OSHA's 3-step program for fall protection includes:
1. Plan - employers must plan projects to identify fall hazards and select appropriate safety equipment
2. Provide - employers must provide the necessary safety equipment, such as harnesses and lifelines for roof work
3. Train - employers must train workers on how to properly use equipment like ladders, scaffolds, and fall arrest systems to work safely at heights
The document then debunks 5 common myths about fall protection requirements, noting that residential construction, short job durations, and warning lines alone are not sufficient protection in many cases. Statistics on past OSHA citations related to these myths are also provided.
1. 5 Fall Protection Myths and OSHA’s 3
Step Program For Fall Protection
2. 5 fall protection myths
• Myth #1: “Residential construction has an exemption from the fall
protection rules.”
This used to be true. However, in December 2010, OSHA rescinded the
directive that allowed for that exception and as of September 15,
2011, all residential construction companies must comply with
1926.501(b)(13). The employer still has the option to develop and
implement a fall protection plan that meets the requirements of
paragraph (k) of 1926.502 if the employer can demonstrate that fall
protection is infeasible or creates a greater hazard.
The new directive STD 03-00-002, Compliance Guidance for Residential
Construction, rescinds STD 03-00-001, Interim Fall Protection
Compliance Guidelines for Residential Construction, and provides that
OSHA will be enforcing 1926.501(b)(13) for all residential construction
work.
3. 29 CFR 1926.501(b)(13)
• EFFECTIVE SEPTEMBER 15, 2012 - The new directive requires all residential
builders to comply with 29 Code of Federal Regulations 1926.501(b)(13).
• Under 29 CFR 1926.501(b)(13) workers engaged in residential construction six (6)
feet or more above lower levels are to be protected by conventional fall
protection. For roofers, the 25 foot, ground-to-eave height threshold no longer
applies, nor do slide guards as an acceptable form of fall protection, regardless of
the roof pitch or height of the roof eave.
• These new requirements replace the Interim Fall Protection Compliance Guidelines
for Residential Construction, Standard 03-00-001 that have been in effect since
1995 and allowed residential builders to bypass fall protection requirements.
• OSHA has developed training and compliance assistance materials for small
employers and will host a webinar for parties interested in learning more about
complying with the standard.
4. 5 fall protection myths
• Myth #2: “I don’t need any fall protection; it’s only going to
take me a couple minutes to install that equipment.”
Fall protection must be provided when employees are
performing construction work on a walking/working surface
with an unprotected side or edge that is six feet or more
above a lower level. (Note: Construction work is “work for
construction, alteration, and/or repair, including painting and
decorating.”)
The length of time needed to perform that construction work
has no bearing on the employer’s duty to provide fall
protection. Be it one minute or one hour, OSHA requires fall
protection per 1926.501(b)(1).
5. 5 fall protection myths
• Exception To Myth #2:
There is an exception: when employees are making an inspection,
investigation or assessment of workplace conditions prior to the actual
start of construction work or after all construction work has been
completed, no fall protection is needed.
The following is from an OSHA Letter of Interpretation dated March 2,
2010:
“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... [R]equiring
the installation of fall protection systems under such circumstances
would expose the employee who installs those systems to falling
hazards for a longer time than the person performing an inspection or
similar work.”
6. 5 fall protection myths
• Myth #3: “Training programs for fall protection
aren’t really needed.”
OSHA is clear about requiring training for each
employee who might be exposed to fall hazards. For
example, employees may be familiar with specific
types of fall protection and have had proper
training. However, if a different type of fall
protection is to be used, employees using it must be
trained by a competent person qualified in this area
of expertise.
7. 5 fall protection myths
• Myth #4: “I’m doing roofing on a low-sloped roof so I don’t
need any fall protection.”
• OSHA requires (per 1926.5010(b)(10)) each employee engaged in roofing
activities on low-sloped roofs, with unprotected sides and edges six feet or
more above lower levels be protected from falling by:
• Guardrail systems,
• Safety net systems, or
• Personal fall arrest systems.
• Other options include a combination of:
• Warning line system and guardrail system,
• Warning line system and safety net system,
• Warning line system and personal fall arrest system, or
• Warning line system and safety monitoring system.
• On roofs 50 feet or less in width, the use of a safety monitoring system
alone (i.e., without the warning line system) is permitted.
8. 5 fall protection myths
• Myth #5: “A warning line is all I need for fall
protection when working on a steep roof.”
According to 1926.501(b)(11), a warning line is not
allowed as a form of fall protection when working
on a steeply pitched roof. OSHA requires that each
employee on a steep roof with unprotected sides
and edges six feet or more above lower levels be
protected from falling by guardrail systems with toe
boards, safety net systems or personal fall arrest
systems.
9. According to OSHA Statistics:
• In 2010:
• Myth #2: cost employers $1,344,612 in OSHA
citations.
• Myth #3: failure to provide the required fall
protection training in 1926.503(a)(1) resulted in
$649,006 in OSHA citations
• Myth #4: OSHA issued $909,442 in citations to
enforce the requirement in1926.5010(b)(10)
• Myth #5: Training employees on the
requirements of 1926.501(b)(11) would have
saved employers $447,828 in citations
10. Myth: Six-Foot Rule
• This myth involves the so-called 6-ft rule or “two-step
rule” where distance alone is the protection. OSHA has
never viewed as compliant the practice of remaining at
least 6 feet away from the edge. The preamble to 29
CFR 1926, Subpart M, states the premise that “OSHA
has determined that there is no safe distance from an
unprotected side or edge that would render fall
protection unnecessary.”
• That interpretation was the rule until July 23, 1996,
when a letter of interpretation was written that
stipulated for a low-slope roof, “However, when
employees working 50 to 100 feet away from the
unprotected edge have been properly trained, then the
situation can be considered a de minimis condition.”
11. Welcome to OSHA's Fall Prevention Campaign
• FALLS ARE THE LEADING CAUSE OF DEATH IN
CONSTRUCTION. In 2010, there were 264 fall
fatalities (255 falls to lower level) out of 774 total
fatalities in construction. These deaths are
preventable.
• Falls can be prevented and lives can be saved
through three simple steps:
• Plan
• Provide
• Train
12. FALLS FROM ROOFS CAN BE PREVENTED!
Inspect all fall protection equipment before use
Use guardrails or lifelines
Wear a harness and always stay connected
Make sure your harness fits
Guard or cover all holes, openings, and skylights
PLAN ahead to get the job done safely.
PROVIDE the right roof equipment.
TRAIN everyone to use the equipment safely.
13. PLAN ahead to get the job done safely.
• When working from heights, such as ladders, scaffolds,
and roofs, employers must Plan projects to ensure that
the job is done safely. Begin by deciding how the job will
be done, what tasks will be involved, and what safety
equipment may be needed to complete each task.
• When estimating the cost of a job, employers should
include safety equipment, and Plan to have all the
necessary equipment and tools available at the
construction site. For example, in a roofing job, think
about all of the different fall hazards, such as holes or
skylights and leading edges, then Plan and select fall
protection suitable to that work, such as personal fall
arrest systems (PFAS).
14. PROVIDE the right roof equipment.
• Workers who are six feet or more above lower levels are at risk for
serious injury or death if they should fall. To protect these workers,
employers must Provide fall protection and the right equipment for
the job, including the right kinds of ladders, scaffolds, and safety
gear.
• Different ladders and scaffolds are appropriate for different jobs.
Always Provide workers with the kind they need to get the job done
safely. For roof work, there are many ways to prevent falls. If
workers use personal fall arrest systems (PFAS), Provide a harness
for each worker who needs to tie off to the anchor. Make sure the
PFAS fits, and regularly inspect all fall protection equipment to
ensure it's still in good condition and safe to use.
15. TRAIN everyone to use the equipment safely
• Falls can be prevented when workers understand proper
set-up and safe use of equipment, so they need training on
the specific equipment they will use to complete the job.
Employers must train workers in hazard recognition and in
the care and safe use ladders, scaffolds, fall protection
.
systems, and other equipment they'll be using on the job.
• OSHA has provided numerous materials and resources that
employers can use during toolbox talks to train workers on
safe practices to avoid falls in construction. Falls from
ladders, scaffolds and roofs can be prevented and lives can
be saved through three simple steps: Plan, Provide and
Train.
