Is fall protection required at the edge of a roof when getting on it until a worker is more than 6 feet from the edge if using a designated area?

The area at the top or edge of the roof used in conjunction with a designated area is called the “access path.” In the 2010 proposed walking-working surfaces rule, OSHA included a provision for employers to provide clear access paths to designated areas. The proposal specified that the path have warning lines on both sides attached to stanchions to help guide employees to the designated area from the point of roof access (e.g., the top of a fixed ladder). OSHA requested comment on whether this proposed requirement was necessary to protect workers when they travel to and from designated areas from roof edge hazards.

One commenter stated that an access path is not necessary because employees do not trip or fall when traversing to and from the access ladder in their experience of using designated areas on roofs.

Based on this comment, and others in the preamble to the final rule, OSHA removed the proposed access path provision but stresses that employers still must train workers “about potential fall hazards in the work area, which includes accessing the work area ...”

Based on this information, employers do not have to provide fall protection at the roof edge when accessing the roof to work in a designated area.