The impact on the roofing industry of the OSHA's newly revised fall protection standard.

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.

May 8, 1995

The Honorable John Linder
U.S. House of Representatives
Washington, D.C. 20515-1004

Dear Congressman Linder:

Thank you for your letter of February 16, requesting our response to concerns raised by two of your constituents, Mr. and Mrs. William E. Dodd, about the impact on the roofing industry of the Occupational Safety and Health Administration's (OSHA) newly revised fall protection standard. We appreciate the opportunity to clarify this matter and apologize for the delay of this response.

The impact on the roofing industry from OSHA's fall protection standard.

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.

 

 

Acceptable use of warning lines as fall protection for roofers and other trades.

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.

 

 

Fall protection: determination of roof width on irregular shaped roofs.

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.

January 16, 2001

Mr. Craig D. Adams
Safety and Health Agenda
For Roofing Professionals
4840 West 15th Street
Suite 1000
Lawrence, KS 66049-3862

Re: 1926.501(b)(10), 1926.502(h), Subpart M, Low-Slope Roof, Safety Monitoring System

Dear Mr. Adams:

Fall protection requirements for workers engaged in "roof blocking."

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.

May 3, 2001

Joseph J. Novak
1399 Vischers Ferry Road
Clifton Park, New York 12065-6390

Re: 1926.501(b)(10); 1926.501(b)(13); STD 3-0.1A; personal fall arrest; safety monitors; warning lines.

[This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy referencing STD 3-0.1A.]

Dear Mr. Novak,

Fall protection requirements for employees, other than roofers, working on low-slope roofs

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 15, 2002

Mr. Keith Harkins
Safety Manager
Linbeck/Kennedy & Rossi
One Maguire Road
Lexington, Ma 02421

Re: Whether a warning line at 6 feet used to protect roofing workers may also be used to meet fall protection requirements for HVAC construction workers; §1926.502(b)

Dear Mr. Harkins:

Fall protection requirements for construction workers doing work while on a roof

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.

December 15, 2003

Mr. Anthony O'Dea
ADP Marshall Construction
75 Newman Avenue
Rumford, RI 02916

Re: Fall protection requirements for construction workers doing work while on a roof.

Dear Mr. O'Dea:

Fall protection during roofing inspections, investigations, and assessments

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.

March 12, 2004

Mr. Randy Stahl
Safety Manager
Korellis Roofing, Inc.
1333 169th Street
Hammond, IN 46324-2008

Re: Is fall protection required during small roofing repairs that take minimal time to complete?

Dear Mr. Stahl:

This is in response to your letter dated December 16, 2003, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your question as follows:

Fall protection non-conforming guardrail criteria for application of a de minimis policy.

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.

May 12, 2000

Mr. Barry A. Cole
Executive Vice-President
Steel Erectors Safety Association
of Colorado
5750 Pecos Street, Suite 6
Denver, Colorado 80221

Re: Fall Protection/Use of barricades; 1926.500, Subpart M

Dear Mr. Cole:

This is in response to your letter dated July 24, 1998, addressed to OSHA's Directorate of Construction. In the letter you ask a series of questions regarding 29 CFR 1926.500, Subpart M. We apologize for the long delay in responding.

Use of a warning line instead of conventional fall protection; Part 1926 Subpart M

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.

January 3, 2005

Mr. Dan Steigerwald
Safety Consultant
IMA Community Business
250 N. Water Street
600 IMA Plaza
Witchita, KS 67202

Re: Use of a warning line instead of conventional fall protection; Part 1926 Subpart M.

Dear Mr. Steigerwald: