- 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.
November 17, 2003
Mr. Todd Hoffmann
Specialty Associates, Inc.
11122 W. Rogers Street
West Allis, WI 53227
Re: Whether fall protection is required for employees installing the first three rows of roofing material or for removing slide guards from a completed roof with a slope 6-in-12 or less?
Dear Mr. Hoffmann:
This is in response to your letter dated June 5, 2003, to the Occupational Safety and Health Administration (OSHA). You ask about fall protection requirements for residential construction under STD 03-00-001 [formerly STD 3-0.1A] when installing and removing slide guards on roofs with a slope of less than 6-in-12. We apologize for the delay in responding.
We have paraphrased your questions as follows:
Question (1): Under STD 3-0.1A, is fall protection required for employees on a roof with a slope of less than 6-in-12 while installing the first three rows of material (which is before slide guards are required)?
STD 3-0.1A states:
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- Fall protection requirements for residential construction are set out in 29 CFR 1926.501(b)(13). In general, that provision requires conventional fall protection for work at or over six feet. However, OSHA Instruction STD 3.1 modifies those requirements. It permits employers engaged in certain residential construction activities to use alternative procedures routinely instead of conventional fall protection. No showing of infeasibility of conventional fall protection is needed before using these procedures...
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- Alternative Procedures for Group 4: Roofing Work
Restriction on Application for Roofing Work. The alternative procedures in this Instruction may only be used for this work where: (a) the roof slope is 8 in 12 or less, and (b) the fall distance, measure from the eave to the ground level, is 25 feet or less
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- Roof Slope: 6 in 12 or less
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- Installation. No more than three rows of roofing material (installed across the lower eave) shall be applied before installing the slide guards. The roof jacks (or other similar supports) shall be installed using nails long enough to withstand an employee sliding into the guard.
- Roof Slope: 6 in 12 or less
Where work occurs on a roof where the slope is 8-in-12 or less, and the fall distance, measured from the eave to the ground level, is 25 feet or less, an employer may use slide guards as a means of fall protection.
STD 3-0.1A states that, when the roof sloop is 6-in-12 or less, slide guards are required after the first three rows of roofing material have been installed across the lower eave. The slide guards must meet the criteria included in section XII(c)(1), which includes the following requirements: (1) use nails long enough to withstand an employee sliding into the guard; (2) the face of the guard must be perpendicular (about 90 degrees) to the roof surface; and (3) there must be continuous guards along the eave.
No fall protection is required under STD 3-0.1A while employees lay the initial three rows of material;1 it is only required to install slide guards after the installation of the first three rows of shingles.
Question (2): Must an employer provide fall protection for employees removing slide guards from a roof with a slope of 6- in-12 or less?
Although STD 3-0.1A lays out specific requirements for the removal of slide guards where the roof slope is over 6-in-12 (and up to 8-in-12),2 there are no explicit instructions for the safe removal of slide guards when the roof slope is 6-in-12 or less. Therefore, there is no requirement for fall protection for employees removing the required slide guards discussed above.3
If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, 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
1 While not required, it is, of course, permissible for the employer to provide fall protection during this stage of the work, which we strongly recommend. [back to text]
2 See STD 03-00-001 [formerly STD 3-0.1A] Section XII(c)(2). [back to text]
3 See footnote 1 above. [back to text