April 21, 1994
This is in response to your March 15 request for DCP review of Oregon's fall protection policy for residential construction.
||ZOLTAN BAGDY, Acting Director
||H. BERRIEN ZETTLER, Deputy Director
Directorate of Compliance Programs
||Oregon 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.