OSHA FALL PROTECTION FAQ'S
Which OSHA standards address fall hazards in construction work?
29 CFR Part 1926, Subpart M, which became effective on February 6, 1995, contains general fall protection requirements for construction work. Additional fall protection requirements can be found throughout Part 1926.
When will residential construction employers that were covered by STD 03-00-001 have to start complying with 1926.501(b)(13)?
STD 03-00-002 became effective on September 15, 2011.
What are the Subpart M requirements for residential construction?
Under 29 CFR 1926.501(b)(13), workers engaged in residential construction six(6) feet or more above lower levels must be protected by conventional fall protection (i.e. Guardrail Systems, Safety Net Systems, or Personal Fall Arrest Systems) or alternative fall protection measures allowed under 1926.501(b) for particular types of work. A personal fall arrest system may consist of a full body harness, a deceleration device, a lanyard, and anchor point. (See the definition of "Personal Fall Arrest System" in 29 CFR 1926.500). If an employer can demonstrate that fall protection required under 1926.501(b)(13) is in-feasible or presents a greater hazard it must implement a written, site-specific fall protection plan meeting the requirements of 29 CFR 1926.502(k). The fall protection plan must specify alternative measures that will be used to eliminate or reduce the possibility of employee falls.
Why did OSHA issue Instruction STD 3.1 "Interim Fall Protection Compliance Guidelines for Residential Construction" in 1995?
Once the final rule for Subpart M was published, representatives from the residential construction industry, including the National Association of Home Builders (NAHB) and the National Roofing Contractors Association (NRCA), expressed ongoing concerns about complying with 1926.501(b)(13). For example, industry representatives were concerned about the feasibility of establishing proper anchor points on wood-framed structures. In response to their concerns and to give OSHA time to revisit some feasibility issues, the Agency issued Directive STD 3.1. The directive allowed employers doing specified residential construction activities to comply with the requirements of Subpart M by implementing the alternative fall protection and work procedures prescribed in the directive. The alternative procedures could be used without a prior showing of in-feasibility or greater hazard and without a written fall protection plan. The Agency did not intend STD 3.1 to be a permanent policy.
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