Standard Interpretations - Table of Contents|
| Standard Number:||1926.501(b)(10); 1926.501(b)(1); 1926.501(b)(2); 1926.502(b); 1926.502(f)(2)|
|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 athttp://www.osha.gov.|
(b)(1) Unprotected sides and edges. Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.As discussed in the Preamble to Part 1926 Subpart M (Volume 59 of the Federal Register, page 40683), OSHA determined in the rulemaking that there is no safe distance from an unprotected side or edge of a walking/working surface that would render protection unnecessary. However, in the rulemaking for Subpart M, OSHA determined that in certain very limited situations, warning lines are an appropriate means of protection. Section 1926.501(b)(10) sets out the fall protection requirement for roofing work on low slope roofs. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination with monitors in place of personal fall protection equipment or guardrails. Under §1926.501(b)(2), employers engaged in other specified work, such as leading edge work, precast concrete erection work and residential construction, may develop and implement a site-specific fall protection plan that uses alternative fall protection methods if they can demonstrate the infeasibility of conventional fall protection. As can be seen in the examples given in Appendix E to Subpart M, warning lines 6 feet back from the edge can be used as part of such a plan.
We have now had five years of experience with the application of the rule since it was published in 1994. We continue to believe that distance alone is ineffective to protect workers from unprotected sides or edges. However, we have determined that, in the area further back from the distances specified for the warning lines permitted under the standard, there is a point that is sufficiently far from the edge or hole to warrant the application of a de minimis policy regarding non-conforming guardrails.We concluded that the use of certain physical barriers that fail to meet the criteria for a guardrail would be considered a de minimis violation of the guardrail criteria in §1926.502(b) where all of the following are met:
At 15 feet from the edge or hole (in the case of a hole, measured from the nearest edge of the hole), a warning line, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge. Also, at that distance, the failure of a barrier to restrain a worker from unintentionally crossing it would not place the worker in immediate risk of falling off the edge. Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances.
|Standard Interpretations - Table of Contents|
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