Construction exceptions

• Exceptions to the fall protection rule exist for construction workers who are in the process of inspecting or investigating a worksite before work begins or after work is completed.

The rule covers most construction workers except those inspecting, investigating, or assessing workplace conditions prior to the actual start of work or after all work has been completed (1926.500(a)(1)).

The Occupational Safety and Health Administration (OSHA) has set this exception because employees engaged in inspecting, investigating and assessing workplace conditions before the actual work begins or after work has been completed are exposed to fall hazards for very short durations, if at all, since they most likely would be able to accomplish their work without going near the danger zone.

It is OSHA’s experience that such individuals, who are not continually or routinely exposed to fall hazards, tend to be very focused on their footing, ever alert, and aware of the hazards associated with falling.

OSHA says that employees who inspect, investigate, or assess workplace conditions will be more aware of their proximity to an unprotected edge than, for example, a roofer who is moving backwards while operating a felt laying machine, or a plumber whose attention is on overhead pipe and not on the floor edge.

Perform inspections regularly and as needed

• Inspections of all walking-working surfaces are required to be performed regularly and as necessary.
• If safety deficiencies are found, they must be corrected before workers can resume working on those surfaces.

Employers are required to conduct inspections of all walking-working surfaces, including those identified as having fall or falling object hazards or the potential for falls or falling objects.

An inspection is intended to identify and correct regulatory violations, reduce company liability, and promote good relations with workers.

Inspections must be conducted regularly and as necessary. The Occupational Safety and Health Administration (OSHA) uses a performance-based approach instead of mandating inspection frequency. This allows employers some flexibility to establish a schedule of how often inspections need to be done given circumstances and variables in the workplace.

The term “regularly” means that an employer has some type of schedule, formal or informal, for inspecting areas that is adequate to identify hazards. Once an employer makes this determination, OSHA expects the inspections to be conducted according to that frequency.

Subpart D also requires employers to conduct inspections “as necessary.” This means that inspections must be done when particular workplace conditions, circumstances, or events occur that warrant an additional check to ensure that they are safe for employees use. For example, if a forklift bumps a stairway, the stairs should be inspected.

If a deficiency is found, repairs must be made before employees are allowed to work in the area, or the hazard must be guarded until corrections or repairs are completed.

Although not required by OSHA, many employers find checklists helpful to ensure that critical compliance requirements and other items are not overlooked.

Protect workers from sides, edges, and hoist areas

• Employers must provide fall protection when an unprotected side or edge is four feet or more above a lower level, with some exceptions.

Employers are required to protect employees when an unprotected edge or side is four feet or more above a lower level.

Hoisting areas are any elevated opening that allows equipment or materials to be raised or lowered to another walking-working surface.

If the hoisting area or other edge is four feet or more above the lower level, employers must protect employees from falls by using:

• Guardrail systems
• Personal fall arrest systems
• Travel restraint systems

If a guardrail system is used but needs to be removed while the equipment or materials are being transferred, OSHA requires that any employee who is required to lean through or over the edge must wear personal fall protection.

Protect workers from holes and openings

• Employers must protect employees from the risk of falling through or into holes at the worksite.
• Types of holes may include skylights, stairway floor holes, ladderway holes, hatchways, and chutes.

The Occupational Safety and Health Administration (OSHA) requires employers to protect employees from falling through holes, including skylights. Holes less than four feet above a lower level need to be protected by a cover or guardrail system. When holes are four feet or more above a lower level, options include the following:

• Covers
• Guardrail systems
• Travel restraint systems
• Personal fall arrest systems

Stairway floor holes must use guardrail systems on all exposed sides, except the side at the stairway entrance. One exception is if the stairway hole is used less than once a day and is in cross traffic, the employer may use a hinged hole cover and removable guardrail system that protects on all sides except the stairway entrance.

Ladderway floor holes or ladderway platform holes must be protected by a guardrail system and toeboards, except at the entrance of the ladder, where a self-closing gate or offset is required.

Hatchways and chutes must be protected by one of the following:

• A hinged floor-hole cover and a fixed guardrail system that leaves only one exposed side. When not in use, the cover must be closed or a removable guardrail system provided on the exposed sides.
• A removable guardrail system and toeboards on not more than two sides of the hole and a fixed guardrail system on all other exposed sides. The removable guardrail system must be kept in place when the hole is not in use.
• A guardrail system or a travel restraint system when a work operation necessitates passing material through a hatchway or chute floor hole.

An opening is a gap or open space in a wall or vertical surface that is at least 30 inches high and 18 inches wide, through which an employee could fall to a lower level (such as a chute, window-wall, or temporary wall opening). Employers must ensure that each employee near an opening, including one with a chute attached, is protected by a guardrail system or other fall protection.

Fall protection is required when the bottom edge of the opening is less than 39 inches above the walking-working surface and the outside bottom edge of the opening is four feet or more above a lower level. Fall protection is not required when the bottom edge of a wall opening is 39 inches or more above the walking-working surface.

Employers are not allowed to use designated areas to protect employees from openings.

Use dockboards safely

• Employers must ensure that any dockboards used are secure and free from risk of equipment runoff.
• Workers walking or standing on a dockboard need fall protection at heights of four feet or more above a lower level, if a risk of falling exists.

Dockboards and runoff protection

The Occupational Safety and Health Administration (OSHA) requires that dockboards (i.e., bridge plates) be provided with a means, such as edging or curbing, to prevent equipment from running off the edge. This is intended to protect employees from injury if equipment falls off the edge of the dockboard.

Any dockboards put into service after January 17, 2017, must have runoff protection or curbing unless the employer can demonstrate there is no potential for material handling equipment to fall off the dockboard.

A forklift that runs off the side of a dockboard could kill or injure employees working on or near it, even if the fall is less than four feet. In addition, workers using hand trucks to load and unload materials from a truck could fall if there is no runoff guard to prevent the hand truck from running off the side. Runoff protection on many dockboards is simply a lip on the side that is bent 90 degrees from the horizontal portion of the dockboard.

Employers do not have to use dockboards equipped with runoff guards if there is no fall hazard. However, OSHA does not specify what size opening constitutes a runoff hazard. Employers must evaluate whether a particular opening poses a hazard, considering factors such as the type and size of transfer vehicle the worker is using.

For example, if a semi-trailer is backed into a loading dock and the sides of the trailer are touching the padded area around the door, there is likely no potential for runoff, so the dockboard should not need runoff protection.

To ensure the safety of dockboards, employers must also:

• Ensure that dockboards can support the maximum intended load.
• Secure portable dockboards from moving while being used by employees.
• Ensure that portable dockboards have handholds or another means for safe transport.
• Prevent the accidental movement of transport vehicles while they are being used by employees.

Dockboards and fall protection

Workers walking or standing on a dockboard need fall protection (in the form of a railing system) at heights of four feet or more above a lower level. For example, if a dockboard is used to span a gap of several feet between a rail car and a platform, and employees walk across the dockboard, a railing system may be needed to protect against falls.

A guardrail system or handrails are not required when three conditions are met: (a) dockboards are used solely for materials-handling operations using motorized equipment; (b) employees engaged in these operations are not exposed to fall hazards greater than 10 feet; and (c) those employees have been trained under 1910.30.

Use fall protection on and around dangerous equipment

• Employers must protect employees from the hazards of falling onto or into various types of dangerous equipment.

The Occupational Safety and Health Administration (OSHA) adopted the definition of dangerous equipment from the construction fall protection standard.

Dangerous equipment means equipment (such as pickling or galvanizing tanks, degreasing units, machinery, electrical equipment, and other units) which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment.

Additionally, OSHA includes vats, tanks, electrical equipment, machinery, machinery with protruding parts, or similar units to be dangerous equipment. These were added because their function or form could injure a falling worker.

The employer must require employees working four feet or more above dangerous equipment to use one of the following fall protection systems:

• Guardrail systems
• Safety net systems
• Travel restraint systems
• Personal fall arrest systems

Employees must be protected from falling into dangerous equipment even when the distance is less than four feet. Employers are not allowed to use safety net systems or personal fall arrest systems when work is less than four feet above the hazardous equipment. If the dangerous equipment is covered or guarded, OSHA does not require the use of fall protection.

Prevent falls in repair, service, and assembly pits

• Employees must be protected from falling into repair, service, and assembly pits.

The Occupational Safety and Health Administration (OSHA) believes that most workplace pits are used for vehicle repair, service, and assembly. The use of a fall protection system is not required for a repair pit, service pit, or assembly pit that is less than 10 feet deep, if the employer complies with these requirements:

• Limits access within 6 feet of the edge of the pit to authorized employees who have been trained per 1910.30.
• Posts readily visible caution signs that meet the requirements of 1910.145 and state “Caution—Open Pit.”
• Does one of the following:
  • Applies floor markings at least six feet from the edge of the pit in colors that contrast with the surrounding area.
  • Places a warning line at least six feet from the edge of the pit as well as stanchions that are capable of resisting, without tipping over, a force of at least 16 pounds applied horizontally against the stanchion at a height of 30 inches.
  • Places a combination of floor markings and warning lines at least six feet from the edge of the pit.

When two or more pits in a common area are not more than 15 feet apart, the employer may comply by placing contrasting floor markings at least 6 feet from the pit edge around the entire area of the pits.

Update fixed ladders to meet new safety requirements

• Employees must be protected from falls while using fixed ladders that extend more than 24 feet above a lower level.
• Regulations vary depending on whether the fixed ladder was installed before or after November 19, 2018. If before, employers have until November 19, 2036 to bring their equipment up to the current standard.

The Occupational Safety and Health Administration (OSHA)’s fall protection requirement applies to fixed ladders that extend more than 24 feet above a lower level. This is found in 1910.28(b)(9). Employees are not required to use fall protection when working on portable ladders, nor when using fixed ladders under 24 feet.

OSHA determines the height of a fixed ladder based on the total distance between the starting level and the top level or the total potential falling distance, regardless of whether the climb consists of several sections. For example, if a climb consists of two offset ladder sections of 20 feet each, the ladder needs fall protection because the total height is more than 24 feet. Similarly, if employees access a 16-foot fixed ladder from a point 10 feet above a lower level (creating a potential fall of 26 feet), OSHA considers that ladder to be more than 24 feet.

For existing fixed ladders that extend more than 24 feet above a lower level and were erected before November 19, 2018, an employer has until November 18, 2036, to equip the fixed ladder with a ladder safety or personal fall arrest system. State plan states may allow additional time based on the date that they adopted the OSHA regulation.

A fixed ladder that extends more than 24 feet above a lower level and was erected after November 19, 2018 must be equipped with a ladder safety system or personal fall arrest system.

The employer may use a cage or well in combination with a personal fall arrest system or ladder safety system, provided that the cage or well does not interfere with the operation of the system.

Cages and wells must be designed, constructed, and maintained:

• To permit easy access to and egress from the ladder.
• To contain employees in the event of a fall.
• To direct employees to a lower landing.

The employer must ensure ladder sections having a cage or well:

• Are offset from adjacent sections; and
• Have landing platforms provided at maximum intervals of 50 feet.

If an employer repairs or replaces any portion of a fixed ladder that is more than 24 feet above a lower level, the replacement is required to be equipped with a ladder safety or personal fall arrest system. However, non-structural repairs such as replacing a bolt or repairing a weld on a cage do not require upgrading the ladder.

Protect workers using mobile ladder stands

• Mobile ladder stands are subject to safety requirements that are in addition to the requirements for all ladders.
• Specific requirements will depend on the height of the stand or platform in relation to the lower level.

The mobile ladder stand and mobile ladder stand platform requirements are in addition to the requirements for all ladders. The Occupational Safety and Health Administration (OSHA) uses performance-based requirements for these units.

Mobile ladder stands and platforms must have handrails on both sides if the top step or platform height is four feet or more above the lower level. The handrail height must be a minimum 29.5 inches to a maximum 37 inches. The distance must be measured from the front edge of a step.

In some applications, OSHA allows removable gates or non-rigid members (such as chains) instead of handrails. For example, if an employee is required to place or remove boxes from a shelf, and a permanent handrail or guardrail system would create a fall risk or interfere with placing or removing the boxes, using a removable gate or chain may be safer. If an employer uses a removable gate or chain, the stand or platform must be placed in such a way so there is no gap between the unit and shelf that could result in a worker falling. After the task is complete, the gate or chain must be replaced.

Mobile ladder platforms with platform heights at least 4 feet and up to 10 feet must have handrails at least 36 inches high, and midrails.

Mobile ladder stands with a top step above 10 feet must have:

• Protection on three sides by handrails, midrails, and toeboards;
• Handrails that are at least 36 inches in height;
• A top step with a depth of at least 20 inches from front to back; and
• A standing area that is within the base frame.

Mobile ladder platforms above 10 feet must have guardrails that comply with 1910.29(b). They must also have toeboards that comply with 1910.29(k)(1) as follows:

• Have a height of 3.5 inches,
• Have a clearance above the platform not more than 0.25-inches,
• Be solid or have no gap that exceeds 1 inch, and
• Be capable of withstanding a force of at least 50 pounds, applied downward and outward.

Ensure stairway railings meet height requirements

• Height requirements for stair rail systems vary depending on when the system was installed.
• Additional requirements for stair rail systems include minimum clearance for fingers, smooth surfaces to avoid injury, and strength criteria.

Handrails must not be less than 30 inches and not more than 38 inches measured from the leading edge of the stair tread to the top surface of the handrail (see 1910.29(f)(1)(i) and Figure D-12 to section 1910.29).

Stair rail systems, which provide fall protection, must meet the following height criteria:

• For stair rail systems installed before January 17, 2017, the height must not be less than 30 inches from the leading edge of the stair tread to the top surface of the top rail, per 1910.29(f)(1)(ii)(A).
• For stair rail systems installed on or after January 17, 2017, the height must not be less than 42 inches from the leading edge of the stair tread to the top surface of the top rail, per 1910.29(f)(1)(ii)(B).

For systems installed prior to January 17, 2017, the top rail of a stair rail system may serve as a handrail only when:

• The height of the stair rail system is not less than 36 inches and not more than 38 inches as measured at the leading edge of the stair tread to the top surface of the top rail (see 1910.29(f)(1)(iii)(A) and Figure D-13 to section 1910.29).
• The top rail of the stair rail system meets the other handrail requirements in 1910.29(f).

Other criteria are found in 1910.29(f). These include:

• A minimum clearance for fingers between handrails and any other object of 2.25 inches.
• Handrails and stair rail systems that are smooth surfaced to protect employees from injury, and to prevent catching or snagging of clothing.
• No opening in a stair rail system that exceeds 19 inches at its least dimension.
• Handrails and the top rails of stair rail systems that are capable of withstanding, without failure, a force of at least 200 pounds applied in any downward or outward direction within 2 inches of any point along the top edge of the rail.

Use designated areas appropriately

• Designated areas allow employees to work on flat roofs within a specifically defined area without additional fall protection, provided certain standards for safety and training are met.

A designated area is a distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.

A good portion of the requirements for designated areas come from the construction standards. However, the Occupational Safety and Health Administration (OSHA) excluded the use of monitors, opting instead to require employers in general industry to erect warning lines.

Designated areas cannot be used on platforms or around floor openings or holes. A designated area may only be used:

• On flat or low-sloping roofs;
• If work is at least six feet from the roof edge;
• With the use of warning lines as defined;
• If holes or openings are protected by additional fall protection systems (i.e., guardrail systems); and
• By employees that are authorized by the employer and have completed the required training.

Employers that use designated areas must:

• Train employees who use the designated area on the proper care, inspection, storage, set up, and use of the equipment.
• Authorize employees to work in a designated area.
• Erect warning lines that delineate the designated area.
• Ensure that warning lines are visible throughout the designated area and from a minimum of 25 feet away.
• Ensure that warning lines meet the design requirements defined in General Industry Subpart D.
• Keep the designated area at least six feet from the roof’s edge.
• Use them only on low-sloping roofs.
• Not use them on platforms or around floor openings and holes.
• Ensure that work done within six feet of the roof edge uses other fall protection options (such as guardrail systems, safety net systems, and personal fall protection systems).

Protect workers on CMV trailers or tankers

• Federal agencies do not require fall protection for employees working on flatbeds, tankers and other commercial motor vehicles, or train cars.
• Even though it is not required, fall protection is a good idea for employees who work on these surfaces.

Even though drivers working on top of flatbeds, tankers, and other commercial motor vehicles (CMVs) face significant hazards, neither the Federal Motor Carrier Safety Administration (FMCSA) nor the Occupational Safety and Health Administration (OSHA) currently have standards directly addressing falls from CMVs. In fact, the OSHA Construction regulations specifically exclude vehicles and trailers from the definition of a walking-working surface. However, some standards (and common sense) apply.

OSHA has determined that fall protection is generally not required for drivers working on top of trailers. The key exception is if the employee is working on top of a vehicle that is positioned inside of or contiguous to a building or other structure where the installation of fall protection is feasible. In such cases it would be expected that the worker be provided with fall protection. OSHA published its position in an interpretation dated October 18, 1996.

Under OSHA’s “general duty clause” (section 5(a)(1) of the OSH Act):

• It is expected that employers will not force or allow employees to be on top of trailers if a situation exists that may lead to injury or death. An example of such a situation could be the presence of inclement weather, such as ice or rain, making the trailer catwalk slippery.
• Employers should make sure employees have been trained to minimize the risks and to perform their work safely.

Despite the federal standards (or lack thereof), common sense would dictate that fall protection is usually a good idea when working on a tractor or trailer. There is no standard method used for fall protection from CMVs, but a personal fall arrest system is recommended.

Protect workers from falling objects

• Employers must protect employees from the danger of being struck by objects falling from an overhead area.

The Walking-Working Surfaces rule requires that employers protect employees from being struck by objects falling from overhead. When workers are at risk the employer must take preventative steps, including:

• Requiring employees to wear head protection that meets the requirements of 1910 Subpart I;
• Erecting toeboards, screens, or guardrail systems;
• Erecting canopy structures;
• Keeping falling objects far from an edge, hole, etc., to prevent the object from falling to a lower level; or
• Barricading the area until the hazard is protected or eliminated.

Keep workers safe and working with hands-free travel restraint and positioning systems

• A travel restraint system protects workers from falling off an unprotected edge of an elevated walking-working surface.
• Positioning systems allow an employee to be protected from falls while still working with both hands free.

A travel restraint system eliminates the possibility of a worker falling from the unprotected edge of an elevated walking-working surface. The Occupational Safety and Health Administration (OSHA) requires that the restraint lines in the travel restraint systems be capable of sustaining a tensile load of at least 5,000 pounds.

Positioning systems allow an employee to be supported on an elevated vertical surface, such as a wall or windowsill, and work with both hands free. Positioning systems must meet the general design requirements that apply to all personal fall protection. Additionally, OSHA requires that all positioning systems must be capable of withstanding, without failure, a drop test consisting of a four-foot drop of a 250-pound weight.

Note: Window cleaners’ positioning systems must be capable of withstanding without failure a drop test consisting of a 6-foot drop of a 250-pound weight, and must limit the initial arresting force on the employee to not more than 2,000 pounds, with a duration not exceeding two milliseconds and any subsequent arresting forces to not more than 1,000 pounds.

Understand system-use criteria for personal fall arrest systems

• Personal fall arrest systems are designed to prevent employees from falling from an elevated work surface.
• OSHA sets criteria for the design and installation of personal fall protection systems.

Personal fall arrest systems must meet all the general personal fall protection design requirements and several additional design requirements, including:

• The maximum arresting force on the employee may only be up to 1,800 pounds.
• The system must bring the employee to a complete stop (the six-foot free fall distance) and limit the maximum deceleration distance to 3.5 feet. Therefore, the total maximum distance a worker may travel during a fall is 9.5 feet.
• The system must have sufficient strength to withstand twice the potential impact energy of the employee free fall distance of six feet, or the free fall distance allowed by the system.
• The system must be capable of keeping the worker within the system or strap configuration without making contact with the worker’s neck or chin area. This requires the employer to ensure that personal arrest systems properly fit each employee that uses it.

The Occupational Safety and Health Administration (OSHA) has developed system-use criteria for personal fall arrest systems. The criteria include the following:

• The device used to connect to a horizontal lifeline must be capable of locking in both directions. The horizontal lifeline may become a vertical lifeline if the support lines on one end fails. If this occurs and the locking device (i.e., grab rope) does not lock in both directions on the now-vertical lifeline, it could fail to hold the worker.
• The system must ensure that an employee cannot free fall more than six feet or make contact with a lower level. An employer may allow a free fall of more than six feet only if they can demonstrate that the manufacturer designed the system to allow a free fall of more than six feet and tested the system to ensure a maximum arresting force of 1,800 pounds is not exceeded.
• Body belts are not allowed as part of a personal fall arrest system.

Adhere to design requirements for personal fall protection systems

• Fall protection systems must meet several specific design requirements.
• Fall protection systems must be inspected any time they are subjected to impact, and not used again until the system is deemed safe.

Employers must ensure that each personal fall protection system meets the following design requirements:

• Connectors used in personal fall protection systems must be made of dropforged, pressed or formed steel, or equivalent material and have a corrosion-resistant finish. They must also have smooth surfaces and edges to prevent damage to interfacing parts of the fall protection system.
  Note: Employers must not allow employees to wear personal fall protection equipment if wear and tear reaches the point where the equipment performance might be compromised.
• Vertical lifelines are only designed to support one worker. Allowing additional workers to use the same vertical lifeline creates a hazard. For example, if more than one worker was attached to a vertical lifeline and one worker slipped, the other worker could also fall.
• Lanyards and vertical lifelines must have a minimum breaking strength of 5,000 pounds. Breaking strength is the point at which a lanyard or vertical lifeline will break because of the stress placed on it.
• Self-retracting lifelines/lanyards that allow free fall of more than two feet, ripstitch, and tearing and deforming lanyards must have a minimum tensile load of 5,000 pounds. If self-retracting lifelines/lanyards allow free fall of less than two feet, the minimum tensile load is 3,000 pounds.
• If an employer allows knots in lanyards and lifelines, a competent person or qualified person must inspect them before any employees use them, to ensure they still meet the minimum strength requirements.
• D-rings, snaphooks, and carabiners are devices used to connect or couple together components of personal fall protection systems. D-rings, snaphooks, and carabiners must:
  • Sustain a minimum tensile load of 5,000 pounds, and
  • Be proof tested to a minimum tensile load of 3,600 pounds without cracking, breaking, or incurring permanent deformation.
• The gate strength of snaphooks and carabiners must be proof-tested to 3,600 pounds.
• Snaphooks and carabiners must:
  • Be the automatic locking type that requires at least two separate, consecutive movements to open, and
  • Not be connected to any of the following unless specifically designed for such connections:
    • Webbing, rope, or wire rope;
    • Each other;
    • A D-ring to which another snaphook, carabiner, or connector is attached;
    • Any object that is incompatibly shaped or dimensioned in relation to the snaphook or carabiner so that the gate could accidentally be dislodged.
• Horizontal lifelines must:
  • Be designed, installed, and used under the supervision of a qualified person; and
  • Be part of a complete personal fall arrest system that maintains a safety factor of at least two.
• Anchorages must:
  • Be capable of supporting at least 5,000 pounds for each employee attached; or
  • Be designed, installed, and used under the supervision of qualified person, as part of a complete personal fall protection system that maintains a safety factor of at least two.
• Travel restraint lines must be capable of sustaining a tensile load of at least 5,000 pounds.
• Lifelines must not be made from natural fiber rope, and polypropylene rope must contain an ultraviolet light inhibitor.

Personal fall protection systems and their components must be used only for employee fall protection. They may not be used for hoisting any other equipment or materials.

Personal fall protection systems or equipment subject to impact must be immediately removed from service and not used again until a competent person can inspect the system or components. The competent person must determine if the system or components are still safe to use.

Know the OSHA regulations that govern fall protection

• Requirements for fall protection are found under 1926.501, 1926.502, and 1926.503.

Section 1926.501 has requirements for workplaces, conditions, operations, and circumstances where fall protection must be provided. In addition:

• Requirements for employees working on scaffolds are provided in Subpart L.
• Requirements for employees working on cranes and derricks are provided in Subpart CC.
• Requirements for employees performing steel erection work (except for towers and tanks) are provided in Subpart R.
• Requirements for employees working on certain types of equipment used in tunneling operations are provided in Subpart S.
• Requirements for employees engaged in the erection of tanks and communication and broadcast towers are provided in 1926.105.
• Requirements for employees working from aerial lifts or on poles, towers, or similar structures while engaged in the construction of electric transmission or distribution lines or equipment are provided in Subpart V.
• Requirements for employees working on stairways and ladders are provided in Subpart X.

Section 1926.502 sets the requirements for the installation, construction, and proper use of fall protection required by Part 1926, except as follows:

• Performance requirements for guardrail systems used on scaffolds and performance requirements for falling object protection used on scaffolds are provided in Subpart L.
• Performance requirements for stairways, stair rail systems, and handrails are provided in Subpart X.
• Additional performance requirements for fall arrest and work-positioning equipment are provided in Subpart V.
• Section 1926.502 does not apply to the erection of tanks and communication and broadcast towers. (Note: Section 1926.104 sets the criteria for body belts, lanyards and lifelines used for fall protection during tank and communication and broadcast tower erection.)
• Criteria for steps, handholds, ladders, and grabrails/guardrails/railings required by Subpart CC are provided in subpart CC. Sections 1926.502(a), (c) through (e), and (i) apply to activities covered under Subpart CC unless otherwise stated in subpart CC. No other paragraphs of 1926.502 apply to subpart CC.

Section 1926.503 sets requirements for training in the installation and use of fall protection systems, except in relation to steel erection activities, and the use of equipment covered by subpart CC.

Protect workers from falls with a workplace assessment and fall protection system selection

• Workplace assessment is the first step in evaluating whether work surfaces are safe to work on, and in selecting the proper fall protection options.
• Employees need appropriate training to recognize and avoid workplace hazards.
• Employers must also ensure that any contractors and subcontractors on site are using appropriate worksite safety measures.

To prevent falls, employers have a duty to anticipate the need to work at heights and plan work activities accordingly. Careful planning and preparation lay the necessary groundwork for an accident-free workplace.

Employers are required to assess the workplace to evaluate whether walking-working surfaces have the strength and structural integrity to safely support workers. Employees are not permitted to work on any surface until the surface is determined to be safe.

Once the surface is found to be safe for employees to work on, employers must determine whether any fall hazard is present. If so, the next step is to select one of the fall protection options for the particular work operation. Employers must make a reasonable effort to anticipate the particular hazards to which employees may be exposed in the course of a job. For example, employers should:

• Inspect the area to determine what hazards exist or may arise during work in that area.
• Identify hazards correctly and select the appropriate measures and equipment to eliminate the hazard.
• Communicate and coordinate with customers, other contractors (particularly at multi-employer worksites), and suppliers to ensure all workers at the site are safe.

Many employers minimize exposure to fall hazards by having anchorage points for personal fall arrest systems fabricated or designed into structural members and by installing perimeter lines on structural members before those members are lifted into position.

Employers may need to reexamine their traditional safety methods and, when possible, update them by incorporating available fall protection technology and design concepts. Employers should also:

• Give specific and appropriate instructions to prevent exposure to unsafe conditions.
• Ensure employees follow the procedures given and understand the training provided.
• Learn what safety efforts any specialty subcontractors have chosen to make in completing their assignments. Subcontractors have the reciprocal responsibility to determine what protective measures the employer, as the general contractor, has identified and implemented. This also holds true for multi-employer worksites.

Mitigate the dangers of unprotected sides and edges

• Employees must be protected from falls when they are working near unprotected edges or sides.
• There is no “safe” distance from a side or edge that would eliminate the need for fall protection.
• Employees must be protected from falls when they are working in a hoist area.
• If a guardrail system must be removed during hoisting operations, and employees are required to lean through the access opening, they must be protected with a personal fall arrest system.

Section 1926.501(b)(15) is a catch-all requirement intended to clarify the overall thrust of the duty to have fall protection. It sets forth clearly that all employees exposed to falls of six feet or more to lower levels must be protected by a guardrail system, safety net system, or personal fall arrest system, except where otherwise provided in 1926.501(b) or by fall protection standards in other Subparts of Part 1926. This provision will facilitate compliance for employers who do not fit any of the specific categories set by 1926.501(b).

Sides and edges

Employees must be protected from falls when they are exposed to unprotected sides and edges of walking-working surfaces (horizontal and vertical surfaces) that are six feet or more above lower levels. Options to mitigate this hazard include:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems

The Occupational Safety and Health Administration (OSHA) considers these three types of systems to be “conventional fall protection systems.” OSHA expects employers to implement a safety system early in the construction process and to maintain that system in place until all work has been completed or until the permanent elements of the structure, which will eliminate the exposure to falling hazards, are in place.

OSHA has determined that there is no “safe” distance from an unprotected side or edge that would render fall protection unnecessary.

Hoist areas

Each employee in a hoist area must be protected from falling six feet or more. Choices for this protection are:

• Guardrail systems
• Personal fall arrest systems

If guardrail systems (chain gate or guardrail) or portions thereof must be removed to facilitate hoisting operations, as during the landing of materials, and a worker must lean through the access opening or out over the edge of the access opening to receive or guide equipment and materials, that employee must be protected by a personal fall arrest system.

Formwork and reinforcing steel

Protect employees working on formwork and reinforcing steel six feet or more above lower levels by one of the following:

• Personal fall arrest system
• Safety net system
• Positioning device system

Equip ramps, runways, and other walkways with guardrails where employees could fall six feet or more to lower levels.

Implement a fall protection plan for leading edge work

• Employees must be protected from falls when they are working near leading edges.
• If the employer can demonstrate that the three primary methods are infeasible, the employer must create a fall protection plan that meets requirements set in 1926.502(k).

Like with unprotected sides and edges, workers who are constructing leading edges 6 feet or more above lower levels must be protected through one of these primary methods:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems

If the employer can demonstrate that it is infeasible or creates a greater hazard to implement these systems, it must develop and implement a fall protection plan that meets the requirements of 1926.502(k). 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 employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k).

The Occupational Safety and Health Administration (OSHA) considers a fall protection measure to be infeasible if the employer can establish that the application of that measure is either functionally unworkable or would prevent the performance of required work. OSHA recognizes that there are situations where one or another measure cannot be implemented because of the configuration of the worksite (for example, where structures are built so close together that nets cannot be installed) or due to circumstances during a particular phase of the construction process (for example, where work at the leading edge precludes the use of guardrails).

Protect workers from falling through holes and wall openings

• Employees must be protected from falling into, tripping over, or being hit by objects falling through holes.
• Employees must be protected from falling out or through wall openings.
• OSHA considers the guardrail system to be the most practical method of compliance in protecting against falls around wall openings.

Holes

Employees may be injured or killed if they step into holes, trip over holes, fall through holes, or are hit by objects falling through holes.

Employees on walking-working surfaces must be protected from:

• Falling into or through holes (including skylight openings) 6 or more feet above lower levels by covers over the hole, erecting a guardrail system around the hole, or by the use of a personal fall arrest system.
• Tripping into or stepping into or through holes (including skylights), by the use of covers.
• Being hit by objects falling through holes (including skylights) by the use of covers.

The Occupational Safety and Health Administration (OSHA) does not intend that a guardrail be erected around holes while employees are working at the hole, passing materials, etc. Therefore, if the cover is removed while work is in progress, guardrails are not required because they would interfere with the performance of work. When the work has been completed, the employer will be required to either replace the cover or erect guardrails around the hole.

Case law has established that brevity of exposure to a hazard is not a defense to a failure to protect against the hazard. Where the duty under 1926.501(b)1(4) applies, it must be complied with immediately.

Wall openings

Employees who are exposed to the hazard of falling out or through wall openings (including those with chutes attached) must be protected from falling by the use of one the following:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems

Wall openings are defined as openings 30 inches or more high and 18 inches or more wide, which have a bottom edge to lower level fall distance of six feet or more on the side away from employees, and a bottom edge to walking-working surface height of less than 39 inches on the side facing the employees.

The Occupational Safety and Health Administration (OSHA) believes the most practical method of compliance is the guardrail system because it provides protection at all times and for all employees who may have exposure at the wall opening. However, OSHA recognizes that there may be cases where safety net systems or personal fall arrest systems are preferred and will also provide an appropriate level of protection.

Barricade excavation sites to prevent falls

• Edges of excavations that are not readily seen should be protected by guardrails, fences, or barricades.
• Wells, pits, shafts and similar excavations should be protected when they are 6 feet deep or more.

Although employers are not generally required to provide guardrail systems at excavations, the rule requires that the edges of excavations which are not readily seen (such as one that is concealed from view by plant growth) be protected by guardrail systems, fences, or barricades to prevent employees from falling into them if the excavation depth is six feet or more.

In addition, wells, pits, shafts, and similar excavations with depths of six feet or more must be guarded to prevent employees from falling into them.

Use fall protection systems to protect workers against falls on and around dangerous equipment

• Employers must protect employees from the hazards of falling onto or into various types of dangerous equipment.

Employees working six feet or more above dangerous equipment must be protected from falling by one of the following systems:

• Guardrail systems
• Personal fall arrest systems
• Safety net systems

Where a floor, roof, or other walking-working surface is less than six feet above such hazards, protect employees with either guardrails or equipment guards that shield the hazard. Safety nets or personal fall arrest systems would not be appropriate at this height.

Dangerous equipment means equipment (such as pickling or galvanizing tanks, degreasing units, machinery, electrical equipment, and other units) which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment.

Implement fall protection for workers performing overhand bricklaying and related work

• Employers must protect employees from falls while performing overhand bricklaying and other related work.

Protect workers performing overhand bricklaying and related work six feet or more above lower levels by one of the following systems:

• Guardrail systems
• Personal fall arrest systems
• Safety net systems
• Controlled access zones

The exception to selecting one of these methods would be if another provision in 1926.501 provides for an alternative fall protection measure.

Note that controlled access zones are not permitted to be used as protection for employees performing overhand bricklaying and related work who are exposed to fall hazards located within the zone such as hoist areas, holes, ramps, runways, and other walkways, and dangerous equipment.

In these situations, fall protection must be provided by compliance with the sections addressing the specific hazard. For example, a worker performing overhand bricklaying work near a floor hole would have to be protected by the requirements for hole protection.

Related work, as used in this work scenario, means mason tending as well as electrical work that must be incorporated into the brick wall during the bricklaying process.

Employees who must reach more than 10 inches below the level of the walking-working surface on which they are working must be protected from falls through the use of one of the following:

• Guardrail systems
• Personal fall arrest systems
• Safety net systems

Use appropriate fall protection for workers on low slope and steep roofs

• Employees who are engaged in work on low-slope roofs with unprotected sides must be protected from falls.
• Employers must protect workers from falls while working on steep roofs (roofs with slopes greater than 4 to 12, vertical to horizontal)

Low slope roofs

Each employee engaged in roofing activities on low-slop roofs with unprotected sides and edges six feet or more above lower levels must be protected from falling by one of the following methods:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems
• A combination of:
  • Warning line and guardrail systems
  • Warning line and safety net systems
  • Warning line and personal fall arrest systems
  • Warning line safety monitoring systems

On roofs 50 feet or less in width, the use of a safety monitoring system alone is sufficient.

The exception to selecting one of these methods would be if another provision in 1926.501 provides for an alternative fall protection measure.

Appendix A in the regulations (Part 1926 Subpart M) provides guidance on how to correctly measure a roof that is not a rectangle.

Steep roofs

Employers are required to protect workers on roofs with slopes greater than 4 to 12 (vertical to horizontal) when the roof has unprotected sides or edges more than six feet above lower levels by the use of:

• Guardrail systems with toeboards
• Personal fall arrest systems
• Safety net systems

Roof jacks can be used as long as employees are protected from fall hazards by one of the above methods. While roof jacks provide a foothold that may reduce the possibility of falling, they cannot be used as a substitute for fall protection.

Protect workers from falls while erecting precast concrete

• Employees must be protected from falls when they are working on erecting precast concrete members.
• Precast concrete erection includes erection of wall panels, columns, beams, and more.

Employees erecting precast concrete members six feet or more above a lower level must be protected from falling by one of the following methods:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems

The exception to selecting one of these methods would be if another provision in 1926.501 provides for an alternative fall protection measure.

Precast concrete erection includes, but is 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.

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 employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k).

Protect workers in residential construction with guardrails, safety nets, or fall arrest systems

• Employees must be protected from falls during residential construction work.
• At least one fall protection method should be used. If employers find the conventional fall protection systems infeasible, employers should review whether a change in work procedures could eliminate or reduce fall hazards.
• OSHA does not expect home builders to erect scaffolds around the entire perimeter of a house, or to take other extremely burdensome measures during residential construction.

Employers engaged in residential construction work must protect employees from falls of six feet or more to lower levels using one of these three conventional fall protection systems:

• Guardrail systems
• Safety net systems
• Personal fall arrest systems

The exception to selecting one of these methods would be if another provision in 1926.501 provides for an alternative fall protection measure.

The Occupational Safety and Health Administration (OSHA) recognizes that some employers may find that it is infeasible or would create a greater hazard to provide and use conventional fall protection systems to protect employees. In these situations, OSHA suggests that employers review their building methods to determine if a change in work procedures could eliminate or reduce fall hazards.

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 employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k).

If an employer can demonstrate either infeasibility or greater hazard, it must implement alternative safe work practices, such as requiring work to be performed from ladders, scaffolds or other types of work platforms and prohibiting the practice of standing on the top plate of the walls to set roof trusses to the walls.

OSHA is aware that some builders assemble the roof system on the ground, either partially or entirely, and then lift it into place. OSHA would expect any fall protection plans developed to explain why such measures could not be implemented when other builders find them to be feasible alternatives.

OSHA believes that employees can be protected with conventional fall protection systems in virtually all situations involving residential construction work, but there may be some limited situations where the use of conventional fall protection systems is infeasible or would create a greater hazard. In those cases, OSHA has established a regulatory mechanism (fall protection plan) through which an employer who satisfies the pertinent criteria must implement a fall protection plan instead of providing conventional fall protection. While OSHA encourages creative solutions, OSHA does not expect employers (home builders) to pursue measures which would make their work unprofitable.

A number of devices are available for use as attachment points for fall arrest equipment, and employers must document why using such equipment is infeasible or creates a greater hazard. On the other hand, OSHA believes it would be unreasonable to expect the home builder to, for example, rent a crane when the home site is difficult to access or when the home builder has only a single roof to raise.

OSHA does not expect home builders to erect scaffolds around the entire perimeter of a house, or to take other extremely burdensome measures such as erecting separate structures and stringing a lifeline to use as an attachment point for personal fall arrest equipment. These measures would be considered infeasible.

Erect barriers to protect workers from falling objects

• Employers must protect workers against the danger of falling objects in the workplace.

In a workplace where employees are exposed to falling objects, employers must require each employee to wear a hard hat and must implement one of the following measures:

• Erect toeboards, screens, or guardrail systems to prevent objects from falling from higher levels;
• Erect a canopy structure and keep potential falling objects far enough from the edge of the higher level so that those objects would not go over the edge if they were accidentally moved; or
• Barricade the area into which objects could fall; prohibit employees from entering the barricaded area; and keep objects that may fall far enough away from the edge of a higher level so that those objects would not go over the edge if they were accidentally moved.

Know your role in protecting workers on communication towers

• Employees must be protected from falls while working on communication towers.
• The typical business structure of the communication tower industry means that responsibility for ensuring worker safety is fractured into many layers.
• Employers at all levels (from carriers to subcontractors) must play a role in ensuring the safety of their workers.

The business structure of the communication tower industry presents additional challenges to ensuring employee safety. When carriers own the towers and directly employ the workers who build and maintain the towers and the equipment on them, the carriers have the ability and incentive to ensure safe practices. Typically, however, the relationship between carriers and tower employees is more complicated. For example:

• Towers are often owned by separate corporations (not carriers, generally), and are built by contractors;
• Carriers often contract with “turfing vendors” for the installation and maintenance of equipment on towers;
• Turfing vendors, in turn, may hire other contractors to perform work; and
• These contractors may subcontract tower work to still-smaller employers.

As a result, carriers and tower owners may not know who is performing work for them, or when work is being performed. Thus, responsibility for employee safety is fractured into many layers. Instead of a single company having control and responsibility for employee safety and tower integrity, employer responsibilities can be spread over numerous small employers.

Additionally, the amount of communication tower work being performed waxes and wanes with waves of new technology. The work is physically demanding and requires employees to spend long periods of time away from home; this leads to short job tenure and turnover tends to be high. Considering these circumstances, ensuring employee safety requires accountability and diligence throughout the contracting process, all the way from the carrier to the individual employee performing the work.

Deliver training by a qualified person

• Safety training must be conducted by a competent person who has themselves been properly trained and qualified.

Training must be delivered by a competent person who is qualified in the following areas:

• The nature of fall hazards in the work area.
• The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used.
• The use and operation of controlled access zones; guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems; and other protection to be used.
• The role of each worker in the safety monitoring system when the system is used. The limitations on the use of mechanical equipment during the performance of roofing work on low-slope roofs.
• The correct procedures for equipment and materials handling and storage and the erection of overhead protection.
• The role of workers in fall protection plans.
• The fall protection requirements in 1926 Subpart M.

Use ladder safety systems to prevent falls

• Ladder safety systems are used to protect employees using fixed ladders over 24 feet.
• Ladder safety systems must meet specific requirements to ensure they provide sufficient fall protection.

A ladder safety system is a fall protection option that is permanently attached to a fixed ladder and is immediately adjacent to the ladder. The system must be designed to eliminate or reduce the possibility of falling from a ladder.

The ladder safety system is made up of two parts:

• The carrier, also called a lifeline, which is a rigid or flexible track attached to or adjacent to the fixed ladder; and
• A safety sleeve, which is a moving component that travels on the carrier.

A ladder safety system allows employees to climb up and down using both hands and must not require the employee to continuously hold, push, or pull any part of the system while climbing.

Additional requirements include:

• The connection between the carrier/lifeline and point of attachment to the body harness or belt cannot exceed 9 inches.
• Mountings for the rigid carriers are attached at each end of the carrier, with intermediate mountings spaced as necessary. This will provide the system the strength to stop a worker from falling.
• Mountings for flexible carriers are attached at each end of the carrier and cable guides and are installed at least 25 feet apart along the entire length of the carrier.
• The design and installation of the mountings and cable guides must not reduce the design strength of the ladder.
• The ladder safety system and support systems must be capable of withstanding, without failure, a drop test consisting of an 18-inch drop of a 500-pound weight.

Install self-closing gates or offsets at the tops of fixed ladders

• Employers must provide a self-closing gate or offset to keep workers from falling through ladderway holes.

The entrance at the top of a fixed ladder is considered a “hole” that must be guarded. Fall protection requirements for holes are found under 1910.28(b)(3). Paragraph (iii) requires that “each employee is protected from tripping into a ladderway floor hole or ladderway platform hole by a guardrail system and toeboards erected on all exposed sides, except at the entrance to the hole, where a self-closing gate or an offset must be used.”

Guardrail system requirements specific to holes are found in 1910.29(b)(13) which says, “when guardrail systems are used around holes that serve as points of access (such as ladderways), the guardrail system opening must have a self-closing gate...or is offset to prevent an employee from walking or falling into the hole.” All fixed ladder entrances that are four feet or more above a lower level must be guarded in this manner.

Safety chains are not allowed as fall protection at fixed ladder entrances. The Occupational Safety and Health Administration (OSHA) specifically addresses safety chains regarding fixed ladder openings in the preamble to the walking-working surfaces final rule by stating:

“... OSHA believes that chains are less protective than self-closing gates. Self-closing gates and offsets are passive fall protection methods that automatically restore guardrail protection as soon as the worker passes through the opening or offset area. Neither method requires the worker to take any action to restore that protection. However, if employers provide double chains at entrances to ladderway floor or platform holes, their employees would have to remove the chains and reattach them once they pass through the opening. If workers forget or fail to reattach the chains, they and others in the area could fall through the hole. Workers also are at increased risk of falling through the hole once they enter the area inside the guardrails to climb down the ladder because they have to turn around and away from the hole to reattach the chains and risk falling backward into the hole.”

Use designated areas only when allowed

• Designated areas are permitted only on flat or low-slope roofs, and only under certain conditions.
• Temporary and infrequent work describes work that is brief, such as equipment repair or inspections, that a worker can perform in less time that what is needed to set up temporary fall protection.

Designated areas are permitted only in limited situations. First, a designated area may be used if:

• Employees will be working at least 6 feet but less than 15 feet from the roof edge, and
• The work is both temporary and infrequent.

Second, if employees will be working 15 feet or more from the edge, a designated area may be used. At this distance, there is no requirement for the work to be temporary and infrequent.

Finally, if the work is both 15 feet or more from the edge AND the work is both temporary and infrequent, no fall protection is required (not even a designated area). In that case, the employer must implement and enforce rule prohibiting employees from going within 15 feet from the roof edge unless fall protection is provided and used.

Designated areas may NOT be used:

• On platforms;
• Around pits;
• Around unprotected roof holes or openings;
• Without the use of warning lines;
• Within six feet from the roof edge; or
• On roofs that do not meet the definition of low-sloping.

Temporary and infrequent

Generally, temporary and infrequent means short-term work (requiring no more than an hour or two) that is done only on occasion (such as once per month, or as needed). An example would be changing an air conditioner filter once per month.

The Occupational Safety and Health Administration (OSHA) defines temporary work as brief tasks, such as equipment repair or annual inspections that a worker is able to perform in less time than it takes to install or set up conventional fall protection. Additionally, OSHA considers a temporary task to be something that can be completed at one time rather than a task that requires repeatedly climbing up or returning to the roof, or requires more than one work shift to complete.

OSHA defines infrequent work as a task or job done only when needed (e.g., an equipment breakdown), on an occasional basis, or at sporadic or irregular intervals. OSHA provides the following examples:

• Annual maintenance or servicing of equipment;
• Monthly or quarterly replacement of batteries or HVAC filters; and
• Responding to equipment outage or breakdown.

If a task is performed on a daily basis, is a routine part of the job, or is repeated at various locations during the work shift, it does not meet the definition of infrequent. OSHA provides further clarification by stating, “A task may be considered infrequent when it is performed once a month, once a year, or when needed.”

Caution workers about safety hazards using warning lines

• Warning lines are used to delineate a designated area.
• Warning lines can consist of rope, wire, tape or chains, as long as certain criteria are met.

The term warning lines describes the barrier used on a roof to warn workers when they are approaching an unprotected side or edge. Warning lines delineate a designated area in which employees may work without additional fall protection. Warning lines can consist of rope, wire, tape, or chains that meet the following requirements:

• Have a minimum breaking strength of 200 pounds.
• Are, at their lowest point, including the sag, not less than 34 inches and not more than 39 inches above the walking-working surface.
• Are supported so that if one section of the line is pulled it will not take up slack in an adjacent section, causing the line to fall below the limits specified above.
• Are visible from a distance of 25 feet.
• Are erected as close to the work as possible without interfering with the tasks.
• Are erected no closer than 6 feet from the roof edge for work that is temporary and infrequent.
• Are erected no closer than 15 feet from the roof edge for work that is NOT temporary and infrequent.