| OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. |
April 10, 2001
Dennis Vance
Safety Services
711 Low Gap Road
Princeton, WV 24740
Re: STD 3-0.1A; residential construction; §1926.501(b)(13);
guardrails; roofing work
Dear Mr. Vance:
This is in response to your October 9, 2000 letter to the
Occupational Safety and Health Administration (OSHA), in which
you ask several questions about [STD 03-00-001 (formerly STD
3-0.1A)], the Interim Fall Protection Compliance Guidelines for
Residential Construction.
We have paraphrased your questions as follows:
Question 1: You first ask if the 48 feet mentioned in STD
3-0.1A is a limit on the height of the structure or how high a
residential construction employee can be working without using
conventional fall protection.
Response: The section of STD 3-0.1A that you reference
states:
NOTE: Height Limitation: The Appendix E plan may
only be used on structures up to three and a half stories or 48
feet (including basement, two finished levels, attic). The
48' measure is from the base of the building, at the lowest
ground level (including any excavation), to the point of greatest
height.
This Note helps to define the scope of
structures covered by STD 3-0.1A. An employer has to determine if
the structure being built is within the scope of STD 3-0.1A
before using the alternative fall protection methods it
prescribes for specific residential construction activities. The
first sentence of the Note makes clear that the height limitation
is based on the height of the structure: "The Appendix E
plan may only be used on structures up to three and a half
stories or 48 feet..." [emphasis added]. Therefore, the
"point of greatest height" referred to in the second
sentence refers to the height of the structure, not the point at
which the employees are working.
Question 2: During roofing work, if the roof pitch is 10
in 12 and an employer chooses to use guardrails for fall
protection, must guardrails be installed along the rake edges as
well as the eave?
Response: Yes, if no other fall protection method is
provided. On roofs up to 8 in 12 pitch, STD 3-0.1A allows an
employer to use alternative methods of fall protection. For roofs
of over 8 in 12 pitch, conventional fall protection methods such
as safety nets, catch platforms, personal fall arrest systems,
guardrails, positioning devices, or restraint devices must be
used, but no particular method is prescribed. In the scenario you
describe, if no other means of fall protection is used,
guardrails would have to be along the rake edges.
Question 3: Is there a distance from the fall hazard
presented by a rake edge on a 10 in 12 roof where an employee can
be considered safe if guardrails are used only at the eave?
Response: Neither the applicable standard, 29 CFR Part
1926, Subpart M (beginning at §1926.500), nor STD 3-0.1A,
sets a "safe distance" that would negate the
requirement for fall protection on these steep pitched roofs. [The applicable standard, 29 CFR Part
1926, Subpart M (beginning at §1926.500), does not
set a "safe distance" that would negate the
requirement for fall protection on these steep pitched roofs.] If
there is a particular situation involving specified distances
that you would like us to evaluate, please let us know.
[This document was edited on 12/5/12 to strike information that no longer relects current OSHA policy.]
Question 4(a): Can a scaffold be used as fall
protection for roofers by reducing the fall distance from the
edge of a roof? Can a scaffold be used at the rake edges of a
roof to reduce the fall distance?
Response: Yes, as long as it reduces the fall distance to
less than 6 feet and meets the requirements of 29 CFR Part 1926,
Subpart L (Scaffolds, beginning at §1926.450).
Question 4(b) How close would that scaffold have to be to
the eave?
Response: The fall protection standard,
§1926.501(b)(13), requires that a residential construction
worker be protected from falls of 6 feet or more. How an employer
limits that fall distance using a scaffold during roofing work is
not prescribed in fall protection. So, with respect to Subpart M,
it is close enough if it is positioned so that it will catch the
employee in all reasonably foreseeable circumstances.
NOTE: A scaffold more than 10 feet high, when used as a catch
platform, would be required to have guardrails (assuming no other
form of fall protection was used on it) under §1926.451(g)
("each employee on a scaffold more than 10 feet...above a
lower level shall be protected from falling to that lower
level...."). Under §1926.451(b)(3), on the side of the
scaffold facing the building, if the face of the building is used
as fall protection instead of a guardrail, the scaffold would
have to be no more than 14 inches from the building face
("except as provided in paragraphs 1926.451(b)(3)(i) and 1926.451(b)(3)(ii) of
this section, the front edge of all platforms shall not be more
than 14 inches (36 cm) from the face of the work, unless
guardrail systems are erected along the front edge and\or
personal fall arrest systems are used...."). As a practical
matter, the scaffold would probably have to be no more than that
distance from the building anyway in order to be sure of catching
the employee.
If you need additional information, please contact us by fax at:
U.S. Department of Labor, OSHA, Directorate of Construction,
Office of Construction Standards and Guidance, fax #
202-693-1689. You can also contact us by mail at the above
office, Room N3468, 200 Constitution Avenue, N.W., Washington,
D.C. 20210, although there will be a delay in our receiving
correspondence by mail.
Sincerely,
Russell B. Swanson, Director
Directorate of Construction
[Corrected 6/2/2005]
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