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June 13, 1994

MEMORANDUM FOR:	OFFICE OF FIELD PROGRAMS REGIONAL ADMINISTRATORS
FROM:	JAMES W. STANLEY DEPUTY ASSISTANT SECRETARY
SUBJECT:	Fall Protection for Steep Roofs and During the Performance of Built-Up Roofing Work

Until new subpart M--Fall protection is published, the interim policy regarding fall protection during roofing operations is as follows:

Citations for failure to use fall protection shall be issued to employers engaged in steep roof or built-up roofing activities only when those employers are not in compliance with the requirements of 29 CFR 1926.451(u)(3) for work on steep roofs, and 29 CFR 1926.500(g) for work during built-up roofing operations. Section 5(a)(1) of the Act and 29 CFR 1926.95(a) shall not be used to require fall protection during those operations when the fall distance is less than 16 feet.