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 10, 2001

Dennis Vance
Safety Services
711 Low Gap Road
Princeton, WV 24740

Re: STD 3-0.1A; residential construction; §1926.501(b)(13); guardrails; roofing work

Dear Mr. Vance:

This is in response to your October 9, 2000 letter to the Occupational Safety and Health Administration (OSHA), in which you ask several questions about [STD 03-00-001 (formerly STD 3-0.1A)], the Interim Fall Protection Compliance Guidelines for Residential Construction.

We have paraphrased your questions as follows:

Question 1: You first ask if the 48 feet mentioned in STD 3-0.1A is a limit on the height of the structure or how high a residential construction employee can be working without using conventional fall protection.

Response: The section of STD 3-0.1A that you reference states:

NOTE: Height Limitation: The Appendix E plan may only be used on structures up to three and a half stories or 48 feet (including basement, two finished levels, attic). The 48' measure is from the base of the building, at the lowest ground level (including any excavation), to the point of greatest height.

This Note helps to define the scope of structures covered by STD 3-0.1A. An employer has to determine if the structure being built is within the scope of STD 3-0.1A before using the alternative fall protection methods it prescribes for specific residential construction activities. The first sentence of the Note makes clear that the height limitation is based on the height of the structure: "The Appendix E plan may only be used on structures up to three and a half stories or 48 feet..." [emphasis added]. Therefore, the "point of greatest height" referred to in the second sentence refers to the height of the structure, not the point at which the employees are working.

Question 2: During roofing work, if the roof pitch is 10 in 12 and an employer chooses to use guardrails for fall protection, must guardrails be installed along the rake edges as well as the eave?

Response: Yes, if no other fall protection method is provided. On roofs up to 8 in 12 pitch, STD 3-0.1A allows an employer to use alternative methods of fall protection. For roofs of over 8 in 12 pitch, conventional fall protection methods such as safety nets, catch platforms, personal fall arrest systems, guardrails, positioning devices, or restraint devices must be used, but no particular method is prescribed. In the scenario you describe, if no other means of fall protection is used, guardrails would have to be along the rake edges.

Question 3: Is there a distance from the fall hazard presented by a rake edge on a 10 in 12 roof where an employee can be considered safe if guardrails are used only at the eave?

Response: Neither the applicable standard, 29 CFR Part 1926, Subpart M (beginning at §1926.500), nor STD 3-0.1A, sets a "safe distance" that would negate the requirement for fall protection on these steep pitched roofs. [The applicable standard, 29 CFR Part 1926, Subpart M (beginning at §1926.500), does not set a "safe distance" that would negate the requirement for fall protection on these steep pitched roofs.] If there is a particular situation involving specified distances that you would like us to evaluate, please let us know.

[This document was edited on 12/5/12 to strike information that no longer relects current OSHA policy.]

Question 4(a): Can a scaffold be used as fall protection for roofers by reducing the fall distance from the edge of a roof? Can a scaffold be used at the rake edges of a roof to reduce the fall distance?

Response: Yes, as long as it reduces the fall distance to less than 6 feet and meets the requirements of 29 CFR Part 1926, Subpart L (Scaffolds, beginning at §1926.450).

Question 4(b) How close would that scaffold have to be to the eave?

Response: The fall protection standard, §1926.501(b)(13), requires that a residential construction worker be protected from falls of 6 feet or more. How an employer limits that fall distance using a scaffold during roofing work is not prescribed in fall protection. So, with respect to Subpart M, it is close enough if it is positioned so that it will catch the employee in all reasonably foreseeable circumstances.

NOTE: A scaffold more than 10 feet high, when used as a catch platform, would be required to have guardrails (assuming no other form of fall protection was used on it) under §1926.451(g) ("each employee on a scaffold more than 10 feet...above a lower level shall be protected from falling to that lower level...."). Under §1926.451(b)(3), on the side of the scaffold facing the building, if the face of the building is used as fall protection instead of a guardrail, the scaffold would have to be no more than 14 inches from the building face ("except as provided in paragraphs 1926.451(b)(3)(i) and 1926.451(b)(3)(ii) of this section, the front edge of all platforms shall not be more than 14 inches (36 cm) from the face of the work, unless guardrail systems are erected along the front edge and\or personal fall arrest systems are used...."). As a practical matter, the scaffold would probably have to be no more than that distance from the building anyway in order to be sure of catching the employee.

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.


Russell B. Swanson, Director
Directorate of Construction

[Corrected 6/2/2005]