- 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.
February 23, 2000
CCI Construction Co., Inc.
P.O. Box 8800
Camp Hill, PA 171001
Ref: Slide guards,
STD 3.1, STD 3-0.1A, Appendix E, 1926.501(b)(13), 1926.502(k)
Dear Mr. Niznik:
This is in response to your May 10 letter to the Occupational Safety and Health Administration (OSHA), in which you ask several questions regarding the use of roof jacks during residential construction activities. You further questioned whether roof jacks could be used on commercial projects. We apologize for the delay in responding to your request.
Are roof jacks an acceptable means of fall protection for residential roofing contractors?
Under very specific conditions, roof jacks (slide guards) can be used as part of a fall protection plan in lieu of conventional fall protection. Residential contractors are permitted to use alternative methods of fall protection where it is infeasible to use conventional means (29 CFR 1926.501(b) (13)). Where infeasibility is demonstrated, the contractors can implement a fall protection plan, as specified in section 1926.502(k). (A sample plan is provided in Appendix E of subpart M.)
In addition to the options mentioned above, in 1995 OSHA published an interim fall protection compliance policy for certain residential construction activities (STD 3.1). Recently, a plain language re-write of the same interim enforcement policy was published. Instruction number STD 3-0.1A reiterates OSHA's policy that alternative fall protection methods, such as slide guards, can be used during certain roofing activities. STD 3-0.1A specifies that slide guards must be constructed of 2x6 (nominal) stock lumber, installed at 90 degrees to the surface of the roof, and must be continuous along the eave.
At what distance must the slide guards be separated along the slope of the roof?
In addition to continuous slide guards along the eave, roofs having a pitch in excess of 6 in 12 (up to and including 8 in 12), need slide guards installed below each work area at intervals not to exceed 8 feet. While these need not be continuous, they must be long enough to protect the work area.
Would slide guards be an acceptable alternative fall protection means on a commercial project when installing asphalt shingles?
You describe a commercial project having a metal-frame building with a 6 in 12 pitch roof. The roof consists of a pre-fabricated roofing system of insulation sandwiched between plywood sheets. Asphalt shingles would then be applied over the plywood/insulation unit. For purposes of STD 3-0.1A, residential construction is characterized by the materials and methods used, i.e., wood framing, wooden floor joists and roof structures, and traditional wood frame construction techniques. The construction of discrete parts of large commercial buildings (wood frame, shingled entranceway) may qualify where these characteristics are present.
The roofing project you describe does not appear to meet this criteria. Typically, metal framed structures can support attachments for conventional fall protection, and on commercial projects, equipment such as scaffolds and/or aerial lifts would normally be available for use as alternative fall protection measures.
[This document was edited on 12/4/12 to strike information that no longer reflects current OSHA policy.]
Should you have further questions, please do not hesitate to contact us again by writing to: Occupational Safety and Health Administration, Directorate of Construction, Office of Construction Standards and Compliance Assistance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210.
Russell B. Swanson, Director
Directorate of Construction