- Standard Number:
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 https://www.osha.gov.
April 21, 1994
|MEMORANDUM FOR:||ZOLTAN BAGDY, Acting Director
|FROM:||H. BERRIEN ZETTLER, Deputy Director
Directorate of Compliance Programs
|SUBJECT:||Oregon Fall Protection Policy for Residential Construction
This is in response to your March 15 request for DCP review of Oregon's fall protection policy for residential construction.
We have reviewed Oregon's fall protection plan and their response to the Region's Complaint About State Program Administration (CASPA 0-146) and we agree with the Region's conclusion that Oregon's policy related to fall protection for workers engaged in sheathing and roofing installation in the residential construction industry is less effective than Federal requirements. Federal standards require that when roof brackets are used, roofs more than 16 feet from the ground to eaves with a slope greater than 4:12, without a parapet, be provided with a catch platform unless the employees are protected by a safety belt attached to a lifeline. Oregon's policy allows employees to work from roof brackets on roofs with ground to eave heights between 16 feet and 25 feet without catch platforms or safety belts and lifelines. Oregon's policy allows employees to work without fall protection on higher pitched roofs and at greater heights, than do Federal Regulations. Therefore, we conclude that Oregon's fall protection policy is not equivalent to the Federal.
If we can be of any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.