net and net installation must be available at the jobsite
for inspection and must include the following (29 CFR 1926.502(c)(4))(ii)):
– an identification of the net and net installation for which the certification record is being prepared;
– the date that it was determined that the identified net and net installation were in compliance; and
– the signature of the person making the determination and certification.

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2.10 Safety nets and safety net systems must be inspected for wear, damage, deterioration, and
defects. (29 CFR 1926.502(c)(5))
Guide Note
• Verify that safety nets are inspected at least once a week for wear, damage, and other deterioration (29 CFR
1926.502(c)(5)).
• Verify that safety nets are inspected after any occurrence that could affect the integrity of the safety net system
(29 CFR 1926.502(c)(5)).
• Verify that defective nets are not used and that defective components are removed from service (29 CFR
1926.502(c)(5)).

2.11 Objects that fall into safety nets must be removed as soon as possible. (29 CFR 1926.502(c)(6))
Guide Note
• Verify that materials, scrap pieces, equipment, and tools that have fallen into safety nets are removed as soon
as possible from the net and at least before the next work shift (29 CFR 1926.502(c)(6)).

2.12 Safety nets must be constructed according to certain requirements. (29 CFR 1926.502(c)(7) –
(c)(9))
Guide Note
• Measure the maximum size of each safety net mesh opening to ensure it conforms to the following
requirements (29 CFR 1926.502(c)(7)):
– Each opening must not exceed 36 sq inches (230 cm2) nor be longer than 6 inches (15 cm) on any side.
– The opening, measured center-to-center of mesh ropes or webbing, must not be longer than 6 inches
(15 cm).
– All mesh crossings must be secured to prevent enlargement of the mesh opening.
• Verify that each safety net (or section of it) has a border rope for webbing with a minimum breaking strength
of 5,000 lb (22.2 kN) (29 CFR 1926.502(c)(8)).
• Ensure that connections between safety net panels are as strong as integral net components and are not spaced
more than 6 inches (15 cm) apart (29 CFR 1926.502(c)(9)).

3.

Personal Fall Arrest Systems

.

Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest
system. The use of a body belt in a positioning device system is acceptable and is regulated
under 29 CFR 1926.502(e) (see section 4 below) (29 CFR 1926.502(d)).
3.1

Connectors for personal fall arrest systems must meet certain requirements. (29 CFR
1926.502(d)(1) – (d)(6))
Guide Note
• Inspect connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalent materials
(29 CFR 1926.502(d)(1)).
• Inspect connectors to verify that they have a corrosion-resistant finish and that all surfaces and edges are
smooth to prevent damage to interfacing parts of the system (29 CFR 1926.502(d)(2)).
• Verify that dee-rings and snaphooks have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR
1926.502(d)(3)).
• Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without
cracking, breaking, or taking permanent deformation (29 CFR 1926.502(d)(4)).
• Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR
1926.502(d)(5)):
– Snaphooks are a compatible size for the member to which they are connected.
– Only locking type snaphooks are used.

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•

3.2

Verify that unless snaphooks are a locking type and are designed for the following connections, the snaphooks
are not engaged (29 CFR 1926.502(d)(6)):
– directly to webbing, rope, or wire rope;
– to each other;
– to a dee-ring to which another snaphook or other connector is attached;
– to a horizontal lifeline; or
– to any object that is incompatibly shaped or dimensioned in relation to the snaphook such that
unintentional disengagement could occur by the connected object depressing the snaphook keeper and
releasing itself.

Lifelines for personal fall protection systems must meet certain requirements. (29 CFR
1926.502(d)(7) – (d)(14))
Guide Note
• Verify that on suspended scaffolds or similar work platforms with horizontal lifelines that may become vertical
lifelines, the devices used to connect to a horizontal lifeline are capable of locking in both directions on the
lifeline (29 CFR 1926.502(d)(7)).
• Verify that horizontal lifelines are designed, installed, and used under the supervision of a qualified person as
part of a complete personal fall arrest system that maintains a safety factor of at least 2 (29 CFR
1926.502(d)(8)).
• Verify that lanyards and vertical lifelines have a minimum breaking strength of 5,000 lb (22.2 kN) (29 CFR
1926.502(d)(9)).
• Verify that when vertical lifelines are used, each employee is attached to a separate lifeline (29 CFR
1926.502(d)(10)(i)).
EXCEPTION: During the construction of elevator shafts, 2 employees may be attached to the same lifeline in
the hoistway, provided that all of the following conditions are met (29 CFR 1926.502(d)(10)(ii)):
– Both employees are working atop a false car that is equipped with guardrails.
– The strength of the lifeline is 10,000 lb (44.4 kN) (5,000 lb per employee attached).
– All other criteria specified in 29 CFR 1926.502(d) (see section 3) for lifelines have been met.
• Verify that lifelines are protected against being cut or abraded (29 CFR 1926.502(d)(11)).
• Verify that self-retracting lifelines and lanyards that automatically limit free fall distance to 2 ft (0.61 m) or
less are capable of sustaining a minimum tensile load of 3,000 lb (13.3 kN) applied to the device with the
lifeline or lanyard in the fully extended position (29 CFR 1926.502(d)(12)).
• Verify that self-retracting lifelines and lanyards that do not limit free fall distance to 2 ft (0.61 m) or less,
ripstitch lanyards, and tearing and deforming lanyards are capable of sustaining a minimum tensile load of
5,000 lb (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position (29 CFR
1926.502(d)(13)).
• Verify that ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and
body harnesses are made from synthetic fibers (29 CFR 1926.502(d)(14)).

3.3

Anchorages used for attachment of personal fall arrest systems must be designed, installed, and
used according to certain requirements. (29 CFR 1926.502(d)(15))
Guide Note
• Verify that anchorages used for attachment of personal fall arrest equipment meet either of the following
conditions (29 CFR 1926.502(d)(15)):
– The anchorages are independent of any anchorage being used to support or suspend platforms and are
capable of supporting at least 5,000 lb (22.2 kN) per employee attached.
– The anchorages are designed, installed, and used under the supervision of a qualified person as part of a
complete personal fall arrest system that maintains a safety factor of at least 2.
NOTE: OSHA allows scaffolding to function as a suitable anchorage for fall arrest systems when the
scaffolding used is erected and braced such that the criteria of 29 CFR 1926.502(d)(15) are met. This applies
whether the scaffold is partially built (i.e., being erected or disassembled) or completely built (OSHA Standard
Interpretation, 04/02/98).

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3.4

When stopping a fall, personal fall arrest systems must meet certain requirements. (29 CFR
1926.502(d)(16))
Guide Note
• Verify that when stopping a fall, personal fall arrest systems (29 CFR 1926.502(d)(16)):
– limit maximum arresting force on an employee to 900 lb (4 kN) when used with a body belt;
– limit maximum arresting force on an employee to 1,800 lb (8 kN) when used with a body harness;
– be rigged such that an employee can neither free fall more than 6 ft (1.8 m) nor contact any lower level;
– bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5
ft (1.07 m); and
– have sufficient strength to withstand twice the potential impact energy of an employee free falling a
distance of 6 ft (1.8 m) or the free fall distance permitted by the system, whichever is less.
NOTE 1: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to this
subpart, and if the system is being used by an employee with a combined person and tool weight of less than
310 lb (140 kg), the system will be considered to be in compliance with the provisions of 29 CFR
1926.502(d)(16) (see guide notes above). If the system is used by an employee with a combined tool and body
weight of 310 lb (140 kg) or more, then the employer must appropriately modify the criteria and protocols of
the appendix to provide proper protection for such heavier weights, or the system will not be deemed to be in
compliance.
NOTE 2: Shock-absorbing lanyards are not mandatory but may be used to comply with this provision (OSHA
Standard Interpretation, 06/03/98).
NOTE 3: A body harness used as a component of a personal fall arrest system does not require nor does it
exclude the use of a waist or chest strap as part of a full body harness, as long as the harness properly
distributes the fall arrest forces (OSHA Standard Interpretation, 09/23/99).

3.5

Body belts and harnesses on personal fall arrest systems must meet certain requirements.
(29 CFR 1926.502(d)(17) – (d)(18) and (d)(22))
Guide Note
• Verify that the attachment point of a body belt is located in the center of the wearer’s back (29 CFR
1926.502(d)(17)).
• Verify that the attachment point of a body harness is located in the center of the wearer’s back near shoulder
level or above the wearer’s head (29 CFR 1926.502(d)(17)).
• Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal
fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(d)(18)).
NOTE: If any component of the rigging system, such as a shackle, wire rope, or synthetic sling was or is used
to hoist materials, these components are not be used as part of a fall protection system (OSHA Standard
Interpretation, 11/03/00, Question 4).
• Inspect all body belts to ensure they are at least 1 5/8 inches (4.1 cm) wide (29 CFR 1926.502(d)(22)).

3.6

Personal fall arrest systems and components must be inspected under certain conditions.
(29 CFR 1926.502(d)(19) and (d)(21))
Guide Note
• Verify that personal fall arrest systems and components subjected to impact loading are immediately removed
from service and are not used again for employee protection until inspected and determined by a competent
person to be undamaged and suitable for reuse (29 CFR 1926.502(d)(19)).
• Review procedures to ensure that personal fall arrest systems are inspected prior to each use for wear, damage,
and other deterioration and that defective components are removed from service (29 CFR 1926.502(d)(21)).

3.7

Personal fall arrest systems must not be attached to guardrail systems or hoists, except as
specified in this subpart. (29 CFR 1926.502(d)(23))
Guide Note
• Verify that personal fall arrest systems are not attached to guardrail systems (29 CFR 1926.502(d)(23)).
• Verify that fall arrest systems are not attached to hoists, except as specified in other subparts of 29 CFR 1926
(29 CFR 1926.502(d)(23)).

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3.8

A personal fall arrest system used at hoist areas must be rigged according to certain
requirements. (29 CFR 1926.502(d)(24))
Guide Note
• When a personal fall arrest system is used at hoist areas, verify that it is rigged to allow the movement of the
employee only as far as the edge of the walking/working surface (29 CFR 1926.502(d)(24)).

3.9

In the event of a fall by an employee, prompt rescue must be executed. (29 CFR
1926.502(d)(20))
Guide Note
• In the event of a fall, verify that the employer provides for the prompt rescue of employees or that employees
are able to rescue themselves (29 CFR 1926.502(d)(20)).

4.

Positioning Device Systems

4.1

Positioning device systems and their use must comply with certain requirements. (29 CFR
1926.502(e)(1) – (e)(5))

.

Guide Note
• Verify that positioning devices are rigged such that an employee cannot free fall more than 2 ft (0.9 m)
(29 CFR 1926.502(e)(1)).
• Inspect the positioning devices to ensure they are secured to an anchorage capable of supporting at least twice
the potential impact load of an employee’s fall or 3,000 lb (13.3 kN), whichever is greater (29 CFR
1926.502(e)(2)).
• Inspect the connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalent
materials (29 CFR 1926.502(e)(3)).
• Inspect the connectors to ensure they have a corrosion-resistant finish and that all surfaces and edges are
smooth to prevent damage to interfacing parts of this system (29 CFR 1926.502(e)(4)).
• Verify that connecting assemblies have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR
1926.502(e)(5)).

4.2

Dee-rings and snaphooks must be properly tested and used. (29 CFR 1926.502(e)(6) – (e)(8))
Guide Note
• Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without
cracking, breaking, or taking permanent deformation (29 CFR 1926.502(e)(6)).
• Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR
1926.502(e)(7)):
– Snaphooks are a compatible size for the member to which they are connected.
– Locking type snaphooks are used.
NOTE: Effective January 1, 1998, only locking type snaphooks may be used.
• Verify that unless the snaphook is a locking type and is designed for the following connections, snaphooks are
not engaged (29 CFR 1926.502(e)(8)):
– directly to webbing, rope, or wire rope;
– to each other;
– to a dee-ring to which another snaphook or other connector is attached;
– to a horizontal lifeline; or
– to any object that is incompatibly shaped or dimensional in relation to the snaphook such that
unintentional disengagement could occur by the connected object depressing the snaphook keeper and
releasing itself.

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4.3

Positioning device systems and components must be inspected under certain conditions.
(29 CFR 1926.502(e)(9))
Guide Note
• Verify that positioning device systems are inspected prior to each use for wear, damage, and other
deterioration and that defective components are removed from service (29 CFR 1926.502(e)(9)).

4.4

Body belts, harnesses, and components must not be used to hoist materials. (29 CFR
1926.502(e)(10))
Guide Note
• Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal
fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(e)(10)).
NOTE: Personal fall arrest systems must have the lanyard attached to a dee-ring at the back to minimize injury
to the wearer. Belts used for fall arrest with side dee-rings are not in compliance and are dangerous to the
wearer. Belts worn with the dee-rings(s) at the side(s) are suitable only as positioning devices. (OSHA
Standard Interpretation, 09/25/95).

5.

Warning Line Systems

5.1

Warning lines around all sides of a roof work area must meet certain requirements. (29 CFR
1926.502(f)(1))

.

Guide Note
• Verify that a warning line is erected around all sides of the roof work area according to the following
requirements (29 CFR 1926.502(f)(1)):
– When mechanical equipment is not being used, the warning line must be erected no less than 6 ft (1.8 m)
from the roof edge.
– When mechanical equipment is being used, the warning line must be erected no less than 6 ft (1.8 m)
from the roof edge that is parallel to the direction of mechanical equipment operation, and not less than
10 ft (3.1 m) from the roof edge that is perpendicular to the direction of mechanical equipment operation.
NOTE: OSHA further defines and clarifies the use of mechanical equipment in its Standard Interpretation,
10/17/00.
– Points of access, materials handling areas, storage areas, and hoisting areas must be connected to the work
area by an access path formed by two warning lines.
– When the path to a point of access is not in use, either of the following must occur so that a person cannot
walk directly into the work area:
1) a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line, must be
placed across the path at the point where the path intersects the warning line; or
2) the path must be offset such that a person cannot walk directly into the work area.

5.2

Warning lines must consist of ropes, wires, or chains, and supporting stanchions, and must be
erected according to certain requirements. (29 CFR 1926.502(f)(2))
Guide Note
• Verify that warning lines consist of ropes, wires, or chains and supporting stanchions and are erected as
follows (29 CFR 1926.502(f)(2)):
– The rope, wire, or chain must be flagged at not more than 6-ft (1.8 m) intervals with high-visibility
material.
– The rope, wire, or chain must be rigged and supported in such a way that its lowest point (including sag)
is no less than 34 inches (0.9 m) from the walking/working surface and its highest point is no more than
39 inches (1.0 m) from the walking/working surface.
– After being erected and with the rope, wire, or chain attached, stanchions must be capable of resisting,
without tipping over, a force of at least 16 lb (71 N) that is applied horizontally against the stanchion and
perpendicular to the warning line, 30 inches (0.8 m) above the walking/working surface in the direction of
the floor, roof, or platform edge.

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–

5.3

The rope, wire, or chain must have a minimum tensile strength of 500 lb (2.22 kN) and, after being
attached to the stanchions, must be capable of supporting, without breaking, the loads applied to the
stanchions as prescribed in 29 CFR 1926.502(f)(2)(iii) (see third dashed point above).
The line must be attached at each stanchion in such a way that pulling on one section of the line between
stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.

Only authorized employees are allowed in the area between a roof edge and a warning line.
(29 CFR 1926.502(f)(3))
Guide Note
• Review procedures to ensure that no employee is allowed in the area between a roof edge and a warning line
unless the employee is performing roofing work in that area (29 CFR 1926.502(f)(3)).

5.4

Employees must be protected from mechanical equipment on roofs. (29 CFR 1926.502(f)(4))
Guide Note
• Verify that mechanical equipment on roofs is used or stored only in areas where employees are protected by a
warning line system, guardrail system, or personal fall arrest system (29 CFR 1926.502(f)(4)).

6.

Controlled Access Zones

6.1

CAZs must de defined where leading edge and other operations are taking place. (29 CFR
1926.502(g)(1))

.

Guide Note
• Verify that when a CAZ is used to control access to areas where leading edge and other operations are taking
place, the CAZ is defined by a control line or by any other means that restricts access (29 CFR
1926.502(g)(1)).
• If control lines are used to control access to areas where leading edge and other operations are taking place,
verify that they are erected according to the following requirements (29 CFR 1926.502(g)(1)):
– Control lines must be erected not less than 6 ft (1.8 m) nor more than 25 ft (7.7 m) from the unprotected
or leading edge, except when erecting precast concrete members.
– When erecting precast concrete members, the control line must be erected either not less than 6 ft (1.8 m)
nor more than 60 ft (18 m) from the leading edge or half the length of the member being erected from the
leading edge, whichever is less.
– The control line must extend along the entire length of the unprotected or leading edge and must be
approximately parallel to the unprotected or leading edge.
– The control line must be connected on each side to a guardrail system or wall.

6.2

CAZs used to control access to areas where overhand bricklaying and related work are taking
place must meet certain requirements. (29 CFR 1926.502(g)(2))
Guide Note
• When CAZs are used to control access to areas where overhand bricklaying and related work are taking place,
verify that the following requirements are met (29 CFR 1926.502(g)(2)):
– The CAZ is defined by a control line erected not less than 10 ft (3.1 m) nor more than 15 ft (4.5 m) from
the working edge.
– The control line extends for a distance sufficient for the CAZ to enclose all employees performing
overhand bricklaying and related work at the working edge and must be approximately parallel to the
working edge.
– Additional control lines are erected at each end to enclose the CAZ.
– Only employees engaged in overhand bricklaying or related work are permitted in the CAZ.

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6.3

Control lines must consist of ropes, wires, tapes, or equivalent materials, and supporting
stanchions, and must meet certain requirements. (29 CFR 1926.502(g)(3))
Guide Note
• Verify that control lines consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions as
follows (29 CFR 1926.502(g)(3)):
– Each line must be flagged or otherwise clearly marked at not more than 6 ft (1.8 m) intervals with highvisibility material.
– Each line must be rigged and supported in such a way that its lowest point (including sag) is not less than
39 inches (1 m) from the walking/working surface and its highest point is not more than 45 inches (1.3 m)
from the walking/working surface.
NOTE: When overhand bricklaying operations are being performed, the line’s highest point must not be
more than 50 inches (1.3 m) from the walking/working surface.
– Each line must have a minimum breaking strength of 200 lb (0.88 kN).

6.4

Floors and roofs in CAZs must be properly constructed for bricklaying operations. (29 CFR
1926.502(g)(4) – (g)(5))
Guide Note
• Verify that on floors and roofs where guardrail systems are not in place prior to the beginning of overhand
bricklaying operations, CAZs are enlarged as necessary to enclose all points of access, material handling areas,
and storage areas (29 CFR 1926.502(g)(4)).
• Verify that on floors and roofs where guardrail systems are in place but need to be removed to allow overhand
bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish
that day’s work is removed (29 CFR 1926.502(g)(5)).

7.

Safety Monitoring Systems

7.1

Safety monitoring systems must meet certain requirements. (29 CFR 1926.502(h))

.

Guide Note
• Interview employees to verify that the employer designates a competent person to monitor the safety of other
employees and that the employer ensures that the safety monitor complies with all of the following
requirements (29 CFR 1926.502(h)(1)):
– The safety monitor must be competent to recognize fall hazards.
– The safety monitor must warn the employee when it appears that the employee is unaware of a fall hazard
or is acting in an unsafe manner.
– The safety monitor must be on the same walking/working surface and within visual sighting distance of
the employee being monitored.
– The safety monitor must be close enough to communicate orally with the employee.
– The safety monitor must not have other responsibilities that could take the monitor’s attention from the
monitoring function.
• Verify that mechanical equipment is not used or stored in areas where safety monitoring systems are being
used to monitor employees engaged in roofing operations on low-slope roofs (29 CFR 1926.502(h)(2)).
• Review employee work practices to verify that no employee, other than an employee engaged in roofing work
on low-sloped roofs or an employee covered by a fall protection plan, is allowed in an area where an employee
is being protected by a safety monitoring system (29 CFR 1926.502(h)(3)).
• Verify that each employee working in a CAZ is directed to comply promptly with fall hazard warnings from
safety monitors (29 CFR 1926.502(h)(4)).

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8.

Covers

8.1

Covers for holes must meet certain requirements. (29 CFR 1926.502(i))

.

Guide Note
• Verify that covers located in roadways and vehicular aisles are capable of supporting, without failure, at least
twice the maximum axle load of the largest vehicle expected to cross over the cover (29 CFR 1926.502(i)(1)).
• Verify that all other covers are capable of supporting, without failure, at least twice the weight of employees,
equipment, and materials that may be imposed on the cover at any one time (29 CFR 1926.502(i)(2)).
• Verify that all covers are secured when installed to prevent accidental displacement by the wind, equipment, or
employees (29 CFR 1926.502(i)(3)).
• Verify that all covers are color coded, or that they are marked with the word “Hole” or “Cover” to provide
warning of the hazard (29 CFR 1926.502(i)(4)).
NOTE: This provision does not apply to cast iron manhole covers or steel grates used on streets or roadways.

9.

Protection from Falling Objects

.

NOTE: Additional provisions for protection from falling objects are found in 29 CFR
1926.501(c) (see paragraph 1.17 above)
9.1

Toeboards, when used as falling object protection, must meet certain requirements. (29 CFR
1926.502(j)(1) – (j)(4))
Guide Note
• Verify that toeboards, when used as falling object protection, are erected along the edge of the overhead
walking/working surface for a distance sufficient to protect employees below (29 CFR 1926.502(j)(1)).
• Verify that toeboards are capable of withstanding, without failure, a force of at least 50 lb (222 N) applied in
any downward or outward direction at any point along the toeboard (29 CFR 1926.502(j)(2)).
• Inspect the toeboards to ensure they meet the following requirements (29 CFR 1926.502(j)(3)):
– They are a minimum of 3½ inches (9 cm) in vertical height from their top edge to the edge of the
walking/working surface.
– They are no more than ¼ inch (0.6 cm) clearance above the walking/working surface.
– They are solid or have openings no greater than 1 inch (2.5 cm) in any dimension.
• Where tools, equipment, or materials are piled higher than the top edge of a toeboard, verify that paneling or
screening is erected from the walking/working surface or toeboard to the top of a guardrail system’s top rail or
midrail, for a distance sufficient to protect employees below (29 CFR 1926.502(j)(4)).

9.2

Guard rail systems, when used as falling object protection, must meet certain requirements.
(29 CFR 1926.502(j)(5))
Guide Note
• Verify that guardrail systems, when used as falling object protection, have all openings small enough to
prevent passage of potential falling objects (29 CFR 1926.502(j)(5)).

9.3

Certain requirements must be met during the performance of bricklaying and related work.
(29 CFR 1926.502(j)(6))
Guide Note
• Verify that no equipment except masonry and mortar are stored within 4 ft (1.2 m) of the working edge
(29 CFR 1926.502(j)(6)(i)).
• Verify that excess mortar, broken or scattered masonry units, and all other materials and debris are removed
from the work area at regular intervals (29 CFR 1926.502(j)(6)(ii)).

COA 3/12 ©STP

FL/Part 3 - 15
Fall Protection Rulebook
9.4

Certain requirements must be met during the performance of roofing work. (29 CFR
1926.502(j)(7))
Guide Note
• Verify that equipment and materials are not stored within 6 ft (1.8 m) of a roof edge unless guardrails are
erected at the edge (29 CFR 1926.502(j)(7)(i)).
• Verify that piled, grouped, or stacked materials near a roof are stable and self-supporting (29 CFR
1926.502(j)(7)(ii)).

9.5

Canopies used as falling object protection must meet certain requirements. (29 CFR
1926.502(j)(8))
Guide Note
• Verify that canopies, when used as falling object protection, are strong enough to prevent collapse and to
prevent penetration by any objects that may fall onto the canopy (29 CFR 1926.502(j)(8)).

10.

Fall Protection Plans

.

10.1 Fall protection plans must meet certain requirements. (29 CFR 1926.502(k))
Guide Note
NOTE: The option for using a fall protection plan is available only to employees engaged in leading edge
work, precast concrete erection work, or residential construction work who can demonstrate that it is infeasible
or it creates a greater hazard to use conventional fall protection equipment (29 CFR 1926.502(k)).
• Verify that the fall protection plan is prepared by a qualified person and developed specifically for the site
where the work is being performed and that the plan is maintained up-to-date. Any changes to the fall
protection plan must be approved by a qualified person (29 CFR 1926.502(k)(1) – (k)(2)).
• Verify that a copy of the fall protection plan with all approved changes is maintained at the job site (29 CFR
1926.502(k)(3)).
• Verify that the implementation of the fall protection plan is under the supervision of a competent person
(29 CFR 1926.502(k)(4)).
• Verify that the fall protection plan documents the reasons why the use of conventional fall protection systems
(guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would
create a greater hazard (29 CFR 1926.502(k)(5)).
• Review the fall protection plan to ensure it includes a written discussion of other measures that will be taken
to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the
conventional fall protection systems (29 CFR 1926.502(k)(6)).
• Review the fall protection plan to ensure it identifies each location where conventional fall protection methods
cannot be used. These locations must then be classified as CAZs and the employer must comply with the
criteria in 29 CFR 1926.502(g) (see section 6 above) (29 CFR 1926.502(k)(7)).
• Verify that where no other alternative measure has been implemented, the employer implements a safety
monitoring system in conformance with 29 CFR 1926.502(h) (see paragraph 7.1 above) (29 CFR
1926.502(k)(8)).
• Verify that the fall protection plan includes a statement that provides the name or other method of
identification for each employee who is designated to work in CAZs. No other employees may enter CAZs
(29 CFR 1926.502(k)(9)).
• If an employee falls or some other related, serious incident occurs (e.g., a near miss), verify that the employer
investigates the circumstances of the incident to determine if the fall protection plan needs to be changed (e.g.,
by new practices, procedures, or training) and implements those changes to prevent similar types of falls or
incidents (29 CFR 1926.502(k)(10)).

FL/Part 3 - 16

COA 3/12 ©STP
OSHA Construction Safety Guide
OSHA Construction Safety Guide
OSHA Construction Safety Guide
OSHA Construction Safety Guide
OSHA Construction Safety Guide
OSHA Construction Safety Guide
OSHA Construction Safety Guide
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OSHA Construction Safety Guide

  • 1. Sample OSHA Auditing: Federal Compliance: Construction: The Complete Safety and Health Audit Checklist www.stpub.com
  • 2. OSHA Auditing: Federal Compliance Guide – Construction © STP
  • 3. OSHA Auditing: Federal Compliance Guide – Construction A tool for assessing a facility’s compliance with the Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1926 and the general recordkeeping requirements of 29 CFR 1904 © STP
  • 4. Users of This Guide Include • General construction and demolition contractors • Specialty construction contractors and developers • Construction and state inspectors • Engineering consultants • Utility and larger corporations • And many more… © STP
  • 5. Features of This Guide • Field-tested by recognized experts • Helps ensure compliance • Helps avoid citations and fines • Allows experienced auditors to expedite their assessment • Allows less experienced auditors to review detailed instructions © STP
  • 6. Features of This Guide • Saves time and reduces compliance and audit costs • Demonstrates due diligence • Customizable to site-specific requirements • Applicability Tables • Pre-audit Preparation • Rulebooks • Scoresheets © STP
  • 7. Comprehensive Topic Areas • General safety and health • General recordkeeping and posting • Occupational exposures and environmental controls • Hazardous waste operations and emergency response • Process safety • Personal protective and life saving equipment © STP
  • 8. Comprehensive Topic Areas • Fire protection and prevention • Signs, signals and barricades • Materials handling • Hand and power tools • Welding and cutting • Electrical • Scaffolds • Fall protection • Demolition © STP
  • 9. Features – Applicability Tables Use multi-level questions to quickly determine which regulations and sections of the rulebooks apply to specific facilities or operations © STP
  • 10. Sample Applicability Table BLASTING AND USE OF EXPLOSIVES. . PART 1: INTRODUCTION Applicability of This Module Use the following General Applicability Checklist to determine whether a rulebook and its sections apply to your operation. If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for a rulebook exemption. Once you determine that the rulebook does apply to your operation, you must answer the section questions. If a section question does not exist, then that section applies if the rulebook applies. If you answer YES to a section question, that section applies to you unless you answer YES for an exemption from that section. If you answer YES to a rulebook or section exemption, then the rulebook or section does not apply. . . . . Applies . Exempt . GENERAL APPLICABILITY CHECKLIST . . . . Rulebook: Blasting and Use of Explosives . . RULEBOOK: Do you handle, transport, use, or store explosives in construction activities? Y N q q Y N q q Y N q q Y N q q Y N q q . .............................................................................................................................................................................................................................................................. Section 2: Do you have employees who are blasters? ........................... ........................... . . .............................................................................................................................................................................................................................................................. Section 3: Do your operations involve surface transportation of explosives? ........................... ........................... . . .............................................................................................................................................................................................................................................................. Section 4: Do your operations involve underground transportation of explosives? ........................... ........................... . . .............................................................................................................................................................................................................................................................. Section 5: Do your operations include storage of explosives or blasting agents at construction sites? . ........................... ........................... . .............................................................................................................................................................................................................................................................. Section 6: Do your operations include loading or preparing explosive or blasting agents for use? . ........................... Y q ........................... N q . .............................................................................................................................................................................................................................................................. Section 7: Do your operations include initiating explosives charges with electricity? ........................... Y q q Y N q q Y N q ........................... N q . . .............................................................................................................................................................................................................................................................. Section 8: Do your operations include initiating explosives charges with safety fuse? ........................... ........................... . . .............................................................................................................................................................................................................................................................. Section 9: Do your operations include initiating explosives charges with detonating cord? ........................... ........................... . . © STP
  • 11. Features – Pre-audit Preparation Lists materials to be reviewed or prepared before conducting an audit © STP
  • 12. Sample Pre-audit Preparation . SCAFFOLDS. . PART 2: PRE–AUDIT PREPARATION. . Items to consider getting in advance: • Access to the information in 29 CFR 1926 Subpart L. • Access to the information in OSHA Directive CPL 02-01-023, “Inspection Procedures for Enforcing Subpart L, Scaffolds Used in Construction,” available online at www.osha.gov/pls /oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1528. OSHA has also adopted the following third party standards. We have listed the standards that are cited in the regulations. We have provided contact information for each of the referenced third parties in the appendix to the general introduction (located at the beginning of this manual). • The following standards of the American National Standard Institute (ANSI) and the Scaffolding Industry Association (SIA) (as provided in Appendix C to Subpart L): – ANSI/SIA A92.2-1990, “Vehicle Mounted Elevating and Rotating Aerial Devices,” including Appendix. – ANSI/SIA A92.3-1990, “Manually Propelled Elevating Aerial Platforms.” – ANSI/SIA A92.5-1992, “Boom-Supported Elevating Work Platforms.” – ANSI/SIA A92.6-1990, “Self-Propelled Elevating Work Platforms.” – ANSI/SIA A92.7-1990, “Airline Ground Support Vehicle-Mounted Vertical Lift Devices.” – ANSI/SIA A92.8-1993, “Vehicle-Mounted Bridge Inspection and Maintenance Devices.” – ANSI A92.9-1993, “Mast-Climbing Work Platforms.” (Note: This Standard is not currently available.) • The following Standards of the American Welding Society (AWS): – AWS B3.0-41, “Welding Procedure and Performance Qualification.” – AWS D8.4-61, “Recommended Practices for Automotive Welding Design.” (Note: This Standard has been withdrawn and has not been replaced.) – AWS D10.9-69, “Standard Qualification of Welding Procedures and Welders for Piping and Tubing.” – AWS D2.0-69, “Specifications for Welding Highway and Railway Bridges.” (Note: This Standard is not currently available.) © STP
  • 13. Features – Rulebooks Provide a comprehensive set of regulatory requirement statements, plus detailed guidance on compliance issues and inspection procedures © STP
  • 14. Sample Rulebook . SCAFFOLDS. . PART 3: RULEBOOK The requirements of this rulebook do not apply to crane or derrick suspended personnel platforms. The criteria for aerial lifts are set out exclusively in 29 CFR 1926.453 (see section 34). All dimensions are nominal sizes as provided in the American Lumber Standards, except that where rough sizes are noted, only rough or undressed lumber of the size specified will satisfy minimum requirements. NOTE: OSHA has determined that standing on the guardrails of lifting equipment such as aerial lifts or scissor lifts is not a suitable substitute for the use of scaffolding, even if the employee is wearing fall protection. There may be specific prohibitions in some regulations, but even in the absence of such regulations, the guardrails would have to meet all requirements for scaffolding, including load requirements, and it is unlikely that these could be met (OSHA Interpretation Letter, 10/23/02). 1. Scaffold Capacity 1.1 Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a)) . Guide Note • Review the design of each scaffold and scaffold component to ensure it is capable of supporting, without failure, its own weight and at least four times the maximum intended load applied or transmitted to it, except as provided in 29 CFR 1926.451(a)(2) – (a)(5) and (g) (see section 7) (29 CFR 1926.451(a)(1)). • Review the design to verify that direct connections to roofs and floors, and counterweights used to balance adjustable suspension scaffolds are capable of resisting at least four times the tipping moment (the tendency to cause a tip) imposed by the scaffold operating at the rated load of the hoist, or at least 1.5 times the tipping moment imposed by the scaffold operating at the stall load of the hoist, whichever is greater (29 CFR 1926.451(a)(2)). • Verify that each suspension rope, including connecting hardware, used on nonadjustable suspension scaffolds is capable of supporting, without failure, at least six times the maximum intended load applied or transmitted to that rope (29 CFR 1926.451(a)(3)). • Verify that each suspension rope, including connecting hardware, used on adjustable suspension scaffolds is capable of supporting, without failure, at least six times the maximum intended load applied or transmitted to that rope with the scaffold operating at either the rated load of the hoist, or at least two times the stall load of the hoist, whichever is greater (29 CFR 1926.451(a)(4)). • Ensure that the stall load of any scaffold hoist does not exceed three times its rated load (29 CFR 1926.451(a)(5)). • Ensure that all scaffolds are designed by a qualified person and are constructed and loaded in accordance with that design (see Key Compliance Definitions in the Introduction to this module for the definition of a “qualified person”) (29 CFR 1926.451(a)(6)). NOTE: Non-mandatory Appendix A of this Subpart contains examples of construction, loading, and design criteria for scaffolds. © STP
  • 15. Features – Scoresheets Enable quick recording of a facility’s compliance status for each requirement Scoresheets are customizable © STP
  • 16. Sample Scoresheet . SCAFFOLDS. . PART 4: SCORESHEET SITE: DATE: 1. Scaffold Capacity N/A Complies Does not comply 1.1 Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a)) q q q 2. Scaffold Platform Construction N/A Complies Does not comply 2.1 Scaffold platforms must be fully planked or decked according to specific requirements. (29 CFR 1926.451(b)(1)) q q q 2.2 Scaffold platforms and walkways must be a certain width. (29 CFR 1926.451(b)(2)) q q q 2.3 The front edge and ends of platforms must be certain distances from the work and from their supports. (29 CFR 1926.451(b)(3) – (b)(5)) q q q 2.4 Certain requirements must be met on scaffolds where planks are abutted and where platforms are overlapped. (29 CFR 1926.451(b)(6) – (b)(7)) q q q 2.5 Scaffold platforms that change direction must meet certain requirements. (29 CFR 1926.451(b)(8)) q q q 2.6 The coating used on wood platforms must be in accordance with specific requirements. (29 CFR 1926.451(b)(9)) q q q 2.7 Different scaffold components may be used only under certain circumstances. (29 CFR 1926.451(b)(10) – (b)(11)) q q q 3. Supported Scaffolds N/A Complies Does not comply 3.1 Supported scaffolds must meet certain criteria. (29 CFR 1926.451(c)) q q q 4. Suspension Scaffolds N/A Complies Does not comply 4.1 Resting surfaces for suspension scaffold support devices must meet certain requirements. (29 CFR 1926.451(d)(1)) q q q . . . . . . . . . . . . . . . . . . . . © STP
  • 17. Formats • Online single-user • Online multi-user • Loose-leaf • CD • Loose-leaf & CD • Multi-user through risk management systems © STP
  • 18. Up to 4 updates per year Sample Release Notes OSHA Auditing: FederAl COmpliAnCe guide: COnStruCtiOn Release #158 July 2012 new And nOtewOrtHy • The Occupational Health and Safety Administration (OSHA) has issued a direct final rule that modifies the requirements for head protection contained in 29 CFR 1926.100(b). This change removes the 1969 edition of ANSI Z89.1 “Safety Requirements for Industrial Head Protection,” and allows compliance with the 1997, 2003, or 2009 editions of the ANSI Standard. This rule will become effective on September 20, 2012. HigHligHtS OF tHiS releASe • Personal Protective and Life Saving Equipment (Module E) Rulebook section 3 has been updated to reflect the OSHA change indicated in “New and Noteworthy” above. • All sections of this Guide are being reviewed to ensure that the supplemental information which is included to assist customers in applying regulations is current, relevant, and clearly worded. Towards this end, the notes in the rulebooks that refer the user to OSHA Letters of Interpretation and Compliance Directives are being edited. Modules are also being edited to improve the clarity of the information they contain, the wording of the cross-references for users of paper editions of the publication, and the linking function for users of electronic versions. © STP
  • 19. Please enjoy this sample of OSHA Auditing: Federal Compliance Guide – Construction © STP
  • 20. FALL PROTECTION. . PART 1: INTRODUCTION Applicability of This Module Use the following General Applicability Checklist to determine whether a rulebook and its sections apply to your operation. If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for a rulebook exemption. Once you determine that the rulebook does apply to your operation, you must answer the section questions. If a section question does not exist, then that section applies if the rulebook applies. If you answer YES to a section question, that section applies to you unless you answer YES for an exemption from that section. If you answer YES to a rulebook or section exemption, then the rulebook or section does not apply. . GENERAL APPLICABILITY CHECKLIST . . . Applies . Exempt . . . . . Rulebook: Fall Protection . . RULEBOOK: Do you have situations at your construction site where employees may be exposed to a significant fall? RULEBOOK Exemption: Do you meet any of the following exceptions: • employees making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed; • employees work on scaffolds (see Scaffolds (Module M) Applicability Checklist); • employees work on certain cranes and derricks (see Cranes and Derricks in Construction (Module CC) Applicability Checklist); • employees perform steel erection work (except towers and tanks) (see Steel Erection (Module R) Applicability Checklist); • employees work on certain types of equipment used in tunneling operations (see Underground Construction (Module S) Applicability Checklist); • employees are engaged in the erection of tanks and communication and broadcast towers (see Personal Protective and Life Saving Equipment (Module E) Applicability Checklist); • employees are engaged in construction of electric transmission and distribution lines and equipment (see Power Transmission and Distribution (Module V) Applicability Checklist); or • employees work on stairways and ladders (see Stairways and Ladders (Module X) Applicability Checklist)? . . .............................................................................................................................................................................................................................................................. Section 3: Do you utilize personal fall arrest systems for fall protection? Y N q q Y ........................... Y q Y q Y N q q Y N q q ........................... N q q N q N q . . .............................................................................................................................................................................................................................................................. Section 4: Do you utilize positioning systems for fall protection? ........................... ........................... . . .............................................................................................................................................................................................................................................................. Section 5: Do you conduct roof work requiring the use of warning lines around roofs for fall protection? . . .............................................................................................................................................................................................................................................................. Section 6: Do you utilize a controlled access zone as part of your fall protection system? ........................... ........................... ........................... ........................... . . .............................................................................................................................................................................................................................................................. COA 3/12 ©STP ........................... ........................... FL/Part 1 - 1
  • 21. Fall Protection Introduction . GENERAL APPLICABILITY CHECKLIST . . Applies Exempt . . . . Section 7: Do your construction activities involve the use of safety monitoring systems for fall protection? . . NOTE: Employees engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels must be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system. Or, on roofs 50 feet (15.25 m) or less in width (see 29 CFR 1926 Subpart M Appendix A), the use of a safety monitoring system alone (i.e. without the warning line system) is permitted (29 CFR 1926.510(b)(10)). .............................................................................................................................................................................................................................................................. Section 8: Do your construction activities involve the use of covers on holes located in roadways or vehicle aisles? . . .............................................................................................................................................................................................................................................................. Section 9: Do your construction activities require the use of protection from falling objects? . Y q . N q ........................... Y q q Y N q ........................... N q ........................... ........................... . . . FL/Part 1 - 2 COA 3/12 ©STP
  • 22. Fall Protection Introduction Regulatory Summary This module covers fall protection regulations found in 29 CFR 1926 Subpart M, which includes 29 CFR 1926.500 – 1926.503 and 29 CFR 1926 Appendix A – Appendix E. The federal regulations that apply are organized into the following major sections: • 29 CFR 1926.500 Scope, Application, and Definitions • 29 CFR 1926.501 Duty to Have Fall Protection • 29 CFR 1926.502 Fall Protection Systems Criteria and Practices • 29 CFR 1926.503 Training Requirements The following non-mandatory appendices to 29 CFR 1926 Subpart M serve as guidelines to assist employers in complying with the appropriate requirements of this subpart: • 29 CFR 1926 Appendix A, “Determining Roof Widths – Non-Mandatory Guidelines for Complying with 29 CFR 1926.501(b)(10),” provides illustrations of roof plans and indicates where each roof or roof area is to be measured to determine its width for fall protection purposes. • 29 CFR 1926 Appendix B, “Guardrail Systems – Non-Mandatory Guidelines for Complying with 29 CFR 1926.502(b),” serves as a guideline and starting point to assist employers who are designing guardrail systems. • 29 CFR 1926 Appendix C, “Personal Fall Arrest Systems – Non-Mandatory Guidelines for Complying with 29 CFR 1926.502(d),” provides test methods and other guidelines for personal fall arrest systems and positioning device systems. Guidelines for positioning device systems are also covered in 29 CFR 1926 Appendix D. • 29 CFR 1926 Appendix D, “Positioning Device Systems – Non-Mandatory Guidelines for Complying with 29 CFR 1926.502(e),” provides testing methods and inspection considerations for positioning device systems. • 29 CFR 1926 Appendix E, “Sample Fall Protection Plan – Non-Mandatory Guidelines for Complying with 29 CFR 1926.502(k),” provides sample fall protection plans for precast/prestressed concrete structures, residential construction, and leading edge work. These federal regulations address fall protection requirements in construction work in states that follow the federal Occupational Safety and Health Administration (OSHA) program and in states that have their own programs but have adopted the federal regulations. They also apply to federal employees and any construction work performed on federally owned property, no matter where it occurs. Some states and local agencies impose requirements in addition to those listed in this module. Since employers must meet all applicable requirements, it is important to review regulations at the state and local level as well. OSHA frequently adopts third party standards by incorporating them by reference into the regulations. These standards are provided by other governmental, non-profit, or trade organizations (such as the American National Standards Institute [ANSI]). Many of these third party standards have been revised since they were first incorporated into the regulations; however, because OSHA frequently has not adopted the updates, it typically cannot enforce the requirements contained in the most recent version of the standard (unless imminent danger is present). Throughout this module, we refer to the third party standards that are cited in the regulations, even though in many cases these standards have been revised, replaced, and/or deleted. We have provided contact information for each of the referenced third party standards so that you can obtain the most recent information. COA 3/12 ©STP FL/Part 1 - 3
  • 23. Fall Protection Introduction Key Compliance Definitions The following definitions are derived from 29 CFR 1926.500(b) unless otherwise noted. The definitions of some general terms discussed in this module may be found in module C, “General Safety and Health.” Anchorage – A secure point of attachment for lifelines, lanyards, or deceleration devices. Body belt (Safety belt) – A strap with means both for securing it about the waist and for attaching it to a lanyard, lifeline, or deceleration device. Body harness – Straps that, when secured about the employee, will distribute the fall arrest forces over at least the thighs, pelvis, waist, chest, and shoulders and that have means for attaching the harness to other components of a personal fall arrest system. NOTE: This definition does not require nor does it exclude the use of a waist or chest strap as part of a full body harness, as long as the harness properly distributes the fall arrest forces (OSHA Interpretation and Compliance Letter 09/23/1999). Buckle – Any device for holding the body belt or body harness closed around the employee’s body. Connector – A device that is used to couple (connect) parts of the personal fall arrest system and positioning device systems together. A connector may be an independent component of the system (such as a carabiner) or it may be an integral component of part of the system (such as a buckle or dee-ring sewn into a body belt or body harness, or a snap-hook spliced or sewn to a lanyard or selfretracting lanyard). Controlled access zone (CAZ) – An area to which access is controlled and in which certain work (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems. Dangerous equipment – Equipment (such as pickling or galvanizing tanks, degreasing units, machinery, electrical equipment, and other units) that, because of form or function, may be hazardous to employees who fall onto or into such equipment. Deceleration device – Any mechanism that serves to dissipate a substantial amount of energy during a fall arrest or otherwise limit the energy imposed on an employee during fall arrest. Deceleration devices include but are not limited to rope grabs, rip-stitch lanyards, specially woven lanyards, tearing or deforming lanyards, and automatic self-retracting lifelines/lanyards. Deceleration distance – The vertical distance a falling employee travels before stopping, excluding lifeline elongation and free fall distance, from the point at which the deceleration device begins to operate. Deceleration distance is measured as the distance between the location of an employee’s body belt or body harness attachment point at the moment of activation (at the onset of fall arrest forces) of the deceleration device during a fall, and the location of that attachment point after the employee comes to a full stop. Equivalent – Alternative designs, materials, or methods that protect against a hazard and that the employer can demonstrate will provide an equal or greater degree of safety for employees than the methods, materials, or designs specified in the standard. FL/Part 1 - 4 COA 3/12 ©STP
  • 24. Fall Protection Introduction Failure – The occurrence of load refusal, breakage, or separation of component parts. (Load refusal is the point where the structural members lose their ability to carry the load.) Free fall – The act of falling before a personal fall arrest system begins to apply force to arrest the fall. Free fall distance – The vertical displacement of the fall arrest attachment point on the employee’s body belt or body harness between onset of the fall and the time that the system begins to apply force to arrest the fall. This distance excludes deceleration distance and lifeline/lanyard elongation, but includes any deceleration device slide distance or self-retracting lifeline/lanyard extension that occurs before the fall arrest forces begin. Guardrail system – A barrier erected to prevent employees from falling to lower levels. Hole – A gap or void that is 2 inches (5.1 cm) or more in its least dimension and that is located in a floor, roof, or other walking/working surface. Infeasible – Impossible to perform the construction work using a conventional fall protection system (i.e., guardrail system, safety net system, or personal fall arrest system) or technologically impossible to use any conventional fall protection system to provide fall protection. Lanyard – A flexible rope, wire rope, or strap that generally has a connector at each end for connecting the body belt or body harness to a deceleration device, lifeline, or anchorage. Leading edge – The edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) that changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered an unprotected side and edge during periods when it is not actively and continuously under construction. Lifeline – A flexible line that connects either to an anchorage at one end to hang vertically (vertical lifeline) or anchorages at both ends to stretch horizontally (horizontal lifeline), and that serves to connect other components of a personal fall arrest system to the anchorage. Low-slope roof – A roof with a slope less than or equal to 4 to 12 (vertical to horizontal). Lower levels – Those areas or surfaces to which an employee can fall. Such areas or surfaces include, but are not limited, to ground levels, floors, platforms, ramps, runways, excavations, pits, tanks, material, water, equipment, structures, or portions thereof. Mechanical equipment – All motor or human propelled wheeled equipment used for roofing work, except wheelbarrows and mopcarts. Opening – A gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide that is located in a wall or partition through which employees can fall to a lower level. Overhand bricklaying and related work – The process of laying bricks and masonry units such that the surface of the wall to be jointed is on the opposite side of the wall from the mason, requiring the mason to lean over the wall to complete the work. Related work includes mason tending and electrical installation incorporated into the brick wall during the overhand bricklaying process. COA 3/12 ©STP FL/Part 1 - 5
  • 25. Fall Protection Introduction Personal fall arrest system – A system used to arrest an employee in a fall from a working level. Personal fall arrest systems consist of an anchorage, connectors, and a body belt or body harness and may include a lanyard, deceleration device, lifeline, or suitable combinations of these. As of January 1, 1998, the use of a body belt for fall arrest is prohibited. Positioning device system – A body belt or body harness system rigged to allow an employee to be supported on an elevated vertical surface, such as a wall, and work with both hands free while leaning. Roof – The exterior surface on the top of a building. The term roof does not include floors or formwork that, because a building has not been completed, temporarily become the top surface of a building. Roofing work – The hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. Rope grab – A deceleration device that travels on a lifeline and automatically, by friction, engages the lifeline and locks to arrest the fall of an employee. A rope grab usually employs the principle of inertial locking, cam/level locking, or both. Safety belt – See Body belt above. Safety-monitoring system – A safety system in which a competent person is responsible for recognizing and warning employees of fall hazards. Self-retracting lifeline/lanyard – A deceleration device containing a drum-wound line that can be slowly extracted from, or retracted onto, the drum under slight tension during normal employee movement, and that, after onset of a fall, automatically locks the drum and arrests the fall. Snaphook – A connector comprised of a hook-shaped member with a normally closed keeper, or similar arrangement, that may be opened to permit the hook to receive an object and, when released, automatically closes to retain the object. Snaphooks are generally one of two types: • the locking type, with a self-closing, self-locking keeper that remains closed and locked until unlocked and pressed open for connection or disconnection; or • the non-locking type, with a self-closing keeper that remains closed until pressed open for connection or disconnection. NOTE: As of January 1, 1998, the use of a non-locking snaphook as part of personal fall arrest systems and positioning device systems is prohibited. Steep roof – A roof having a slope greater than 4 to 12 (vertical to horizontal). Toeboard – A low protective barrier that will prevent the fall of materials and equipment to lower levels and provide protection from falls for personnel. Unprotected sides and edges – Any side or edge (except at entrances to points of access) of a walking/working surface (e.g., a floor, roof, ramp, or runway) where there is no wall or guardrail system at least 39 inches (1.0 m) high. FL/Part 1 - 6 COA 3/12 ©STP
  • 26. Fall Protection Introduction Walking/working surface – Any surface, whether horizontal or vertical, on which an employee walks or works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concrete reinforcing steel, but not including ladders, vehicles, or trailers on which employees must be located in order to perform their job duties. Warning line system – A barrier erected on a roof that warns employees that they are approaching an unprotected roof side or edge and that designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. Work area – That portion of a walking/working surface where job duties are being performed. COA 3/12 ©STP FL/Part 1 - 7
  • 27. Fall Protection Introduction Appendices Appendix 1: OSHA Compliance Letters OSHA’S Enforcement Policy - Residential Construction OSHA’s Standard Interpretation, 05/25/00, contains a memorandum from the Director, Directorate of Construction clarifying a number of questions regarding residential construction. (See also OSHA’s related Standard Interpretation, 08/10/00.) Q1: Is apartment construction considered residential construction? Only if the apartment complex is constructed using the same materials and methods as are traditionally used for wood framed single-family houses and townhouses (i.e., raising stick framed walls, installing wood trusses and floor joists, etc.) would its construction be considered residential. An apartment constructed with precast concrete floors, structural steel, or other materials that are not traditionally used in stick frame home construction would not be considered residential construction and would be beyond the scope of STD 3-0.1A. Q2: If residential construction materials and techniques are used for something other than a residence, is the project considered residential construction? (Example: It looks like a house but will be used as a dentist’s office.) Yes. Note the answer to the next question. Q3: Can you clarify the definition of residential construction? This was a common request prior to the issuance of STD 3-0.1A. Section VIII of the new plain language directive more thoroughly depicts what would constitute residential construction. It states that where the working environment, materials, methods, and procedures are essentially the same as those used in building a typical single-family home or townhouse, the employer would be considered engaged in residential construction. Wood framing (not steel or concrete), wooden floor joists and roof structures are characteristic of the materials used, and traditional wood frame construction techniques are the methods used in residential construction. OSHA also recognizes metal studs as one for one substitutions for the 2X4 wooden studs used in modern residential construction. Structures that use metal studs are considered residential construction if they meet the other criteria for residential construction. Q4: How do the appendices for the fall protection standard relate to residential construction? The appendices are non-mandatory — there is no requirement that they be followed. However, in specified circumstances, an employer that follows them will be considered to be in compliance with the standard. When a residential contractor can demonstrate that conventional fall protection either is infeasible or creates a greater hazard, section 1926.501(b)(13) permits the use of a fall protection plan, as outlined in 1926.502(k). Appendix E provides sample fall protection plans that contain the required elements. FL/Part 1 - 8 COA 3/12 ©STP
  • 28. Fall Protection Introduction Q5: What are the spacing requirements for slide guards on roofs? The spacing requirements are listed in STD 3-0.1A, Section D. “Alternative Procedures for Group 1 and Section G. – Alternative procedures for Group 4.” If an employer elects to follow STD 3-0.1A, or is operating under the Roof Sheathing Operations section of Appendix E (59 FR 40753), it must follow the spacing requirements in the Directive or the Appendix (they are the same). For a full explanation of these guidelines, refer to the June 18, 1999 directive. Q6: If the slide guards are not properly spaced, what should we cite? If an employer (engaged in residential construction) does not provide conventional fall protection, the compliance officer must determine if STD 3-0.1A provides alternative procedures for the activity in question. If alternative procedures are available, the compliance officer must then determine whether they have been properly implemented. If they have not, cite 1926.501(b)(13). No other provision may be cited for a fall hazard addressed by .501(b)(13). Deficiencies in training required by 1926.20 may be cited where appropriate. Q7: What fall protection is required when trusses and rafters are being placed? For employers operating under STD 3-0.1A (or Appendix E), the procedures are listed in STD 30.1A, Section VIII, paragraph D. Q8: In light of the fact that devices (such as the “Truss-T”) have been developed, can residential construction employers still claim that it is infeasible or creates a greater hazard to use conventional fall protection equipment when performing this work? Will we continue to allow employees to walk the walls, trusses, etc. without conventional fall protection equipment? As long as STD 3-0.1A is in effect, employers may use the alternative procedures in the Directive for the specified operations without showing that conventional fall protection is infeasible. The issue of whether this policy should continue is being examined through the Advanced Notice of Proposed Rulemaking (ANPR) for subpart M. The ANPR sought public comment on many of the questions you have asked. COA 3/12 ©STP FL/Part 1 - 9
  • 29. Fall Protection Introduction Appendix 2: Suggestions for Fall Protection During Installation of Roof Framing, Trusses, and Components OSHA Standard Interpretation, 08/03/99, offers employers the following control suggestions to protect employees during residential construction and installation of roof framing, trusses, and components. Additional information for residential construction may be found in the OSHA Directive, STD 30.1A, “Plain Language Revision of OSHA Instruction STD 3.1, Interim Fall Protection Compliance Guidelines for Residential Construction” (effective June 18, 1999). (NOTE: STD 3-0.1A replaced STD 3.1, “Interim Fall Protection Compliance Policy For Certain Residential Construction Activities,” published December 8, 1995.) One method is to assemble the roof as a unit on the ground and then raise it by crane. Another method involves the use of both roof anchors (permanent as well as removable anchors are available) and reusable truss braces. The reusable truss braces allow the trusses to be braced without being on them. In this type of system, one end of the device is attached to the truss on the ground; the other end has a rope attached to it. The truss is then erected either by crane or manually. Two methods are commonly used to erect them manually. In both approaches workers at either end of the truss work from ladders or platforms. In one approach the workers directly lift and place the truss on the top plates. In the other approach, the truss is first placed upside down between the exterior walls. The workers then rotate it up into place on the top plates. In either case, one or more roof anchors are also attached to one or more strategically located trusses before those trusses are erected. Once the truss is raised, a worker on the floor level pulls the rope that is attached to the other end of the brace, which brings that end of the brace down onto the adjoining truss. At that point the brace is locked onto both trusses. The process is repeated as each truss is erected. Depending on the size of the truss, two or more braces are used per truss. With all the braces locked in place, the trusses can now be sheathed. The initial courses of sheathing, beginning at the eaves, are installed by workers who are on the inside of the structure on platforms. They remove the braces one at a time, as each sheet of sheathing is installed. Some employers will install all but the last (top) course from platforms on the inside. The last course is then sheathed by workers on the roof who are tied-off to the previously installed roof anchor(s). Others install added (wood) bracing sufficient to support a roof anchor so that the almost all of the sheathing courses can be installed by workers on the roof while tied-off. Once the sheathing is done, the weatherproofing material and roof-mounted equipment can be installed with workers tied-off to the previously installed roof anchor(s). There are a number of different types of roof anchors available for use during sheathing. Many are made of metal and attach by screws or nails to a truss or framing members. Another type is comprised of a D-ring attached to a fabric strap. The strap is nailed to and wrapped around one or more roof trusses. The anchor is removed by cutting the D-ring from the strap or using double-headed nails to allow the nails and the strap to be removed. FL/Part 1 - 10 COA 3/12 ©STP
  • 30. . FALL PROTECTION. . PART 2: PRE–AUDIT PREPARATION Items to consider getting in advance: • • • Access to the information in 29 CFR 1926 Subpart M. Access to the information in OSHA Directive STD 03-00-001, “Fall Protection Requirements for Residential Construction,” available online at www.osha.gov/pls/oshaweb/owadisp.show_ document?p_table=DIRECTIVES&p_id=2288. Access to the information on OSHA’s Construction Fall Protection webpage at www.osha.gov/SLTC/fallprotection/construction.html. Items to have facility personnel prepare or gather in advance: • Written certifications of fall protection training. • Fall protection training curriculum. • Equipment inspection and repair records. The next page has been removed from this sample. COA 3/12 ©STP FL/Part 2 - 1
  • 31. Fall Protection Pre–audit Preparation Acronyms and Abbreviations Used in This Module ANPR ANSI CAZ CFR cm ft FL/Part 2 - 2 Advanced Notice of Proposed Rulemaking American National Standards Institute controlled access zone Code of Federal Regulations centimeter(s) foot/feet kg kN lb m N OSHA STD kilogram(s) kilonewtons pound(s) meter(s) newton(s) Occupational Safety and Health Administration Standard COA 3/12 ©STP
  • 32. . FALL PROTECTION. . PART 3: RULEBOOK 1. Duty to Have Fall Protection 1.1 Walking/working surfaces must have the strength and structural integrity to support employees safely. (29 CFR 1926.501(a)(2)) . Guide Note • Review procedures and interview employees to ensure that the walking/working surfaces on which employees are to work have the strength and structural integrity to support employees safely (29 CFR 1926.501(a)(2)). • Verify that employees are allowed to work only on those surfaces that have the requisite strength and structural integrity (29 CFR 1926.501(a)(2)). 1.2 Employees on a walking/working surface must be protected from falling under certain circumstances. (29 CFR 1926.501(b)(1)) Guide Note • Verify that each employee on a walking/working surface (horizontal and vertical) with an unprotected side or edge that is 6 ft (1.8 m) or more above a lower level is protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems (29 CFR 1926.501(b)(1)). NOTE 1: The edge of a completed swimming pool not yet filled with water is considered an unprotected side or edge of a walking/working surface and conventional fall protection would be required if workers were exposed to a fall of 6 ft or more (OSHA Standard Interpretation, 06/08/98). NOTE 2: This requirement also applies to fall protection during construction activities when employees are working 6 ft or more above water (OSHA Standard Interpretation, 09/28/99). 1.3 Employees who are constructing leading edges or working nearby must be protected from falling. (29 CFR 1926.501(b)(2)) Guide Note • Verify that each employee who is constructing a leading edge that is 6 ft (1.8 m) or more above lower levels is protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems (29 CFR 1926.501(b)(2)(i)). NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer must develop and implement a fall protection plan that meets the requirements of 29 CFR 1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burden of proof is on the employer to establish that it is appropriate to implement the fall protection plan only. • Verify that each employee on a walking/working surface 6 ft (1.8 m) or more above a lower level where leading edges are under construction, but who is not engaged in the leading edge work, is protected from falling by a guardrail system, safety net system, or personal fall arrest system (29 CFR 1926.501(b)(2)(ii)). NOTE: If a guardrail system is chosen to provide the fall protection, and a controlled access zone (CAZ) has already been established for leading edge work, the control line may be used in lieu of a guardrail along the edge that parallels the leading edge. 1.4 Employees in a hoist area must be protected from falling. (29 CFR 1926.501(b)(3)) Guide Note • Verify that each employee in a hoist area is protected from falling 6 ft (1.8 m) or more to lower levels by guardrail systems or personal fall arrest systems (29 CFR 1926.501(b)(3)). COA 3/12 ©STP FL/Part 3 - 1
  • 33. Fall Protection Rulebook • 1.5 Review work practices to verify that if chains, gates, guardrail systems, or portions thereof are removed to facilitate the hoist (e.g., during landing of materials), and if an employee must lean through the access opening or out over the edge (e.g., to receive or guide materials), then each employee is protected from fall hazards by a personal fall arrest system (29 CFR 1926.501(b)(3)). NOTE: When all or part of a guardrail has been removed, all employees must be protected by a personal fall arrest system, not just the employee(s) that must lean through the access (OSHA Standard Interpretation, Clips used for wire rope guardrails; required fall protection in hoist area Question 2., 08/28/00). Employees on walking/working surfaces with holes must be protected from falling. (29 CFR 1926.501(b)(4)) Guide Note • Verify that each employee on walking/working surfaces is protected from falling through holes (including skylights) more than 6 ft (1.8 m) above lower levels by personal fall arrest systems, covers, or guardrail systems erected over or around such holes (29 CFR 1926.501(b)(4)(i)). • Verify that each employee on a walking/working surface is protected from tripping in or stepping into or through holes (including skylights) by covers (29 CFR 1926.501(b)(4)(ii)). NOTE 1: This provision does not specify a minimum depth for this requirement to apply (OSHA Standard Interpretation, 11/17/98). NOTE 2: OSHA clarifies the terms “hole” versus “unprotected sides or edges” in their Standard Interpretation, 08/14/00. • Verify that each employee on a walking/working surface is protected from objects falling through holes (including skylights) by covers (29 CFR 1926.501(b)(4)(iii)). NOTE: OSHA will treat a skylight as a cover if it is capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on it at any one time (OSHA Standard Interpretation, 12/20/07). 1.6 Employees on the face of formwork or reinforcing steel must be protected from falling. (29 CFR 1926.501(b)(5)) Guide Note • Verify that each employee on the face of formwork or reinforcing steel used in concrete structures is protected from falling 6 ft (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or positioning device systems (29 CFR 1926.501(b)(5)). NOTE: Fall protection is not necessary for employees climbing or moving on built-in-place rebar assemblies at heights below 24 ft above lower levels, as the multiple hand holds and foot holds on rebar assemblies provide protection similar to that of a fixed ladder. However, once employees have reached their work stations, or have moved to points at least 24 ft above lower levels, fall protection is required (OSHA Standard Interpretation, 05/19/97). On formwork, employees must be protected at all times where the fall distance is 6 ft or more above lower levels, including when employees are moving from point to point (OSHA Standard Interpretation, 08/28/00). 1.7 Employees on ramps, runways, and other walkways must be protected from falling. (29 CFR 1926.501(b)(6)) Guide Note • Verify that each employee on ramps, runways, and other walkways is protected from falling 6 ft (1.8 m) or more to lower levels by guardrail systems (29 CFR 1926.501(b)(6)). 1.8 Employees at the edge of excavations must be protected from falling. (29 CFR 1926.501(b)(7)) Guide Note • Verify that each employee at the edge of excavations 6 ft (1.8 m) or more in depth is protected from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barrier (29 CFR 1926.501(b)(7)(i)). • Verify that each employee at the edge of a well, pit, shaft, and similar excavation 6 ft (1.8 m) or more in depth is protected from falling by guardrail systems, fences, barricades, or covers (29 CFR 1926.501(b)(7)(ii)). FL/Part 3 - 2 COA 3/12 ©STP
  • 34. Fall Protection Rulebook 1.9 Employees above dangerous equipment must be protected from falling. (29 CFR 1926.501(b)(8)) Guide Note • Verify that each employee less than 6 ft (1.8 m) above dangerous equipment is protected from falling into or onto the equipment by guardrails systems or by equipment guards (29 CFR 1926.501(b)(8)(i)). • Verify that each employee 6 ft (1.8 m) or more above dangerous equipment is protected from fall hazards by guardrail systems, personal fall arrest systems, or safety net systems (29 CFR 1926.501(b)(8)(ii)). 1.10 Employees performing overhand bricklaying and related work must be protected from falling. (29 CFR 1926.501(b)(9)) Guide Note • Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee performing bricklaying and related work 6 ft (1.8 m) or more above lower levels is protected from falling by guardrail systems, safety net systems, or personal fall arrest systems or that the work is in a CAZ (29 CFR 1926.501(b)(9)(i)). • Review work practices to verify that employees reaching more than 10 inches (25 cm) below the level of the walking/working surface on which they are working are protected from falling by a guardrail system, safety net system, or personal fall arrest system (29 CFR 1926.501(b)(9)(ii)). NOTE: Bricklaying operations performed on scaffolds are regulated under 29 CFR 1926 Subpart L (see module L, “Scaffolding”). 1.11 Employees engaged in roofing activities on low-slope roofs must be protected from falling. (29 CFR 1926.501(b)(10)) Guide Note • Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee engaged in roofing activities on low-sloped roofs, with unprotected sides and edges 6 ft (1.8 m) or more above lower levels is protected from falling by any of the following (29 CFR 1926.501(b)(10)): – guardrail systems; – safety net systems; – personal fall arrest systems; – a combination of a warning line system and guardrail system; – a combination of a warning line system and safety net system; – a combination of a warning line system and personal fall arrest system; or – a combination of a warning line system and safety monitoring system. NOTE 1: On roofs 50 ft (15.25 m) or less in width (see Appendix A to this subpart), the use of a safety monitoring system alone (i.e., without the warning line system) is permitted. (See also OSHA Standard Interpretation, 01/16/01). NOTE 2: An employer may use a combination of warning lines 6 ft (and in some cases 10 ft) back from the edge in combination with monitors in place of personal fall protection equipment or guardrails (OSHA Standard Interpretation, 08/01/00). 1.12 Employees on a steep roof must be protected from falling. (29 CFR 1926.501(b)(11)) Guide Note • Verify that each employee on a steep roof with unprotected sides and edges 6 ft (1.8 m) or more above lower levels is protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems (29 CFR 1926.501(b)(11)). COA 3/12 ©STP FL/Part 3 - 3
  • 35. Fall Protection Rulebook 1.13 Employees engaged in the erection of precast concrete members must be protected from falling. (29 CFR 1926.501(b)(12)) Guide Note • Verify that each employee engaged in the erection of precast concrete members (including but not limited to the erection of wall panels, columns beams, and floor and roof “tees”) and related operations (such as grouting of precast concrete members) who is 6 ft (1.8 m) or more above lower levels is protected from falling by any of the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 – 1.16] provides for an alternative fall protection measure) (29 CFR 1926.501(b)(12)): – guardrail systems; – safety net systems; or – personal fall arrest systems. NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR 1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burden of proof is on the employer to establish that it is appropriate to implement the fall protection plan only. 1.14 Employees engaged in residential construction must be protected from falling. (29 CFR 1926.501(b)(13)) Guide Note • Verify that each employee engaged in residential construction who is 6 ft (1.8 m) or more above lower levels is protected from falling by any of the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 to 1.16] provides for an alternative fall protection measure) (29 CFR 1926.501(b)(13)): – guardrail systems; – safety net systems; or – personal fall arrest systems. NOTE 1: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR 1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burden of proof is on the employer to establish that it is appropriate to implement the fall protection plan only. NOTE 2: OSHA Instruction STD 03-00-001, “Interim Fall Protection Compliance Guidelines for Residential Construction,” modifies the above requirements. It permits employers engaged in certain residential construction activities (e.g., homebuilders and roofing contractors) to use alternative procedures routinely instead of conventional fall protection. Different alternate procedures are specified for different activities. Such employers do not have to demonstrate the infeasibility of conventional fall protection as a precondition to using the STD 03-00-001 alternative procedures. They also do not have to put their fall protection plan in writing, nor does the plan have to be site-specific . NOTE 3: See the Appendix in the introduction to this module for an OSHA Standard Interpretation, 05/25/00, providing further interpretation on OSHA’s enforcement policy for residential construction. 1.15 Employees working on, at, above, or near wall openings must be protected from falling. (29 CFR 1926.501(b)(14)) Guide Note • If there are wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 ft (1.8 m) or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking/working surface, then verify that each employee working on, at, above, or near such openings is protected from falling by any of the following (29 CFR 1926.501(b)(14)): – guardrail systems; – safety net systems; or – personal fall arrest systems. FL/Part 3 - 4 COA 3/12 ©STP
  • 36. Fall Protection Rulebook 1.16 Employees must be protected from falling on walking/working surfaces not otherwise addressed in this section. (29 CFR 1926.501(b)(15)) Guide Note • Except as provided in 29 CFR 1926.500(a)(2) (see the Introduction to this module) or in 29 CFR 1926.501(b)(1) – (b)(14) (see paragraphs 1.2 – 1.15), verify that each employee on a walking/working surface 6 feet (1.8 m) or more above lower levels is protected from falling by any of the following (29 CFR 1926.501(b)(15)): – guardrail systems; – safety net systems; or – personal fall arrest systems. 1.17 Employers must provide protection from falling objects. (29 CFR 1926.501(c)) Guide Note • Verify that when employees are exposed to falling objects, the employer has each employee wear a hard hat and implements one of the following actions (29 CFR 1926.501(c)): – erects toeboards, screens, or guardrail systems to prevent objects from falling from higher levels; – erects a canopy structure and keeps potential fall objects far enough from the edge of the higher level so that objects will not go over the edge if they are accidentally displaced; or – barricades the area to which objects could fall, prohibits employees from entering the barricaded area, and keeps objects that may fall far enough away from the edge of the higher level so that those objects will not go over the edge if they are accidentally displaced. NOTE: Additional provisions for protection from falling objects are found in 29 CFR 1926.502(j) (see section 9). 2. Fall Protection Systems Criteria and Practices . All fall protection systems must be designed according to these requirements and installed before employees begin the work requiring fall protection (29 CFR 1926.502(a)(2)). 2.1 Top edge height of top rails, or equivalent guardrail system members, must meet certain requirements. (29 CFR 1926.502(b)(1)) Guide Note • Verify that the top edge height of top rails, or equivalent guardrail system members, is 42 inches (1.1 m) . ± 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may exceed the 45 inch limit, provided the guardrail system meets all other criteria of 29 CFR 1926.502(b) (see also paragraphs 2.2 – 2.7) (29 CFR 1926.502(b)(1)). NOTE: When employees are using stilts, the top edge height of the top rail, or equivalent member, must be increased an amount equal to the height of the stilts. 2.2 Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural members must be installed according to certain requirements. (29 CFR 1926.502(b)(2)) Guide Note • Verify that midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural members are installed between the top edge of the guardrail system and the walking/working surface when there is no wall or parapet wall at least 21 inches (53 cm) high (29 CFR 1926.502(b)(2)). When midrails are used, verify that they are installed midway between the top edge of the guardrail system and the walking/working level (29 CFR 1926.502(b)(2)(i)). • Verify that screens and mesh, when used, extend from the top rail to the walking/working level and along the entire opening between top rail supports (29 CFR 1926.502(b)(2)(ii)). • Verify that intermediate members (such as balusters), when used between posts, are no more than 19 inches (48 cm) apart (29 CFR 1926.502(b)(2)(iii)). • Verify that other structural members (such as additional midrails and architectural panels) are installed so that there are no openings in the guardrail system more than 19 inches (48 cm) wide (29 CFR 1926.502(b)(2)(iv)). COA 3/12 ©STP FL/Part 3 - 5
  • 37. Fall Protection Rulebook 2.3 Guardrail systems must be able to withstand a specified amount of force and pressure. (29 CFR 1926.502(b)(3) – (b)(4)) Guide Note • Verify that all guardrail systems are capable of withstanding, without failure, a force of at least 200 lb (890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge (29 CFR 1926.502(b)(3)). • Verify that when the 200 lb (890 N) test load is applied in a downward direction, the top edge of the guardrail does not deflect to a height less than 39 inches (1.0 m) above the walking/working level (29 CFR 1926.502(b)(4)). NOTE: Guardrail system components selected and constructed in accordance with Appendix B to this subpart meet this requirement. 2.4 Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members must be able to withstand a specified amount of force. (29 CFR 1926.502(b)(5)) Guide Note • Verify that midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members are capable of withstanding, without failure, a force of at least 150 lb (666 N) applied in any downward or outward direction at any point along the midrail or other member (29 CFR 1926.502(b)(5)). 2.5 Guardrail systems must be properly constructed to prevent injury. (29 CFR 1926.502(b)(6) – (b)(10) and (b)(14)) Guide Note • Verify that guardrail systems are surfaced to prevent injury to an employee from punctures or lacerations and to prevent snagging of clothing (29 CFR 1926.502(b)(6)). • Verify that the ends of all top rails and midrails do not overhang the terminal posts, except where the overhang does not constitute a projection hazard (29 CFR 1926.502(b)(7)). • Verify that steel banding and plastic banding are not used as top rails or midrails (29 CFR 1926.502(b)(8)). • Verify that top rails and midrails are at least 1/4 inch (0.6 cm) nominal diameter or thickness to prevent cuts and lacerations (29 CFR 1926.502(b)(9)). • If wire rope is used for top rails, verify that it is flagged at not more than 6-ft intervals with high-visibility material (29 CFR 1926.502(b)(9)). • When guardrail systems are used at hoisting areas, verify that a chain, gate, or removable guardrail section is placed across the access opening between guardrail sections when hoisting operations are not taking place (29 CFR 1926.502(b)(10)). • Verify that guardrail systems used on ramps and runways are erected along each unprotected side or edge (29 CFR 1926.502(b)(14)). 2.6 Guardrail systems around holes must meet certain requirements. (29 CFR 1926.502(b)(11) – (b)(13)) Guide Note • When guardrail systems are used at holes, verify that they are erected on all unprotected sides or edges of the hole (29 CFR 1926.502(b)(11)). • When guardrail systems are used around holes used for the passage of materials, verify that no more than two sides of the hole are provided with removable guardrail sections to allow the passage of materials (29 CFR 1926.502(b)(12)). • When the hole is not in use, verify that it is closed over with a cover or that a guardrail system is provided along all unprotected sides or edges (29 CFR 1926.502(b)(12)). • When guardrail systems are used around holes that are used as points of access (such as ladderways), verify that they are provided with a gate, or are so offset that a person cannot walk directly into the hole (29 CFR 1926.502(b)(13)). FL/Part 3 - 6 COA 3/12 ©STP
  • 38. Fall Protection Rulebook 2.7 Manila, plastic, or synthetic rope must meet certain strength requirements. (29 CFR 1926.502(b)(15)) Guide Note • Verify that manila, plastic, or synthetic rope being used for top rails or midrails is inspected as frequently as necessary to verify that it continues to meet the strength requirements of 29 CFR 1926.502(b)(3) (see paragraph 2.3) (29 CFR 1926.502(b)(15)). NOTE: The OSHA standard does not specify a minimum number of clips when using wire rope as a guardrail. However, as a practical matter, it is unlikely you could meet the specific requirements under 29 CFR 1926.502(b) unless you follow the manufacturer’s recommendations for the number of clips to be used on wire ropes of different diameters (OSHA Interpretation Letter, 08/28/00). 2.8 Safety net systems must be installed and used according to certain requirements. (29 CFR 1926.502(c)(1) – (c)(3)) Guide Note • Inspect safety nets to ensure they are installed as close as practicable under the walking/working surface on which employees are working, but no more than 30 ft (9.1 m) below such level (29 CFR 1926.502(c)(1)). • When nets are used on bridges, verify that the potential fall area from the walking/working surface to the net is unobstructed (29 CFR 1926.502(c)(1)). • Inspect safety nets to ensure they extend outward from the outermost projection of the work surface as indicated in Table 1 (29 CFR 1926.502(c)(2)). • Verify that safety nets are installed with sufficient clearance under them to prevent contact with the surface or structures below when subjected to an impact force equal to the drop test specified in 29 CFR 1926.502(c)(4)(i) (see paragraph 2.9) (29 CFR 1926.502(c)(3)). Table 1: Horizontal Extension of Safety Nets from Work Surface Vertical distance from working level to horizontal plane of net Minimum required horizontal distance of outer edge of net from the edge of the working surface Up to 5 ft 8 ft 5 ft – 10 ft 10 ft More than 10 ft 13 ft Source: 29 CFR 1926.502(c)(2) 2.9 Safety nets and safety net installations must be drop-tested. (29 CFR 1926.502(c)(4)) Guide Note • Verify that safety nets and their installations are capable of absorbing an impact force equal to that produced by the drop test specified in 29 CFR 1926.502(c)(4)(i) (29 CFR 1926.502(c)(4)). • Verify that safety nets and safety net installations are drop-tested at the jobsite at the following times (29 CFR 1926.502(c)(4)(i)): – after initial installation and before being used as a fall protection system; – whenever they are relocated; – after major repair; and – at six-month intervals if left in one place. • Review procedures to ensure that the drop-test consists of a 400 lb (180 kg) bag of sand 30 inches ± 2 inches (76 cm ± 5 cm) in diameter dropped into the net from at least 42 inches (1.1 m) above the highest walking/working surface at which employees are exposed to hazards (29 CFR 1926.502(c)(4)(i)). • When the employer can demonstrate that it is unreasonable to perform the drop-test, verify that the employer certifies that the net and net installation is in compliance with the provisions of 29 CFR 1926.502(c)(3) and (c)(4)(i) (see paragraph 2.8) by preparing a certification record prior to the net being used as a fall protection system. The most recent certification record for each net and net installation must be available at the jobsite for inspection and must include the following (29 CFR 1926.502(c)(4))(ii)): – an identification of the net and net installation for which the certification record is being prepared; – the date that it was determined that the identified net and net installation were in compliance; and – the signature of the person making the determination and certification. COA 3/12 ©STP FL/Part 3 - 7
  • 39. Fall Protection Rulebook 2.10 Safety nets and safety net systems must be inspected for wear, damage, deterioration, and defects. (29 CFR 1926.502(c)(5)) Guide Note • Verify that safety nets are inspected at least once a week for wear, damage, and other deterioration (29 CFR 1926.502(c)(5)). • Verify that safety nets are inspected after any occurrence that could affect the integrity of the safety net system (29 CFR 1926.502(c)(5)). • Verify that defective nets are not used and that defective components are removed from service (29 CFR 1926.502(c)(5)). 2.11 Objects that fall into safety nets must be removed as soon as possible. (29 CFR 1926.502(c)(6)) Guide Note • Verify that materials, scrap pieces, equipment, and tools that have fallen into safety nets are removed as soon as possible from the net and at least before the next work shift (29 CFR 1926.502(c)(6)). 2.12 Safety nets must be constructed according to certain requirements. (29 CFR 1926.502(c)(7) – (c)(9)) Guide Note • Measure the maximum size of each safety net mesh opening to ensure it conforms to the following requirements (29 CFR 1926.502(c)(7)): – Each opening must not exceed 36 sq inches (230 cm2) nor be longer than 6 inches (15 cm) on any side. – The opening, measured center-to-center of mesh ropes or webbing, must not be longer than 6 inches (15 cm). – All mesh crossings must be secured to prevent enlargement of the mesh opening. • Verify that each safety net (or section of it) has a border rope for webbing with a minimum breaking strength of 5,000 lb (22.2 kN) (29 CFR 1926.502(c)(8)). • Ensure that connections between safety net panels are as strong as integral net components and are not spaced more than 6 inches (15 cm) apart (29 CFR 1926.502(c)(9)). 3. Personal Fall Arrest Systems . Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system. The use of a body belt in a positioning device system is acceptable and is regulated under 29 CFR 1926.502(e) (see section 4 below) (29 CFR 1926.502(d)). 3.1 Connectors for personal fall arrest systems must meet certain requirements. (29 CFR 1926.502(d)(1) – (d)(6)) Guide Note • Inspect connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalent materials (29 CFR 1926.502(d)(1)). • Inspect connectors to verify that they have a corrosion-resistant finish and that all surfaces and edges are smooth to prevent damage to interfacing parts of the system (29 CFR 1926.502(d)(2)). • Verify that dee-rings and snaphooks have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR 1926.502(d)(3)). • Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without cracking, breaking, or taking permanent deformation (29 CFR 1926.502(d)(4)). • Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR 1926.502(d)(5)): – Snaphooks are a compatible size for the member to which they are connected. – Only locking type snaphooks are used. FL/Part 3 - 8 COA 3/12 ©STP
  • 40. Fall Protection Rulebook • 3.2 Verify that unless snaphooks are a locking type and are designed for the following connections, the snaphooks are not engaged (29 CFR 1926.502(d)(6)): – directly to webbing, rope, or wire rope; – to each other; – to a dee-ring to which another snaphook or other connector is attached; – to a horizontal lifeline; or – to any object that is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional disengagement could occur by the connected object depressing the snaphook keeper and releasing itself. Lifelines for personal fall protection systems must meet certain requirements. (29 CFR 1926.502(d)(7) – (d)(14)) Guide Note • Verify that on suspended scaffolds or similar work platforms with horizontal lifelines that may become vertical lifelines, the devices used to connect to a horizontal lifeline are capable of locking in both directions on the lifeline (29 CFR 1926.502(d)(7)). • Verify that horizontal lifelines are designed, installed, and used under the supervision of a qualified person as part of a complete personal fall arrest system that maintains a safety factor of at least 2 (29 CFR 1926.502(d)(8)). • Verify that lanyards and vertical lifelines have a minimum breaking strength of 5,000 lb (22.2 kN) (29 CFR 1926.502(d)(9)). • Verify that when vertical lifelines are used, each employee is attached to a separate lifeline (29 CFR 1926.502(d)(10)(i)). EXCEPTION: During the construction of elevator shafts, 2 employees may be attached to the same lifeline in the hoistway, provided that all of the following conditions are met (29 CFR 1926.502(d)(10)(ii)): – Both employees are working atop a false car that is equipped with guardrails. – The strength of the lifeline is 10,000 lb (44.4 kN) (5,000 lb per employee attached). – All other criteria specified in 29 CFR 1926.502(d) (see section 3) for lifelines have been met. • Verify that lifelines are protected against being cut or abraded (29 CFR 1926.502(d)(11)). • Verify that self-retracting lifelines and lanyards that automatically limit free fall distance to 2 ft (0.61 m) or less are capable of sustaining a minimum tensile load of 3,000 lb (13.3 kN) applied to the device with the lifeline or lanyard in the fully extended position (29 CFR 1926.502(d)(12)). • Verify that self-retracting lifelines and lanyards that do not limit free fall distance to 2 ft (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards are capable of sustaining a minimum tensile load of 5,000 lb (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position (29 CFR 1926.502(d)(13)). • Verify that ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and body harnesses are made from synthetic fibers (29 CFR 1926.502(d)(14)). 3.3 Anchorages used for attachment of personal fall arrest systems must be designed, installed, and used according to certain requirements. (29 CFR 1926.502(d)(15)) Guide Note • Verify that anchorages used for attachment of personal fall arrest equipment meet either of the following conditions (29 CFR 1926.502(d)(15)): – The anchorages are independent of any anchorage being used to support or suspend platforms and are capable of supporting at least 5,000 lb (22.2 kN) per employee attached. – The anchorages are designed, installed, and used under the supervision of a qualified person as part of a complete personal fall arrest system that maintains a safety factor of at least 2. NOTE: OSHA allows scaffolding to function as a suitable anchorage for fall arrest systems when the scaffolding used is erected and braced such that the criteria of 29 CFR 1926.502(d)(15) are met. This applies whether the scaffold is partially built (i.e., being erected or disassembled) or completely built (OSHA Standard Interpretation, 04/02/98). COA 3/12 ©STP FL/Part 3 - 9
  • 41. Fall Protection Rulebook 3.4 When stopping a fall, personal fall arrest systems must meet certain requirements. (29 CFR 1926.502(d)(16)) Guide Note • Verify that when stopping a fall, personal fall arrest systems (29 CFR 1926.502(d)(16)): – limit maximum arresting force on an employee to 900 lb (4 kN) when used with a body belt; – limit maximum arresting force on an employee to 1,800 lb (8 kN) when used with a body harness; – be rigged such that an employee can neither free fall more than 6 ft (1.8 m) nor contact any lower level; – bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 ft (1.07 m); and – have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 ft (1.8 m) or the free fall distance permitted by the system, whichever is less. NOTE 1: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to this subpart, and if the system is being used by an employee with a combined person and tool weight of less than 310 lb (140 kg), the system will be considered to be in compliance with the provisions of 29 CFR 1926.502(d)(16) (see guide notes above). If the system is used by an employee with a combined tool and body weight of 310 lb (140 kg) or more, then the employer must appropriately modify the criteria and protocols of the appendix to provide proper protection for such heavier weights, or the system will not be deemed to be in compliance. NOTE 2: Shock-absorbing lanyards are not mandatory but may be used to comply with this provision (OSHA Standard Interpretation, 06/03/98). NOTE 3: A body harness used as a component of a personal fall arrest system does not require nor does it exclude the use of a waist or chest strap as part of a full body harness, as long as the harness properly distributes the fall arrest forces (OSHA Standard Interpretation, 09/23/99). 3.5 Body belts and harnesses on personal fall arrest systems must meet certain requirements. (29 CFR 1926.502(d)(17) – (d)(18) and (d)(22)) Guide Note • Verify that the attachment point of a body belt is located in the center of the wearer’s back (29 CFR 1926.502(d)(17)). • Verify that the attachment point of a body harness is located in the center of the wearer’s back near shoulder level or above the wearer’s head (29 CFR 1926.502(d)(17)). • Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(d)(18)). NOTE: If any component of the rigging system, such as a shackle, wire rope, or synthetic sling was or is used to hoist materials, these components are not be used as part of a fall protection system (OSHA Standard Interpretation, 11/03/00, Question 4). • Inspect all body belts to ensure they are at least 1 5/8 inches (4.1 cm) wide (29 CFR 1926.502(d)(22)). 3.6 Personal fall arrest systems and components must be inspected under certain conditions. (29 CFR 1926.502(d)(19) and (d)(21)) Guide Note • Verify that personal fall arrest systems and components subjected to impact loading are immediately removed from service and are not used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse (29 CFR 1926.502(d)(19)). • Review procedures to ensure that personal fall arrest systems are inspected prior to each use for wear, damage, and other deterioration and that defective components are removed from service (29 CFR 1926.502(d)(21)). 3.7 Personal fall arrest systems must not be attached to guardrail systems or hoists, except as specified in this subpart. (29 CFR 1926.502(d)(23)) Guide Note • Verify that personal fall arrest systems are not attached to guardrail systems (29 CFR 1926.502(d)(23)). • Verify that fall arrest systems are not attached to hoists, except as specified in other subparts of 29 CFR 1926 (29 CFR 1926.502(d)(23)). FL/Part 3 - 10 COA 3/12 ©STP
  • 42. Fall Protection Rulebook 3.8 A personal fall arrest system used at hoist areas must be rigged according to certain requirements. (29 CFR 1926.502(d)(24)) Guide Note • When a personal fall arrest system is used at hoist areas, verify that it is rigged to allow the movement of the employee only as far as the edge of the walking/working surface (29 CFR 1926.502(d)(24)). 3.9 In the event of a fall by an employee, prompt rescue must be executed. (29 CFR 1926.502(d)(20)) Guide Note • In the event of a fall, verify that the employer provides for the prompt rescue of employees or that employees are able to rescue themselves (29 CFR 1926.502(d)(20)). 4. Positioning Device Systems 4.1 Positioning device systems and their use must comply with certain requirements. (29 CFR 1926.502(e)(1) – (e)(5)) . Guide Note • Verify that positioning devices are rigged such that an employee cannot free fall more than 2 ft (0.9 m) (29 CFR 1926.502(e)(1)). • Inspect the positioning devices to ensure they are secured to an anchorage capable of supporting at least twice the potential impact load of an employee’s fall or 3,000 lb (13.3 kN), whichever is greater (29 CFR 1926.502(e)(2)). • Inspect the connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalent materials (29 CFR 1926.502(e)(3)). • Inspect the connectors to ensure they have a corrosion-resistant finish and that all surfaces and edges are smooth to prevent damage to interfacing parts of this system (29 CFR 1926.502(e)(4)). • Verify that connecting assemblies have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR 1926.502(e)(5)). 4.2 Dee-rings and snaphooks must be properly tested and used. (29 CFR 1926.502(e)(6) – (e)(8)) Guide Note • Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without cracking, breaking, or taking permanent deformation (29 CFR 1926.502(e)(6)). • Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR 1926.502(e)(7)): – Snaphooks are a compatible size for the member to which they are connected. – Locking type snaphooks are used. NOTE: Effective January 1, 1998, only locking type snaphooks may be used. • Verify that unless the snaphook is a locking type and is designed for the following connections, snaphooks are not engaged (29 CFR 1926.502(e)(8)): – directly to webbing, rope, or wire rope; – to each other; – to a dee-ring to which another snaphook or other connector is attached; – to a horizontal lifeline; or – to any object that is incompatibly shaped or dimensional in relation to the snaphook such that unintentional disengagement could occur by the connected object depressing the snaphook keeper and releasing itself. COA 3/12 ©STP FL/Part 3 - 11
  • 43. Fall Protection Rulebook 4.3 Positioning device systems and components must be inspected under certain conditions. (29 CFR 1926.502(e)(9)) Guide Note • Verify that positioning device systems are inspected prior to each use for wear, damage, and other deterioration and that defective components are removed from service (29 CFR 1926.502(e)(9)). 4.4 Body belts, harnesses, and components must not be used to hoist materials. (29 CFR 1926.502(e)(10)) Guide Note • Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(e)(10)). NOTE: Personal fall arrest systems must have the lanyard attached to a dee-ring at the back to minimize injury to the wearer. Belts used for fall arrest with side dee-rings are not in compliance and are dangerous to the wearer. Belts worn with the dee-rings(s) at the side(s) are suitable only as positioning devices. (OSHA Standard Interpretation, 09/25/95). 5. Warning Line Systems 5.1 Warning lines around all sides of a roof work area must meet certain requirements. (29 CFR 1926.502(f)(1)) . Guide Note • Verify that a warning line is erected around all sides of the roof work area according to the following requirements (29 CFR 1926.502(f)(1)): – When mechanical equipment is not being used, the warning line must be erected no less than 6 ft (1.8 m) from the roof edge. – When mechanical equipment is being used, the warning line must be erected no less than 6 ft (1.8 m) from the roof edge that is parallel to the direction of mechanical equipment operation, and not less than 10 ft (3.1 m) from the roof edge that is perpendicular to the direction of mechanical equipment operation. NOTE: OSHA further defines and clarifies the use of mechanical equipment in its Standard Interpretation, 10/17/00. – Points of access, materials handling areas, storage areas, and hoisting areas must be connected to the work area by an access path formed by two warning lines. – When the path to a point of access is not in use, either of the following must occur so that a person cannot walk directly into the work area: 1) a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line, must be placed across the path at the point where the path intersects the warning line; or 2) the path must be offset such that a person cannot walk directly into the work area. 5.2 Warning lines must consist of ropes, wires, or chains, and supporting stanchions, and must be erected according to certain requirements. (29 CFR 1926.502(f)(2)) Guide Note • Verify that warning lines consist of ropes, wires, or chains and supporting stanchions and are erected as follows (29 CFR 1926.502(f)(2)): – The rope, wire, or chain must be flagged at not more than 6-ft (1.8 m) intervals with high-visibility material. – The rope, wire, or chain must be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches (0.9 m) from the walking/working surface and its highest point is no more than 39 inches (1.0 m) from the walking/working surface. – After being erected and with the rope, wire, or chain attached, stanchions must be capable of resisting, without tipping over, a force of at least 16 lb (71 N) that is applied horizontally against the stanchion and perpendicular to the warning line, 30 inches (0.8 m) above the walking/working surface in the direction of the floor, roof, or platform edge. FL/Part 3 - 12 COA 3/12 ©STP
  • 44. Fall Protection Rulebook – – 5.3 The rope, wire, or chain must have a minimum tensile strength of 500 lb (2.22 kN) and, after being attached to the stanchions, must be capable of supporting, without breaking, the loads applied to the stanchions as prescribed in 29 CFR 1926.502(f)(2)(iii) (see third dashed point above). The line must be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. Only authorized employees are allowed in the area between a roof edge and a warning line. (29 CFR 1926.502(f)(3)) Guide Note • Review procedures to ensure that no employee is allowed in the area between a roof edge and a warning line unless the employee is performing roofing work in that area (29 CFR 1926.502(f)(3)). 5.4 Employees must be protected from mechanical equipment on roofs. (29 CFR 1926.502(f)(4)) Guide Note • Verify that mechanical equipment on roofs is used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system (29 CFR 1926.502(f)(4)). 6. Controlled Access Zones 6.1 CAZs must de defined where leading edge and other operations are taking place. (29 CFR 1926.502(g)(1)) . Guide Note • Verify that when a CAZ is used to control access to areas where leading edge and other operations are taking place, the CAZ is defined by a control line or by any other means that restricts access (29 CFR 1926.502(g)(1)). • If control lines are used to control access to areas where leading edge and other operations are taking place, verify that they are erected according to the following requirements (29 CFR 1926.502(g)(1)): – Control lines must be erected not less than 6 ft (1.8 m) nor more than 25 ft (7.7 m) from the unprotected or leading edge, except when erecting precast concrete members. – When erecting precast concrete members, the control line must be erected either not less than 6 ft (1.8 m) nor more than 60 ft (18 m) from the leading edge or half the length of the member being erected from the leading edge, whichever is less. – The control line must extend along the entire length of the unprotected or leading edge and must be approximately parallel to the unprotected or leading edge. – The control line must be connected on each side to a guardrail system or wall. 6.2 CAZs used to control access to areas where overhand bricklaying and related work are taking place must meet certain requirements. (29 CFR 1926.502(g)(2)) Guide Note • When CAZs are used to control access to areas where overhand bricklaying and related work are taking place, verify that the following requirements are met (29 CFR 1926.502(g)(2)): – The CAZ is defined by a control line erected not less than 10 ft (3.1 m) nor more than 15 ft (4.5 m) from the working edge. – The control line extends for a distance sufficient for the CAZ to enclose all employees performing overhand bricklaying and related work at the working edge and must be approximately parallel to the working edge. – Additional control lines are erected at each end to enclose the CAZ. – Only employees engaged in overhand bricklaying or related work are permitted in the CAZ. COA 3/12 ©STP FL/Part 3 - 13
  • 45. Fall Protection Rulebook 6.3 Control lines must consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions, and must meet certain requirements. (29 CFR 1926.502(g)(3)) Guide Note • Verify that control lines consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions as follows (29 CFR 1926.502(g)(3)): – Each line must be flagged or otherwise clearly marked at not more than 6 ft (1.8 m) intervals with highvisibility material. – Each line must be rigged and supported in such a way that its lowest point (including sag) is not less than 39 inches (1 m) from the walking/working surface and its highest point is not more than 45 inches (1.3 m) from the walking/working surface. NOTE: When overhand bricklaying operations are being performed, the line’s highest point must not be more than 50 inches (1.3 m) from the walking/working surface. – Each line must have a minimum breaking strength of 200 lb (0.88 kN). 6.4 Floors and roofs in CAZs must be properly constructed for bricklaying operations. (29 CFR 1926.502(g)(4) – (g)(5)) Guide Note • Verify that on floors and roofs where guardrail systems are not in place prior to the beginning of overhand bricklaying operations, CAZs are enlarged as necessary to enclose all points of access, material handling areas, and storage areas (29 CFR 1926.502(g)(4)). • Verify that on floors and roofs where guardrail systems are in place but need to be removed to allow overhand bricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplish that day’s work is removed (29 CFR 1926.502(g)(5)). 7. Safety Monitoring Systems 7.1 Safety monitoring systems must meet certain requirements. (29 CFR 1926.502(h)) . Guide Note • Interview employees to verify that the employer designates a competent person to monitor the safety of other employees and that the employer ensures that the safety monitor complies with all of the following requirements (29 CFR 1926.502(h)(1)): – The safety monitor must be competent to recognize fall hazards. – The safety monitor must warn the employee when it appears that the employee is unaware of a fall hazard or is acting in an unsafe manner. – The safety monitor must be on the same walking/working surface and within visual sighting distance of the employee being monitored. – The safety monitor must be close enough to communicate orally with the employee. – The safety monitor must not have other responsibilities that could take the monitor’s attention from the monitoring function. • Verify that mechanical equipment is not used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-slope roofs (29 CFR 1926.502(h)(2)). • Review employee work practices to verify that no employee, other than an employee engaged in roofing work on low-sloped roofs or an employee covered by a fall protection plan, is allowed in an area where an employee is being protected by a safety monitoring system (29 CFR 1926.502(h)(3)). • Verify that each employee working in a CAZ is directed to comply promptly with fall hazard warnings from safety monitors (29 CFR 1926.502(h)(4)). FL/Part 3 - 14 COA 3/12 ©STP
  • 46. Fall Protection Rulebook 8. Covers 8.1 Covers for holes must meet certain requirements. (29 CFR 1926.502(i)) . Guide Note • Verify that covers located in roadways and vehicular aisles are capable of supporting, without failure, at least twice the maximum axle load of the largest vehicle expected to cross over the cover (29 CFR 1926.502(i)(1)). • Verify that all other covers are capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time (29 CFR 1926.502(i)(2)). • Verify that all covers are secured when installed to prevent accidental displacement by the wind, equipment, or employees (29 CFR 1926.502(i)(3)). • Verify that all covers are color coded, or that they are marked with the word “Hole” or “Cover” to provide warning of the hazard (29 CFR 1926.502(i)(4)). NOTE: This provision does not apply to cast iron manhole covers or steel grates used on streets or roadways. 9. Protection from Falling Objects . NOTE: Additional provisions for protection from falling objects are found in 29 CFR 1926.501(c) (see paragraph 1.17 above) 9.1 Toeboards, when used as falling object protection, must meet certain requirements. (29 CFR 1926.502(j)(1) – (j)(4)) Guide Note • Verify that toeboards, when used as falling object protection, are erected along the edge of the overhead walking/working surface for a distance sufficient to protect employees below (29 CFR 1926.502(j)(1)). • Verify that toeboards are capable of withstanding, without failure, a force of at least 50 lb (222 N) applied in any downward or outward direction at any point along the toeboard (29 CFR 1926.502(j)(2)). • Inspect the toeboards to ensure they meet the following requirements (29 CFR 1926.502(j)(3)): – They are a minimum of 3½ inches (9 cm) in vertical height from their top edge to the edge of the walking/working surface. – They are no more than ¼ inch (0.6 cm) clearance above the walking/working surface. – They are solid or have openings no greater than 1 inch (2.5 cm) in any dimension. • Where tools, equipment, or materials are piled higher than the top edge of a toeboard, verify that paneling or screening is erected from the walking/working surface or toeboard to the top of a guardrail system’s top rail or midrail, for a distance sufficient to protect employees below (29 CFR 1926.502(j)(4)). 9.2 Guard rail systems, when used as falling object protection, must meet certain requirements. (29 CFR 1926.502(j)(5)) Guide Note • Verify that guardrail systems, when used as falling object protection, have all openings small enough to prevent passage of potential falling objects (29 CFR 1926.502(j)(5)). 9.3 Certain requirements must be met during the performance of bricklaying and related work. (29 CFR 1926.502(j)(6)) Guide Note • Verify that no equipment except masonry and mortar are stored within 4 ft (1.2 m) of the working edge (29 CFR 1926.502(j)(6)(i)). • Verify that excess mortar, broken or scattered masonry units, and all other materials and debris are removed from the work area at regular intervals (29 CFR 1926.502(j)(6)(ii)). COA 3/12 ©STP FL/Part 3 - 15
  • 47. Fall Protection Rulebook 9.4 Certain requirements must be met during the performance of roofing work. (29 CFR 1926.502(j)(7)) Guide Note • Verify that equipment and materials are not stored within 6 ft (1.8 m) of a roof edge unless guardrails are erected at the edge (29 CFR 1926.502(j)(7)(i)). • Verify that piled, grouped, or stacked materials near a roof are stable and self-supporting (29 CFR 1926.502(j)(7)(ii)). 9.5 Canopies used as falling object protection must meet certain requirements. (29 CFR 1926.502(j)(8)) Guide Note • Verify that canopies, when used as falling object protection, are strong enough to prevent collapse and to prevent penetration by any objects that may fall onto the canopy (29 CFR 1926.502(j)(8)). 10. Fall Protection Plans . 10.1 Fall protection plans must meet certain requirements. (29 CFR 1926.502(k)) Guide Note NOTE: The option for using a fall protection plan is available only to employees engaged in leading edge work, precast concrete erection work, or residential construction work who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment (29 CFR 1926.502(k)). • Verify that the fall protection plan is prepared by a qualified person and developed specifically for the site where the work is being performed and that the plan is maintained up-to-date. Any changes to the fall protection plan must be approved by a qualified person (29 CFR 1926.502(k)(1) – (k)(2)). • Verify that a copy of the fall protection plan with all approved changes is maintained at the job site (29 CFR 1926.502(k)(3)). • Verify that the implementation of the fall protection plan is under the supervision of a competent person (29 CFR 1926.502(k)(4)). • Verify that the fall protection plan documents the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard (29 CFR 1926.502(k)(5)). • Review the fall protection plan to ensure it includes a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems (29 CFR 1926.502(k)(6)). • Review the fall protection plan to ensure it identifies each location where conventional fall protection methods cannot be used. These locations must then be classified as CAZs and the employer must comply with the criteria in 29 CFR 1926.502(g) (see section 6 above) (29 CFR 1926.502(k)(7)). • Verify that where no other alternative measure has been implemented, the employer implements a safety monitoring system in conformance with 29 CFR 1926.502(h) (see paragraph 7.1 above) (29 CFR 1926.502(k)(8)). • Verify that the fall protection plan includes a statement that provides the name or other method of identification for each employee who is designated to work in CAZs. No other employees may enter CAZs (29 CFR 1926.502(k)(9)). • If an employee falls or some other related, serious incident occurs (e.g., a near miss), verify that the employer investigates the circumstances of the incident to determine if the fall protection plan needs to be changed (e.g., by new practices, procedures, or training) and implements those changes to prevent similar types of falls or incidents (29 CFR 1926.502(k)(10)). FL/Part 3 - 16 COA 3/12 ©STP