- 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 http://www.osha.gov.
June 3, 2005
|MEMORANDUM FOR:||CHARLES ADKINS
|FROM:||RUSSELL B. SWANSON
Director, Directorate of Construction
Safety Manager, Region VII
|SUBJECT:||Alternative procedures under STD 03-00-001 (formerly STD 3-0.1A) for employees performing roofing work on roof slopes of 6 in 12 or less during residential construction.|
This is in response to Mr. Drake's e-mail dated April 13, 2005. You ask a question regarding the installation of slide guards under STD 03-00-001.
We have paraphrased your question as follows:
Question: Scenario: Employees are installing weatherproofing materials (tar paper and shingles) on roof slopes of 6 in 12 or less during residential construction covered under STD 03-00-001. Employees cover the entire roof with tar paper without slide guards installed. Then, the employees apply three rows of shingles along the eave. Only after applying these three rows, do the employees install the slide guards. Does this meet the alternative fall protection measures of STD 03-00-001?
Answer: No. STD 03-00-001 states:
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B. 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...Different alternative procedures are specified for different activities.
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XII. ALTERNATIVE PROCEDURES FOR GROUP 4: ROOFING WORK (REMOVAL, REPAIR, OR INSTALLATION OF WEATHERPROOFING ROOFING MATERIALS SUCH AS SHINGLES, TILE, AND TAR PAPER).
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, measured from the eave to the ground level, is 25 feet or less.
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C. Slide Guards: Requirements for Materials, Configuration and Installation.
1. Roof Slope: 6 in 12 or less:
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b. 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 similar supports) shall be installed using nails long enough to withstand an employee sliding into the guard.
In the situation you describe above, employees have applied tar paper to the entire roof without installing slide guards. The alternative procedures permitted in STD 03-00-001 (XII)(C)(1)(b) do not include this practice; it states: "No more than three rows of roofing material (installed across the lower eave) shall be applied before installing the slide guards" (italics added). As noted in the heading to the "Alternative Procedures to Group 4," tar paper is considered a type of roofing material. Therefore, an employer who applies more than three rows of tar paper on a 6 in 12 or less roof without installing slide guards is not in compliance with STD 03-00-001 (XII)(C)(1)(b).
You also note that OSHA, in a letter to Mr. Todd Hoffmann on November 17, 2003, stated that:
No fall protection is required under STD 03-00-001 while employees lay the initial three rows of material; it is only required to install slide guards after the installation of the first three rows of shingles (italics added).
You ask if this language permits employers to apply tar paper to an entire roof without installation of slide guards because at that point, the first three rows of shingles have not been installed. The Hoffman letter does not stand for such a proposition. The incoming Hoffmann letter focused primarily on the application of the first three rows of shingles and, therefore, the Agency was specifically addressing Mr. Hoffmann's question about shingles, not "roofing material" in general.