April 22, 2011
Mid-Atlantic Construction Safety Council
1717 Arch Street
Philadelphia, PA 19103
Dear Mr. Baxter:
Thank you for your September 28, 2008 letter to the Occupational Safety and Health Administration (OSHA) Directorate of Construction. We apologize for the delay in our reply. You have a specific question regarding what constitutes a "safe" distance from an unprotected side or edge for steel erection activities. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.
Question: At what distance from an unprotected side or edge does a worker, performing steel erection activities under 29 CFR 1926 Subpart R with a fall hazard greater than 15 feet, be required to have fall protection?
Response: The fall protection standards for steel erection activities are set out in Sections 1926.760 of 29 CFR 1926 Subpart R (Steel Erection). Section 1926.760(a) states:
(1) Except as provided by paragraph (a)(3) of this section, each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6 m) above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems or fall restraint systems.
By its terms, 1926.760(a)(1) requires all employees performing a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level be protected by one of the enumerated fall protection methods, unless an explicit exception applies. There is no "safe" distance from an unprotected side or edge that would render fall protection unnecessary."1
Section 1926.760(a)(3) permits alternative fall protection requirements for connectors and workers in controlled decking zones (CDZ). More specifically, the alternative requirements for employees engaged in leading edge work in a CDZ are set out in Section 1926.760(c), which states:
(1) Each employee working at the leading edge in a CDZ shall be protected from fall hazards of more than two stories or 30 feet (9.1 m), whichever is less.
In conclusion, all employees performing steel erection activities who are exposed to fall hazards, whether doing leading edge decking work in a CDZ or not, must be protected from such hazards as required by the fall protection standards in 1926.760, regardless of the distance from the edge.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction
1 See the preamble to the fall protection final rule, Safety Standards for Fall Protection in the Construction Industry, 59 FR 40683, available at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=894. [Return to Text]