OSHA FACT SHEET (Fall Protection)

I am not trying to sound like a OSHA Guru,I think its important for everyone to understand the new and existing requirements.Alot of good companies here on roofing.com (IMO) and I have seen these fines and they are VERY ugly.

I would hate to hear of anyone at roofing.com having been slapped with a ridiculous fine.They are not playing around.These hefty fines can shut you down if caught.You MUST abide by existing requirements and you HAVE to attempt to abide by the new.If you are caught not using existing and not applying the new you WLL be fined.90day phase in or not.The attempt MUST be made.

Also if they walk up on you and go over what you are doing wrong with the new and as long as you are using existing you will NOT be fined.However they issue an alert sheet then IF they catch you again repeating what they have alerted you about you WILL be fined.

OSHA Fact Sheet For New fall Protection Requirements

The United States Department of Labor’s
Occupational Safety and Health Administration
(OSHA) has issued a directive rescinding the
Interim Fall Protection Compliance Guidelines for
Residential Construction (STD 03-00-001).
Before issuance of this new directive, STD 03-00-
001 allowed employers engaged in certain
residential construction activities to use specified
alternative methods of fall protection (e.g., slide
guards or safety monitor systems) rather than
the conventional fall protection (guardrails, safety
nets, or personal fall arrest systems) required
by the residential construction fall protection
standard (29 CFR 1926.501(b)(13)). Employers
could use the alternative measures described in
STD 03-00-001 without first proving that the use
of conventional fall protection was infeasible or
created a greater hazard and without a written fall
protection plan.

With the issuance of the new directive, all residential
construction employers must comply with 29
CFR 1926.501(b)(13).
• Residential construction employers generally
must ensure that employees working six feet or
more above lower levels use guardrails, safety
nets, or personal fall arrest systems. A personal
fall arrest system may consist of a full body
harness, a deceleration device, a lanyard, and
an anchor point. (See the definition of “personal
fall arrest system” in 29 CFR 1926.500.)

• Other fall protection measures may be used
to the extent allowed under other provisions
of 29 CFR 1926.501(b) addressing specific
types of work. For example, 1926.501(b)(10)
permits the use of warning lines and safety
monitoring systems during the performance
of roofing work on low-sloped roofs.

• OSHA allows the use of an effective fall
restraint system in lieu of a personal fall
arrest system. To be effective, a fall restraint
system must be rigged to prevent a worker
from reaching a fall hazard and falling over
the edge. A fall restraint system may consist
of a full body harness or body belt that is
connected to an anchor point at the center of
a roof by a lanyard of a length that will not
allow a worker to physically reach the edge
of the roof.

• If the employer can demonstrate that use of
conventional fall protection methods is infeasible
or creates a greater hazard, it must ensure
that a qualified person:

• Creates a written, site-specific fall protection
plan in compliance with 29 CFR 1926.502(k);
and

• Documents, in that plan, the reasons why
conventional fall protection systems are
infeasible or why their use would create a
greater hazard.
The new directive interprets “residential construction”
as construction work that satisfies both of
the following elements:

• The end-use of the structure being built must
be as a home, i.e., a dwelling.

• The structure being built must be constructed
using traditional wood frame construction
materials and methods. The limited use of
structural steel in a predominantly woodframed
home, such as a steel I-beam to help
support wood framing, does not disqualify a
structure from being considered residential
construction.

• Traditional wood frame construction materials
and methods will be characterized by:
Framing materials: Wood (or equivalent
cold-formed sheet metal stud) framing, not
steel or concrete; wooden floor joists and
roof structures.
Exterior wall structure: Wood (or equivalent
cold-formed sheet metal stud) framing
or masonry brick or block.
Methods: Traditional wood frame
construction techniques.

Definition of “residential construction.”
Under STD 03-00-001, a project was considered residential construction “where the working
environment, materials, methods and procedures [we]re essentially the same as those used
in building a typical single-family home or townhouse.” OSHA explained that for purposes of
the directive, residential construction was characterized by wood framing and wooden floor
joists and roof structures and involved traditional wood frame construction techniques. A
discrete part of a large commercial building, e.g., a wood frame, shingled entranceway to a
mall, could fall under the definition of residential construction if the aforementioned
characteristics were present. This definition was always intended to clarify the scope of the
directive; it was not meant to represent OSHA’s view of the scope of 1926.501(b)(13). Now
that OSHA is rescinding the directive, the Agency believes that adopting a clear interpretation
of “residential construction” for purposes of 1926.501(b)(13) will facilitate enforcement as
well as compliance efforts.
In the 1999 ANPR, OSHA requested comments on the definition of “residential construction.”
OSHA has considered the comments received in response to that request (see discussion
below). The Agency is adopting an interpretation of “residential construction” that reflects
what it originally intended when it promulgated the provision specific to “residential
construction” in 1994. The Agency’s interpretation of “residential construction” for purposes of
1926.501(b)(13) combines two elements – both of which must be satisfied for a project to fall
under that provision: (1) the end-use of the structure being built must be as a home, i.e., a
dwelling; and (2) the structure being built must be constructed using traditional wood frame
construction materials and methods (although the limited use of structural steel in a
predominantly wood-framed home, such as a steel I-beam to help support wood framing,
does not disqualify a structure from being considered residential construction).

A. Residence Requirement.
To fall within the definition of “residential construction,” the end-use of the building
in question must be as a home or dwelling. This comports with the plain meaning of
the term “residential” in the text of 1926.501(b)(13) and is consistent with OSHA’s
original intent in promulgating that provision.
OSHA received several comments in response to the ANPR that recommended
excluding an end-use requirement from the definition of residential construction. The
NAHB (Ex. 3-2453) asked OSHA not to “make an arbitrary and capricious assessment
that the end-use of the structure has any correlation to the hazard to which an
employee may be exposed or the type of fall protection systems that can be used.”
The NRCA (OSHA-S206C-2006-0924-0189) agreed, commenting that “emphasis
should be placed on the best way to protect workers, not on the building’s use.”
Other commenters supported the positions of the NCRA and the NAHB. And in
December 2009, ACCSH recommended a definition of “residential construction” that
would have covered the building of non-residential structures where the
environment, methods, materials and procedures used were similar to those used to
build single-family residences. (OSHA-2009-0030-0024.)
OSHA has given these comments full consideration; however, the Agency has
decided that an end-use requirement is necessary to comport with the plain language
of 1926.501(b)(13) and OSHA’s intent in promulgating that provision. In the original
Subpart M rulemaking, various commenters on the proposed rule urged OSHA to
establish unique fall protection requirements for “the residential/light commercial
sector” or for “residential and light commercial construction.” (59 FR at 40693.) For
example, the Home Builders Association of Denver (HBAD) commented that “a
majority of residential builders also perform some amount of light commercial work
and [suggested that] the two types of construction should be categorized [and
treated together] as ‘light construction.’” (59 FR at 40693.) Other commenters
specifically urged OSHA to distinguish light construction from heavy commercial
construction. OSHA responded that evidence did not warrant having different rules
for light and heavy construction. (59 FR at 40695.) And while OSHA was aware of
terms like “light construction,” which avoid reference to the use of the structure and
instead create a category of building defined solely by materials and methods, it
declined to use such terms in the text of 1926.501(b)(13) and elected to use the
phrase “residential construction” instead. This approach reflected an intent by the
Agency to limit the applicability of that paragraph to structures with a residential enduse,
i.e., dwellings.

B. Wood Frame Construction Requirement.
To fall within the definition of “residential construction,” the building in question must
be constructed using traditional wood frame construction materials and methods. All
of the comments received during the original Subpart M rulemaking that suggested
feasibility problems with conventional fall protection dealt with wood framing work.
(59 FR at 40693-40695.) Therefore, the term “residential construction” in
1926.501(b)(13) was designed to apply only to the construction of homes using
traditional wood frame construction materials and methods. This includes the
construction of otherwise covered residences if there is limited use of structural steel
in a predominantly wood-framed home, such as a steel I-beam to support wood
framing.
Recently it has become more common to use metal studs for framing in residential
construction rather than wood. Some commenters to the ANPR believed that the use
of metal studs for framing should be included in the definition of residential
construction. (See, e.g., NAHB (Ex. 3-2453); NRCA (OSHA-S206C-2006-0924-0189).)
Furthermore, at its December 2009 meeting, ACCSH recommended a definition of
residential construction that listed metal studs, along with wood, as materials used
for framing. (See OSHA-2009-0030-0024.) OSHA agrees with the commenters and
ACCSH on this point. The same feasibility concerns that apply to wood framing apply
to framing done using metal studs. Accordingly, OSHA will consider it within the
bounds of “traditional wood frame construction materials and methods” to use coldformed
sheet metal studs in framing.
And finally, OSHA is aware that many homes and townhouses, especially in the
southern and southwestern regions of the country, have usually been built using
traditional wood frame construction throughout the structure except for the exterior
walls, which are often built with masonry brick or block. In a March 27, 2006, letter,
the NAHB advocated for masonry block construction to be treated as wood frame
construction because “masonry block wall construction has the equivalent strength of
traditional wood frame, stick-built walls.” Because the same fall protection methods
are likely to be used in the construction of homes built with wood framed and
masonry brick or block exterior walls, the Agency has decided that it is consistent
with the original purpose of 1926.501(b)(13) to treat the construction of residences
with masonry brick or block in the exterior walls as residential construction.
In accord with the discussion above, and for purposes of the interpretation of
“residential construction” adopted herein, “traditional wood frame construction
materials and methods” will be characterized by:
Framing materials: Wood (or equivalent cold-formed sheet metal stud) framing, not
steel or concrete; wooden floor joists and roof structures.
Exterior wall structure: Wood (or equivalent cold-formed sheet metal stud) framing
or masonry brick or block.
Methods: Traditional wood frame construction techniques.

C. Nursing homes, hotels, and similar facilities.
As noted above, to fall within the definition of “residential construction,” the end use
of the building must be as a home or dwelling and the building must be constructed
using traditional wood frame construction materials and methods. Construction of
nursing homes, hotels, and similar facilities typically involves the use of the following
materials in the framework of the structure: precast concrete, steel I-beams (beyond
the limited use of steel I-beams in conjunction with wood framing, described above),
rebar, and/or poured concrete. These materials are not used in traditional wood
frame construction, and buildings constructed using these materials will not be
considered “residential construction” for purposes of 1926.501(b)(13). For this
reason, OSHA expects that in the vast majority of cases the Compliance Safety and
Health Officer (CSHO) will be able to readily ascertain that the building of structures
such as hotels, motels, and nursing homes is not “residential construction,” as that
term is interpreted in this directive. However, if a CSHO encounters an unusual
situation in which a project such as a hotel, motel, or nursing home is being
constructed using traditional wood frame construction materials and methods, he or
she should contact the Directorate of Construction, Office of Construction Standards
and Guidance, at the address listed above, by telephone at (202)693-2020, or by
facsimile at (202)693-1689, for assistance.

XI. Citation Policy.
A. If an employer is engaged in residential construction, but does not provide guardrail
systems, safety net systems, personal fall arrest systems, or other fall protection
allowed under 1926.501(b), a citation for violating 1926.501(b)(13) should be issued
unless the employer can demonstrate the infeasibility of these protective measures or
the existence of a greater hazard. If the employer demonstrates infeasibility or a
greater hazard, the CSHO must determine if the employer has implemented a fall
protection plan meeting the requirements of 1926.502(k). Part of that determination
will be based on whether the employer has instituted alternative measures to reduce
or eliminate fall hazards.

B. Under STD 03-00-001, the employer was not required to have a fall protection plan
that was written and site-specific. With the cancellation of STD 03-00-001, fall
protection plans under 1926.502(k) must be written and site-specific. If the fall
protection plan is not written, site-specific, or otherwise fails to meet the
requirements of 1926.502(k), the violation should be cited as a grouped citation of
1926.501(b)(13) and 1926.502(k). A written plan developed for repetitive use for a
particular style/model home will be considered site-specific with respect to a
particular site only if it fully addresses all issues related to fall protection at that site.

C. See CPL 02-00-111, Citation Policy for Paperwork and Written Program Requirement
Violations, November 27, 1995, for additional guidance when citing violations of the
requirement for a written fall protection plan in 1926.501(b)(13) and 1926.502(k).

XII. Outreach.
OSHA will begin enforcement activities on or after June 16, 2011. OSHA will publish a notice
in the Federal Register giving notice that STD 03-00-001 has been rescinded and new
compliance guidance has been issued. Prior to the effective date, OSHA will undertake various
outreach efforts. A press release from the Office of Communications will also be published to
notify the public of this policy change. OSHA will also present a webinar explaining the change
in policy contained in this directive. Using the information from webinar, regional and area
offices will conduct appropriate outreach efforts.

• Part Number: 1926
• Part Title: Safety and Health Regulations for Construction
• Subpart: M
• Subpart Title: Fall Protection
• Standard Number: 1926.501
• Title: Duty to have fall protection.


1926.501(a)

“General.”

1926.501(a)(1)

This section sets forth requirements for employers to provide fall protection systems. All fall protection required by this section shall conform to the criteria set forth in 1926.502 of this subpart.

1926.501(a)(2)

The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.

1926.501(b)

1926.501(b)(1)

“Unprotected sides and edges.” Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

…1926.501(b)(2)

1926.501(b)(2)

“Leading edges.”

1926.501(b)(2)(i)

Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: 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) for a particular workplace situation, in lieu of implementing any of those systems.

1926.501(b)(2)(ii)

Each employee on a walking/working surface 6 feet (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, shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system. If a guardrail system is chosen to provide the fall protection, and a controlled access zone 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.

1926.501(b)(3)

“Hoist areas.” Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail] or portions thereof, are removed to facilitate the hoisting operation (e.g., during landing of materials), and an employee must lean through the access opening or out over the edge of the access opening (to receive or guide equipment and materials, for example), that employee shall be protected from fall hazards by a personal fall arrest system.

…1926.501(b)(4)

1926.501(b)(4)

“Holes.”

1926.501(b)(4)(i)

Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.

1926.501(b)(4)(ii)

Each employee on a walking/working surface shall be protected from tripping in or stepping into or through holes (including skylights) by covers.

1926.501(b)(4)(iii)

Each employee on a walking/working surface shall be protected from objects falling through holes (including skylights) by covers.

1926.501(b)(5)

“Formwork and reinforcing steel.” Each employee on the face of formwork or reinforcing steel shall be protected from falling 6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or positioning device systems.

1926.501(b)(6)

“Ramps, runways, and other walkways.” Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8 m) or more to lower levels by guardrail systems.

1926.501(b)(7)

“Excavations.”

1926.501(b)(7)(i)

Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from falling by guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth or other visual barrier;

…1926.501(b)(7)(ii)

1926.501(b)(7)(ii)

Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8 m) or more in depth shall be protected from falling by guardrail systems, fences, barricades, or covers.

1926.501(b)(8)

“Dangerous equipment.”

1926.501(b)(8)(i)

Each employee less than 6 feet (1.8 m) above dangerous equipment shall be protected from falling into or onto the dangerous equipment by guardrail systems or by equipment guards.

1926.501(b)(8)(ii)

Each employee 6 feet (1.8 m) or more above dangerous equipment shall be protected from fall hazards by guardrail systems, personal fall arrest systems, or safety net systems.

1926.501(b)(9)

“Overhand bricklaying and related work.”

1926.501(b)(9)(i)

Except as otherwise provided in paragraph (b) of this section, each employee performing overhand bricklaying and related work 6 feet (1.8 m) or more above lower levels, shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or shall work in a controlled access zone.

1926.501(b)(9)(ii)

Each employee reaching more than 10 inches (25 cm) below the level of the walking/working surface on which they are working, shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system.

Note: Bricklaying operations performed on scaffolds are regulated by subpart L - Scaffolds of this part.

…1926.501(b)(10)

1926.501(b)(10)

“Roofing work on Low-slope roofs.” Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall 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 Appendix A to subpart M of this part), the use of a safety monitoring system alone * is permitted.

1926.501(b)(11)

“Steep roofs.” Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.

1926.501(b)(12)

“Precast concrete erection.” 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 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems, unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: 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) for a particular workplace situation, in lieu of implementing any of those systems.

…1926.501(b)(13)

1926.501(b)(13)

“Residential construction.” Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: 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) for a particular workplace situation, in lieu of implementing any of those systems.

1926.501(b)(14)

“Wall openings.” Each employee working on, at, above, or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet (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, shall be protected from falling by the use of a guardrail system, a safety net system, or a personal fall arrest system.

1926.501(b)(15)

“Walking/working surfaces not otherwise addressed.” Except as provided in 1926.500(a)(2) or in 1926.501 (b)(1) through (b)(14), each employee on a walking/working surface 6 feet (1.8 m) or more above lower levels shall be protected from falling by a guardrail system, safety net system, or personal fall arrest system.

1926.501(c)

“Protection from falling objects.” When an employee is exposed to falling objects, the employer shall have each employee wear a hard hat and shall implement one of the following measures:

1926.501(c)(1)

Erect toeboards, screens, or guardrail systems to prevent objects from falling from higher levels; or,

…1926.501(c)(2)

1926.501(c)(2)

Erect a canopy structure and keep potential fall objects far enough from the edge of the higher level so that those objects would not go over the edge if they were accidentally displaced; or,

1926.501(c)(3)

Barricade the area to 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 displaced.

[59 FR 40732, Aug. 9, 1994; 60 FR 5131, Jan. 26, 1995]

• Part Number: 1926
• Part Title: Safety and Health Regulations for Construction
• Subpart: R
• Subpart Title: Steel Erection
• Standard Number: 1926 Subpart R App G
• Title: 1926.502 (b)-(e) Fall Protection Systems Criteria and Practices.


Appendix G to Subpart R – § 1926.502 (b)-(e) Fall Protection Systems Criteria and Practices

(b)

“Guardrail systems.” Guardrail systems and their use shall comply with the following provisions:

(b)(1)

Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria of this paragraph (§ 1926.502(b)).

Note: When employees are using stilts, the top edge height of the top rail, or equivalent member, shall be increased an amount equal to the height of the stilts.

(b)(2)

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural members shall be 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.

(b)(2)(i)

Midrails, when used, shall be installed at a height midway between the top edge of the guardrail system and the walking/working level.

(b)(2)(ii)

Screens and mesh, when used, shall extend from the top rail to the walking/working level and along the entire opening between top rail supports.

(b)(2)(iii)

Intermediate members (such as balusters), when used between posts, shall be not more than 19 inches (48 cm) apart.

(b)(2)(iv)

Other structural members (such as additional midrails and architectural panels) shall be installed such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

(b)(3)

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (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.

(b)(4)

When the 200 pound (890 N) test load specified in paragraph (b)(3) of this section (§ 1926.502) is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the walking/working level. Guardrail system components selected and constructed in accordance with the appendix B to subpart M of this part will be deemed to meet this requirement.

(b)(5)

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N) applied in any downward or outward direction at any point along the midrail or other member.

(b)(6)

Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or lacerations, and to prevent snagging of clothing.

(b)(7)

The ends of all top rails and midrails shall not overhang the terminal posts, except where such overhang does not constitute a projection hazard.

(b)(8)

Steel banding and plastic banding shall not be used as top rails or midrails.

(b)(9)

Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-foot intervals with high-visibility material.

(b)(10)

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall be placed across the access opening between guardrail sections when hoisting operations are not taking place.

(b)(11)

When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of the hole.

(b)(12)

When guardrail systems are used around holes used for the passage of materials, the hole shall have not more than two sides provided with removable guardrail sections to allow the passage of materials. When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall be provided along all unprotected sides or edges.

(b)(13)

When guardrail systems are used around holes which are used as points of access (such as ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into the hole.

(b)(14)

Guardrail systems used on ramps and runways shall be erected along each unprotected side or edge.

(b)(15)

Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this section (§ 1926.502).

(c)

Safety net systems. Safety net systems and their use shall comply with the following provisions:

(c)(1)

Safety nets shall be installed as close as practicable under the walking/working surface on which employees are working, but in no case more than 30 feet (9.1 m) below such level. When nets are used on bridges, the potential fall area from the walking/working surface to the net shall be unobstructed.

(c)(2)

Safety nets shall extend outward from the outermost projection of the work surface as follows:

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 feet
More than 5 feet up to 10 feet
More than 10 feet 8 feet
10 feet
13 feet

(c)(3)

Safety nets shall be 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 paragraph (4) of this section § 1926.502].

(c)(4)

Safety nets and their installations shall be capable of absorbing an impact force equal to that produced by the drop test specified in paragraph (c)(4)(i) of this section § 1926.502].

(c)(4)(i)

Except as provided in paragraph (c)(4)(ii) of this section (§ 1926.502), safety nets and safety net installations shall be drop-tested at the jobsite after initial installation and before being used as a fall protection system, whenever relocated, after major repair, and at 6-month intervals if left in one place. The drop-test shall consist of a 400 pound (180 kg) bag of sand 30+ or -2 inches (76+ or -5 cm) in diameter dropped into the net from the highest walking/working surface at which employees are exposed to fall hazards, but not from less than 42 inches (1.1 m) above that level.

(c)(4)(ii)

When the employer can demonstrate that it is unreasonable to perform the drop-test required by paragraph (c)(4)(i) of this section (§ 1926.502), the employer (or a designated competent person) shall certify that the net and net installation is in compliance with the provisions of paragraphs (c)(3) and (c)(4)(i) of this section (§ 1926.502) by preparing a certification record prior to the net being used as a fall protection system. The certification record must include 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 with paragraph (c)(3) of this section (§ 1926.502) and the signature of the person making the determination and certification. The most recent certification record for each net and net installation shall be available at the jobsite for inspection.

(c)(5)

Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear, damage, and other deterioration. Defective components shall be removed from service. Safety nets shall also be inspected after any occurrence which could affect the integrity of the safety net system.

(c)(6)

Materials, scrap pieces, equipment, and tools which have fallen into the safety net shall be removed as soon as possible from the net and at least before the next work shift.

(c)(7)

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor be longer than 6 inches (15 cm) on any side, and the opening, measured center-to-center of mesh ropes or webbing, shall not be longer than 6 inches (15 cm). All mesh crossings shall be secured to prevent enlargement of the mesh opening.

(c)(8)

Each safety net (or section of it) shall have a border rope for webbing with a minimum breaking strength of 5,000 pounds (22.2 kN).

(c)(9)

Connections between safety net panels shall be as strong as integral net components and shall be spaced not more than 6 inches (15 cm) apart.

(d)

“Personal fall arrest systems.” Personal fall arrest systems and their use shall comply with the provisions set forth below. Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system.

Note: The use of a body belt in a positioning device system is acceptable and is regulated under paragraph (e) of this section (§ 1926.502).

(d)(1)

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials.

(d)(2)

Connectors shall have a corrosion-resistant finish, and all surfaces and edges shall be smooth to prevent damage to interfacing parts of the system.

(d)(3)

Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds (22.2 kN).

(d)(4)

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or taking permanent deformation.

(d)(5)

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected member, or shall be a locking type snaphook designed and used to prevent disengagement of the snaphook by the contact of the snaphook keeper by the connected member. Effective January 1, 1998, only locking type snaphooks shall be used.

(d)(6)

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged:

(d)(6)(i)

directly to webbing, rope or wire rope;

(d)(6)(ii)

to each other;

(d)(6)(iii)

to a dee-ring to which another snaphook or other connector is attached;

(d)(6)(iv)

to a horizontal lifeline; or

(d)(6)(v)

to any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional disengagement could occur by the connected object being able to depress the snaphook keeper and release itself.

(d)(7)

On suspended scaffolds or similar work platforms with horizontal lifelines which may become vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking in both directions on the lifeline.

(d)(8)

Horizontal lifelines shall be designed, installed, and used, under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two.

(d)(9)

Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN).

(d)(10)(i)

Except as provided in paragraph (d)(10)(ii) of this section § 1926.502], when vertical lifelines are used, each employee shall be attached to a separate lifeline.

(d)(10)(ii)

During the construction of elevator shafts, two employees may be attached to the same lifeline in the hoistway, provided both employees are working atop a false car that is equipped with guardrails; the strength of the lifeline is 10,000 pounds [5,000 pounds per employee attached] (44.4 kN); and all other criteria specified in this paragraph for lifelines have been met.

(d)(11)

Lifelines shall be protected against being cut or abraded.

(d)(12)

Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard in the fully extended position.

(d)(13)

Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position.

(d)(14)

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and body harnesses shall be made from synthetic fibers.

(d)(15)

Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:

(d)(15)(i)

as part of a complete personal fall arrest system which maintains a safety factor of at least two; and

(d)(15)(ii)

under the supervision of a qualified person.

(d)(16)

Personal fall arrest systems, when stopping a fall, shall:

(d)(16)(i)

limit maximum arresting force on an employee to 900 pounds (4 kN) when used with a body belt;

(d)(16)(ii)

limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness;

(d)(16)(iii)

be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level;

(d)(16)(iv)

bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m); and,

(d)(16)(v)

have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.

Note: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to subpart M, and if the system is being used by an employee having a combined person and tool weight of less than 310 pounds (140 kg), the system will be considered to be in compliance with the provisions of paragraph (d)(16) of this section § 1926.502]. If the system is used by an employee having a combined tool and body weight of 310 pounds (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 with the requirements of paragraph (d)(16) of this section (§ 1926.502).

(d)(17)

The attachment point of the body belt shall be located in the center of the wearer’s back. The attachment point of the body harness shall be located in the center of the wearer’s back near shoulder level, or above the wearer’s head.

(d)(18)

Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials.

(d)(19)

Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse.

(d)(20)

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.

(d)(21)

Personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and defective components shall be removed from service.

(d)(22)

Body belts shall be at least one and five-eighths (15/8) inches (4.1 cm) wide.

(d)(23)

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists except as specified in other subparts of this Part.

(d)(24)

When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the movement of the employee only as far as the edge of the walking/working surface.

(e)

Positioning device systems. Positioning device systems and their use shall conform to the following provisions:

(e)(1)

Positioning devices shall be rigged such that an employee cannot free fall more than 2 feet (.9 m).

(e)(2)

Positioning devices shall be secured to an anchorage capable of supporting at least twice the potential impact load of an employee’s fall or 3,000 pounds (13.3 kN), whichever is greater.

(e)(3)

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials.

(e)(4)

Connectors shall have a corrosion-resistant finish, and all surfaces and edges shall be smooth to prevent damage to interfacing parts of this system.

(e)(5)

Connecting assemblies shall have a minimum tensile strength of 5,000 pounds (22.2 kN)

(e)(6)

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or taking permanent deformation.

(e)(7)

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected member, or shall be a locking type snaphook designed and used to prevent disengagement of the snaphook by the contact of the snaphook keeper by the connected member. As of January 1, 1998, only locking type snaphooks shall be used.

(e)(8)

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged:

(e)(8)(i)

directly to webbing, rope or wire rope;

(e)(8)(ii)

to each other;

(e)(8)(iii)

to a dee-ring to which another snaphook or other connector is attached;

(e)(8)(iv)

to a horizontal lifeline; or to depress the snaphook keeper and release itself.

(e)(8)(v)

to any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional disengagement could occur by the connected object being able to depress the snaphook keeper and release itself.

(e)(9)

Positioning device systems shall be inspected prior to each use for wear, damage, and other deterioration, and defective components shall be removed from service.

(e)(10)

Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials.*

If I had 5 bucks every time I tripped on the harness rope…

I like the part were the goverment is not subject to osha laws… It’s just like the politicians who wrote social security who don’t have to be part of it.

just what brought on this crap anyway? Does anyone know if they have an actual reason for making these changes or did they just need somthing to do and this was it. I can see how it could be a revenue generating move since most roofers I’ve met have trouble with authority anyway so for a short time it may bring in some big bucks

We do have a dangerous profession, and we need to ensure safety.

One issue that I have always had is that we are not compensated by insurers for this level of safety compliance. To do the work with those regulations would add hours and a lot of expense to every job. Those are two things I don’t have any extra to give. Really, I can’t imagine doing some of my jobs like that. My crew would leave me to go work elsewhere, where the company worked like everyone else does; and I think I have a very loyal crew now.

There seems to never be proper compensation for this, even given added payment for steep or two story jobs. Still, the OSHA regulations seem to go beyond that, right?

I understand the difficulty of bringing this all to pass, given the decentralized nature of our business, but the insurers are really the one central authority. I could not possibly survive, doing all this safety protection at the prices insurers pay us.

I know it is time to get paid what we truly need to accomplish our jobs on insurance claims, but we have no power to accomplish that.

My solution idea is to kill the deductible. That is counter productive. It causes havoc in our industry. Then, a sincere effort needs to be made to determine what it really costs to do a roof right. I truly think that the pricing given by insurers, this year, causes poor workmanship. Exactimate does not come close to really letting us do our job right. The adjuster comments that the insurers only pay for damage caused by the storm insures only that the job will be done wrong or without adequate profit.

I know that I am not the right guy to price out a roof job, because I am a very small operation. Door knocking/referrals is my marketing, so a few tanks of gas is my marketing expense. My wife does our books, and I handle all the paperwork. We run marginal equipment, because there is no way we could afford a one ton diesel and two 14’ dump trailers. Maybe a couple of years ago, we could have, if we went flat out for max volume.

I frankly don’t know how you big guys survive, though either, any more than the small guys. I really admire you all for it, though. When everyone is failing the OSHA tests almost - if not - daily, it seems like there are just sitting ducks out there, waiting to be picked off. It seems to me that any enforcement has to be arbitrary, and that is not justice.

I had a “competitor” call OSHA on me two weeks ago. They showed up and got the guys off the roof.

We were using proper fall protection UNTIL June 16th. The same fall protection that was fine for the previous 16 years.

They went over some other infractions such as the ladder needing to be three feet higher than the gutter line. We use to standoffs so we don’t damage the gutters so these makes it that much more dangerous.

They said they will let me know what the outcome is once they go back and talk to their boss.

Does anyone have a clear understanding for the rules involving helpers walking up the roof with bundles? The fall arrest systems make sense for the shinglers. Please explain how this works for a guy climbing up a ladder with a bundle? Does he stop at the ladder and set bundle down and then clip on?

Also, at two points in the job someone has to get on and off the peak without a harness? Do you anchor on other side of roof from the ground?

What about a roof repair on the bottom of a roof? Do I have to send a guy to the ridge on a 14/12 to repair a blown shingle on the gutter?

[quote=“famous”] Please explain how this works for a guy climbing up a ladder with a bundle? quote]

I assume as long as the ladder is at the proper height,angle and tied off 2 people might be the easiest way.The guy packing the bundles should hand them off to a guy who is strapped.As far as small repairs it may fall into the category of infeasible.Maybe a spotter and a safety plan.(Tuck and roll) :badgrin:

The guy packing should be wearing a hard hat.If you cannot get a roof delivery it might be a good idea to buy a hoist.All my walkers are always roof top but my steeps are ground dropped.I provide the hoist because of the labor involved in packing.

I hated packing back in the day.Besides it seems more logical for someone to be doing something more productive than packing bundles.

I have started taping off areas at risk from falling debris.(Corners,overhangs etc.) The caution tape is about $8 for 100’.[/quote]

[quote=“Roofmaster417”]I am not trying to sound like a OSHA Guru,I think its important for everyone to understand the new and existing requirements.Alot of good companies here on roofing.com (IMO) and I have seen these fines and they are VERY ugly.

I would hate to hear of anyone at roofing.com having been slapped with a ridiculous fine.They are not playing around.These hefty fines can shut you down if caught.You MUST abide by existing requirements and you HAVE to attempt to abide by the new.If you are caught not using existing and not applying the new you WLL be fined.90day phase in or not.The attempt MUST be made.[/quote]

Thanks for taking the time, Roofmaster417. Much appreciated!

I’m going to hire a couple of busty college girls in bikinis and put one on each corner where we are are working to way-lay any possible OSHA reps while I get everyone off the roof…

In all honesty it’s almost impossible to adhere to every little requirement. What you want to do for certain is take care of the big stuff that they regularly get calls on like:

Fall Protection
Ladders
Hard Hats

Make sure the Foreman knows that if an OSHA rep shows up or anybody starts walking around the job taking pictures etc that everyone comes down off the roof and stays down until the rep is gone.

[quote=“Tar Monkey”]

Make sure the Foreman knows that if an OSHA rep shows up or anybody starts walking around the job taking pictures etc that everyone comes down off the roof and stays down until the rep is gone.[/quote]

I was yaking with my friend who got nailed.I really don’t want to ask alot of questions about it for fear of dragging his nose thru it again.

He told me that noone saw any evidence of OSHA on site.He recieved a phone call and when he showed up at the jobsite to meet the rep he (the rep) pulled up.

He walked up shook hands recieved the biz card and the rep had a laptop and he hooked his camera up and started rolling tape.He video taped everything from the next block.

It is not required for a rep to drive a truck with OSHA plastered everywhere or bells and whistles to let you know they are there.

By the time you notice them,they have been watching for enough time to gather enough evidence against you.

I have seen several and like you said IF you have your sh** together and give them no reason to stop,they roll by.But what I have been hearing is other contractors are turning in anyone who is not abiding or if they are competition,.,.chicken sh** if you ask me.

Yep! That looks like a roof that needs scaffold, hard hats and fall arrest. At least according to OSHA.

The harnesses were in place,the ladder was secured but hardhats I gather that they are required when a worker is below a workspace or the possibility of falling objects are a factor.(Residential)

Anytime ANYONE comes off that ladder a hardhat is there to meet them and they wear it until they are out of the danger zone.But I have not found when the danger zone “technically” ends.

I have to admit that my safety plan was the harnesses keeping the worker from falling between the 5" gap between the house and the carport.

If the worker somehow managed to slip between the gap then the harness would save him or the carport might act as a walk board to help save him from his plummet.

If you notice the entire roof is cleared except for the immediate workspace.So hopefully the anchor is allowed in the immediate area.

But FYI check your subs.Check them frequently.It sucks because some of them have little regard to the fines the contractor can face.It makes no difference to some of them.

[quote=“famous”]Does anyone have a clear understanding for the rules involving helpers walking up the roof with bundles? The fall arrest systems make sense for the shinglers. Please explain how this works for a guy climbing up a ladder with a bundle? Does he stop at the ladder and set bundle down and then clip on?

Also, at two points in the job someone has to get on and off the peak without a harness? Do you anchor on other side of roof from the ground?

What about a roof repair on the bottom of a roof? Do I have to send a guy to the ridge on a 14/12 to repair a blown shingle on the gutter?[/quote]

A worker is not permitted to carry a bundle of shingles up a ladder. the purpose of the ladder is to get the worker to and from the roof. OSHA does not permitt the ladder being used to haul tools,equip,and materials to and from the roof. you must maintain 3 points of contact with the ladder at all times. I would assume you should use a laddervator. worker below needs hardhat, steel toe shoes,glasses, gloves, etc. Worker above must be tied off.

What are the OSHA rules on how much you can carry? Up here we can only ‘legally’ carry 50lbs. I couldn’t imagine loading a 35sq roof with a ladder, breaking all those bundles open, making all those extra trips, just to satisfy a suit.

WOW. 50 Pounds not very much. I have guys that used to carry 2 and three bundles at a time until I jumped them and said no more than a bundle at a time! What’s scary is they only weigh between 130-140 pounds. My sales guy jokes around all the time that we should quit roofing and enter them in toughman contests.

Last year we were unloading 65 squares of Certainteed landmarks and the guys were all carrying 2 and 3 bundles at a time. We were all on the ground and I thought I would be cute and carry 4 bundles to show off. Not real smart. I had ice bags between the legs for a week. Real lucky no surgery.

Looks like I’ll be buying a shingle hoist…

Just to satisfy a suit? If you think it is so easy, what’s keeping you from becoming a suit? You should move to the USA, get a job at GM and join the UAW. You have the perfect mentality.

[quote=“famous”]WOW. 50 Pounds not very much. I have guys that used to carry 2 and three bundles at a time until I jumped them and said no more than a bundle at a time! What’s scary is they only weigh between 130-140 pounds. My sales guy jokes around all the time that we should quit roofing and enter them in toughman contests.

Last year we were unloading 65 squares of Certainteed landmarks and the guys were all carrying 2 and 3 bundles at a time. We were all on the ground and I thought I would be cute and carry 4 bundles to show off. Not real smart. I had ice bags between the legs for a week. Real lucky no surgery.

Looks like I’ll be buying a shingle hoist…[/quote]

I am glad famous is back.

Certainteed Landmarks you say? 4 Bundles… You were able to pick up and put 4 bundles on your shoulder and carry it up a ladder? All 300lbs that 4 bundles weighs?

I will gladly call BS on that and if it is true, I want to see it on YouTube.

I am sure some of the worlds strongest men wouldn’t have the easiest time doing that.

[quote=“BAMBAMM5144”]

[quote=“famous”]WOW. 50 Pounds not very much. I have guys that used to carry 2 and three bundles at a time until I jumped them and said no more than a bundle at a time! What’s scary is they only weigh between 130-140 pounds. My sales guy jokes around all the time that we should quit roofing and enter them in toughman contests.

Last year we were unloading 65 squares of Certainteed landmarks and the guys were all carrying 2 and 3 bundles at a time. We were all on the ground and I thought I would be cute and carry 4 bundles to show off. Not real smart. I had ice bags between the legs for a week. Real lucky no surgery.

Looks like I’ll be buying a shingle hoist…[/quote]

I am glad famous is back.

Certainteed Landmarks you say? 4 Bundles… You were able to pick up and put 4 bundles on your shoulder and carry it up a ladder? All 300lbs that 4 bundles weighs?

I will gladly call BS on that and if it is true, I want to see it on YouTube.

I am sure some of the worlds strongest men wouldn’t have the easiest time doing that.[/quote]

Famous is actually Chuck Norris.

The only thing they let you bring up a ladder is yourself and hand tools…so they’ve told us…but thats what ladder hoists and delivery trucks are for… :roll:

True enough… However chances are that people won’t bother calling OSHA on you if your guys are all strapped, ladders are tight and the guys on the ground are all wearing hard hats. I don’t know about your area but in mine they don’t just drive around like City Inspectors, OSHA guys here don’t leave the office unless they get a call.

If an OSHA rep does visit your job site you should still have your crew hit the ground and stay there until told by you to resume working because even though the rep has probably gathered enough evidence against you to write a couple fines I don’t see any reason to have some infraction happen right in front of him. Better to freeze the job and deal with him imo. He’s either going to leave in a few minutes or tell you to shut it down and leave in a few moments anyway.