Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

November 8, 1988

  Regional Administrator
  Directorate of Field Programs
  Directorate of Compliance Programs
SUBJECT: Interpretation of Fall Protection Requirements
  on Construction Sites.

In response to acting Deputy Regional Administrator, Thomas Marple, I am providing a clarification of the circumstances where a safety monitor may be used in lieu of a motion-stopping-safety system (MSS system) on construction sites.

Under current OSHA regulations the only place where a safety monitor may be used in lieu of a MSS is during built-up roofing operations on low pitched roof perimeters. The record is clear that the safety monitor was not the preferred means of protection and was intended only for circumstances where it was not possible to provide other means of physical fall protection. Although the standard does permit a monitor for built-up roofing work, employers are also required to provide specific training for employees engaged in the work to enable them to recognize and avoid the hazard of falling. The safety monitor system was intended to apply in special cases as referenced in 29 CFR 1926.500(g)(1)(ii) and 29 CFR 1926.500(g)(1)(iii). In fact, 29 CFR 1926.500(g)(5) required a MSS system under those conditions where it is anticipated employees will be required to work at the immediate edge of the roof such as when employees are engaged in roof edge materials handling and material storage.

With regard to the question of whether or not an employee working alone can be his own monitor, the standard does not address this issue. The supplemental information makes it clear that, although an employee may have other duties in addition to monitoring, the work cannot be such that it would cause the monitoring function to be encumbered.

If we can provide further guidance on this matter please let me know.