||All MOSH Personnel
||Cheryl Kammerman, Assistant Commissioner
||Interim Compliance Guidelines for Fall Protection for Residential Construction,
29 CFR 1926, Subpart M
Instruction STD 3.1; MOSH Standards Notice 95-5; Attachment A-Questions
||April 1, 2003
||MOSH Standards Notice 96-1a; MOSH Memorandum 01-7; MOSH Memorandum 99-4
||March 27, 2003
- Purpose and Scope:
OSHA has decided to undertake further rulemaking regarding the Fall Protection
Standard for Construction, 29 CFR Part 1926, Subpart M, and
is moving toward the publication of a Notice of Proposed Rulemaking
(NPRM). This proceeding will address concerns raised by compliance
personnel and by representatives of the residential construction
industry. This instruction addresses the interim fall protection
measures that will be acceptable for compliance with Section
1926.501(b)(13), residential construction, during the rulemaking period.
Subpart M does not define "residential construction." For the purpose
of applying this interim compliance directive, "residential
construction" applies to all structures where the working
environment- the construction materials, methods, and procedures
employed – are essentially the same as those used for typical
single-family or townhouse construction. It may be that some
portions of a large commercial structure may come within the
scope of this directive such as a shingled entranceway to a
mall. In those cases the directive would only apply to the small portion
of the project that is "residential-like" and the
rest of the project would be subject to traditional enforcement under Subpart M.
This directive applies only to construction activities and does not affect
any general industrial activities, such as but not limited to
tree trimming, that take place at residential sites.
The procedures contained in this instruction will remain in effect until further
notice, or superceded, or completion of a new formal rulemaking regarding Subpart M.
Keep in mind that this interim policy only applies to work situations described
herein. If other situations, outside the scope of this directive,
are encountered, the employer shall be compliant with appropriate
provisions in Subpart M.
Please also be advised that certain criteria contained herein such
as impalement hazards or overhead fall object hazards, while
listed as preventative measures, shall continue to be cited
under their specific standards and not necessarily under 29
- On August 9, 1994, OSHA published a final rule on fall protection in
the construction industry.
- The Commissioner of Labor and Industry adopted these standards effective January
- The National Roofing Contractors Association (NRCA) and the National Association
of Home Builders (NAHB) have requested that OSHA reconsider
how the standard would be applied to residential construction
roofing activities, taking into account protective measures
which while not recognized by Subpart M, are commonly used in
the residential construction industry. OSHA acknowledges that
the above-discussed concerns merit further consideration by
the Agency. Therefore, OSHA has determined that it is appropriate
to initiate further proceedings regarding Subpart M so that
the Agency can reevaluate what constitutes adequate fall protection
for various construction operations.
C. Listed Activities:
There are four groups of residential construction activities for which alternative
fall protection measures are available.
1. Group 1 - Installation of floor joists, floor sheathing, and erecting exterior walls.
2. Group 2 - Work on concrete block walls, concrete walls, and related formwork.
3. Group 3 - Work activities performed in attics and on roofs such
as but not limited to plumbing, siding, HVAC, communication
lines, insulation, carpentry, masonry, and other trade activities excluding roofing.
4. Group 4 - Erection of roof trusses and rafters; installation
of roof sheathing; and roofing work, including removal,
repair, or installation of roofing materials such as shingles, tile and tar paper.
D. General Requirements That Apply to ALL FOUR GROUPS:
1. Fall Protection Plan (Plan)- A fall protection plan must be developed and implemented
that identifies the competent person, trained employees,
and procedures used to minimize hazards with elevated work
places. This Plan does not have to be site specific or written.
2. Competent Person - The employer must designate a competent person
to implement the fall protection plan on site. The competent
person must be on site at all times and must continually monitor compliance with the Plan.
3. Designated/Trained Employees - Each employee performing work in ANY Group activity must
be trained in requirements of the Plan. The employer must
ensure the employees understand the procedures and follow
the instructions of the competent person. Employees must
be able to recognize unsafe/hazardous conditions including
when compliance with the Plan creates a greater hazard and
are instructed to report them to the competent person. Employees
must also be trained in hazards associated with their specific
Group activities, such as working near rake edges during roofing operations.
4. Training Certification - The employer must certify this training in writing and
make it available upon request.
5. Adverse Weather/Secure Footing - The employer must ensure that workers remove slip hazards
before walking/working on elevated surfaces. Such measures
include removing mud from shoes or boots. When adverse weather
such as high winds, rain, snow, or sleet is creating a hazardous
condition, operations shall be suspended until such time
as the hazardous condition no longer exists, unless safe footing can be ensured for workers.
6. Impalement Hazards - Materials and other objects that could impose
impalement hazards shall be kept out of the area where employees are walking/working or properly guarded.
7. Material Staging - To minimize exposure to fall hazards, materials must be
staged so as to reduce travel distances.
8. Accident Investigation/Plan Review- All accidents resulting in injury to workers shall be reported
and investigated by the employer. To help prevent further
accidents, the investigation must be documented so that
the cause and means of prevention can be identified. In
the event of a fall or other serious incident, the Plan
shall be reviewed to determine if additional practices,
procedures, or training need to be implemented.
In addition to the aforementioned general requirements, the following
requirements must be followed:
- Group 1: Installation of Floor Joists, Floor Sheathing,
and Erection of Exterior Walls when the Maximum Fall Potential does NOT exceed 25 feet.
- Installation of Floor Joists
The first four floor joist/truss must be rolled into position and secured
by workers on the ground, ladders, or scaffolds. Successive
joists/trusses must be rolled into place. They are then
to be secured from a platform. The platform is to be built
from a sheet of plywood laid over the previously secured floor joists or trusses.
- Installation of Floor Sheathing
The first course of floor sheathing must be secured before additional courses are installed.
3. Erection of Exterior Walls
- Warning Line and Monitoring: A painted warning line six (6) feet from
the perimeter will be clearly marked before any wall erection
activities take place. A crew supervisor/foreman or designated
person is required to monitor this work and warn anyone who approaches the unprotected edge.
- Workers constructing exterior walls shall complete as much cutting of materials
and other preparatory work as possible away from the edge of the deck.
F. Group 2: Working on Concrete Block Walls, Concrete Walls, and Related Formwork
when the Maximum Fall Potential does NOT exceed 13 feet.
All walls and formwork shall be adequately supported before any worker can walk/work
on top of the formwork. Workers shall access formwork only by
safe means such as ladders, formwork steps, or bridging appropriately
G. Group 3: Work
activities performed in attics and on roofs such as, but not
limited to plumbing, siding, HVAC, communication lines, insulation,
carpentry, masonry, and other trade activities excluding roofing.
The Maximum Fall Potential must NOT exceed 25 feet at the eave to lower
level and 48 feet at roof peak. In addition, when working in
attics the Interior Maximum Fall Potential must not exceed 13
- Materials and equipment for the work to be performed shall be located
conveniently close to the workers but not stored within 6 feet of the rake edge.
- Employers shall not allow workers to ascend or descend the roof within
6 feet of the rake edge except where such a limit on movement would prevent the performance of work.
- The provisions of this instruction do not apply to work when done outside
of attic or roof areas. Apply Subpart M to work with respect
to stairways, stairway openings, walkways, floor or window
openings, floor holes or other elevated openings or open sides.
H. Group 4: Erecting roof trusses and rafters; installing roof sheathing; and roofing
work including removal, repair, or installing weather proofing
materials such as shingles, tile, and tar paper when the
Potential does NOT exceed 25 feet eave to lower level or 48
feet at the roof peak.
1. Erecting roof trusses and rafters
a. Walls up to and including 10 feet
Interior scaffolds must be installed along the interior wall, below the area
where the trusses/rafters will be located. This can often
be accomplished with sawhorse scaffolds constructed of 46
inches sawhorses and 2"x 10" planks. Bracing operations
shall follow the requirements of paragraph b below.
b. Walls over 10 feet
If using scaffolds and ladders throughout the process would create a greater
hazard, the following general requirements and specific
i. Trusses must be braced in accordance with HIB-91 or manufacturer’s
instructions before any worker may use them as a support.
ii. Top plate workers shall have no other duties during truss/rafter erection.
iii. The first two trusses/rafters must be set from ladders. The
ladders must lean on side walls at points where the wall
can support the load imposed by the ladder and worker.
After the first two trusses/rafters have been set, workers
will climb a ladder or equivalent to access the truss
webbing/rafters in order to brace the peaks.
iv. Workers will remain on the top plate and use the previously stabilized
trusses/rafters as support while the other trusses/rafters are erected.
v. Workers detaching trusses from cranes or securing trusses at the
peaks may be positioned at the peak of the trusses. Trusses
shall not be released from their lifting device until secured.
vi. Workers at the peak, in the web of trusses, or on top of the ridge
beam shall either sit on a ridge seat (or the equivalent)
or position themselves in previously stabilized trusses/rafters
and lean into, and reach through, the trusses/rafters.
vii. Workers must not remain on or in the peak/ridge any longer than
necessary to complete the task safely.
b2. Installing roof sheathing
a. In addition to Adverse Weather/Secure Footing requirements under General
Requirements, all sheathing operations must be suspended
if winds exceed 40 miles per hour, unless wind breakers are erected.
b. Slide guards –
i. Bottom row: The bottom row of roof sheathing may be installed
by workers standing in truss webs and leaning over the
sheathing. After the bottom row is installed, a slide
guard of at least four inches nominal in height shall
be securely attached to the roof. It must extend across the full length of the roof.
ii. Slide guard intervals: Roof slopes greater than 4 in 12 and
up to and including 9 in 12 require additional slide
guards at 13 foot intervals as successive rows of sheathing are installed.
iii. Slide guard intervals: Roof slopes over 9 in 12 require additional
slide guards at four foot intervals.
NOTE: These slide guard requirements, which come from Appendix E,
differ from those for roofing work.
3. Performing roofing work - including removal, repair, or installing roofing materials
such as shingles, tile, and tar paper.
NOTE: Alternatives to the requirements of the standards are not available for
roof slopes over 8 in 12 OR eave height over 25’.
- The employer shall have any damaged portions of the roof deck repaired
as soon as practicable. Any holes, including skylight
openings, or other areas where employees would not have
safe footing shall be covered or surrounded by guardrails
that comply with the requirements of 29 CFR 1926.502.
- On roofs with a slope of 4 in 12 or less, employees
shall be protected by conventional fall protection methods
or a safety monitoring system which meets the requirements
of 29 CFR 1926.502, or they shall be protected by the
use of roofing slide guards as outlined below. Slide
guards must be used when the roof slope is greater than
4 in 12 and up to and including 8 in 12.
- If ladders or scaffolds are used, they shall be erected and maintained
in accordance with the requirements of Subpart L and X
of 29 CFR 1926. The training requirements of these subparts
are also applicable.
- Supplies and materials shall not be stored within 6 feet of the
rake edge, or 3 feet where tile roof systems are being
installed. Employers shall also not allow workers to ascend
or descend within 6 feet of the rake edge except where
such a limit on movement would prevent the performance of work.
- Employers who use roofing slide guards as fall protection during
the performance of roofing work shall take the following
steps, in addition to those steps outlined above:
i. On roofs with slopes less than or equal to 6 in 12, roofing slide
guards shall be installed continuously along the eave.
To accomplish this, not more than 3 rows of roofing
material shall be applied first. Then, the roof jacks
or equivalent supports shall be installed using nails
long enough to hold the slide guard in place should
any employee slide down the roof and contact the slide
guard. The angle of the slide guard system shall be
approximately 90 degrees, +/- 10, to the roof.
A minimum of 2" x 6" nominal lumber shall be used.
ii. On roofs with slopes greater than 6 in 12, up to and including
8 in 12, eave slide guards shall be installed and additional
slide guards shall be installed below the work area
at intervals not to exceed 8 feet. To install the slide
guards, the employee, while standing on the plank below,
shall secure the roof jacks with nails and then install
the planks. The employee can then climb up to the plank
and continue the roofing work. Although the eave slide
guards must run the entire eave’s length and must be
at approximately a 90 degree angle to the roof, higher
slide guards need only be long enough to provide protection
below the area of the roof where work is being performed
and may be more level, if desired. Once the roof is
installed to the ridge, the employee will climb down
to the lower plank and remove the planks and roof jacks
from the higher level. The employee shall continue this
process until all planks and roof jacks are removed.
Only when the job is completed can the remaining eave planks and roof jacks be removed.
iii. On roofs with slopes greater than 8 in 12 and on roofs
with slopes greater than 4 in 12, where the eave to
lower level fall distance is more than 25 feet, employers
shall have workers use one of the conventional methods
of fall protection, i.e., safety nets, guardrails, or
personal fall arrest systems as provided in 29 CFR 1926.502.
1. MOSH compliance personnel will enforce the standards in a manner consistent
with the guidelines provided.
2. Failure to provide fall protection in accordance with any part of
this directive shall be cited as a violation(s) of Subpart M.