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.

June 24, 1981

MEMORANDUM FOR:     CURTIS A. FOSTER
                   REGIONAL ADMINISTRATOR

THRU:               JOHN B. MILES
                   FIELD COORDINATOR

FROM:               BRUCE HILLENBRAND
                   DEPUTY DIRECTOR,
                   FEDERAL COMPLIANCE AND STATE PROGRAMS

SUBJECT:            29 CFR 1926.500(g)(1):  Guarding 
                   Low-Pitched-Roof Perimeters

REFERENCE:          Your memorandum, dated May 18, 1981, same subject.

It is the intent of 29 CFR 1926.500, roofing standard effective on January 13, 1981, to regulate only the guarding of low-pitched-roof perimeters during the performance of built-up roofing work. 29 CFR 1926.104, 1926.105, 29 CFR 1924.451(u)(3) and 29 CFR 1926.28 are to be enforced for other types of roofing work, such as to be found between points A and B on your sketches.

The eave is at point B as indicated on your two sketches and 29 CFR 1926.500(g) does not apply to anyone installing the built-up roof in the situations depicted in your sketched since the eaves are less than 16 feet above the ground. Additionally, no citation could issue for violation of other fall protection standards (e.g. 1926.28(a)) with regard to employees performing built-up roofing work in your sketches because of the preemptive effect of 1926.500(g). The Directorate of Safety Standards Programs plans to revise the standard with a modification of the roofing paragraphs to address fall distance instead of eave distance as soon as time and priorities permit.