Before the updated Walking-Working Surfaces rule, general industry employers’ only choices for roof fall protection were guardrails or personal fall protection systems (i.e., personal fall arrest systems, travel restraint systems, and safety nets). The revised rule allows general industry an additional option for low-sloping roofs – designated areas.
OSHA states in the Walking-Working Surfaces preamble, “Designated areas are not conventional fall protection systems or engineering controls. Designated areas are alternative fall protection methods that are effective only when set up and used correctly and safely.” The key to safe use of the designated area is proper delineation and keeping workers within the area. This makes training an essential part of designated area use.
A good portion of the requirements for designated areas come from the construction standards. However, OSHA excluded the use of monitor, opting instead to require employers in general industry to erect warning lines.
Designated areas apply to all general industry employers that temporarily and infrequently work on low-sloping roofs. Designated areas cannot be used on platforms or around floor openings or holes.
- 29 CFR 1910.21 — Scope and definitions.
- 29 CFR 1910.28 — Duty to have fall protection and falling object protection.
- 29 CFR 1910.29 — Fall protection systems and Falling objects protection-criteria and practices.
- 29 CFR 1910.30 — Training.
- Designated area: A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection.
- Fall hazard: Any condition on a walking-working surface that exposes an employee to a risk of harm from a fall on the same level or to a lower level.
- Fall protection: Any equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall.
- Guardrail system: A barrier erected along an unprotected or exposed side, edge, or other area of a walking-working surface to prevent employees from falling to a lower level.
- Hole: A gap or open space in a floor, roof, horizontal walking-working surface, or similar surface that is at least 2 inches (5 cm) in its least dimension.
- Low-slope roof: A roof that has a slope less than or equal to a ratio of 4 in 12 (vertical to horizontal).
- Opening: A gap or open space in a wall, partition, vertical walking-working surface, or similar surface that is at least 30 inches (76 cm) high and at least 18 inches (46 cm) wide, through which an employee can fall to a lower level.
- Unprotected sides and edges: Any side or edge of a walking-working surface (except at entrances and other points of access) where there is no wall, guardrail system, or stair rail system to protect an employee from falling to a lower level.
- Walking-working surface: Any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location.
- Warning line: A barrier erected to warn employees that they are approaching an unprotected side or edge, and which designates an area in which work may take place without the use of other means of fall protection.
Summary of requirements
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 a minimum of 25 feet away.
- Ensure that that warning lines meet the construction requirements defined in Subpart D.
- Keep the designated area at least 6 feet from the roof’s edge.
- Use only on low-sloping roofs.
- Not use on platforms or around floor openings and holes.
- Inspect designated areas.
- Only use for work at least 15 feet from the edge, or for temporary and infrequent work that is at least 6 feet but less than 15 feet from the edge.
- Ensure that work done closer than 6 feet use additional fall protection options (i.e., guardrail systems, safety net systems, and personal fall protection systems).