Fall Protection
Frequently Asked Questions
Page 1
Question 1:
In residential construction, when employees are standing
on top of concrete formwork with a fall hazard in excess of six feet, is
conventional fall protection required?
Answer 1:
In residential construction, under STD 3.1 [superseded by
STD 3-0.1A], conventional fall protection is not required for workers working
from the top of foundation wall formwork.
See Letter of Interpretation
Question 2:
Does someone working on a portable ladder need fall
protection?
Answer 2:
Neither the ladder standard (29 CFR 1926, subpart X) nor
the fall protection standard (29 CFR 1926, subpart M) requires fall protection
for workers while working on portable ladders.
See Letter of Interpretation
Question 3:
In reference to 29 CFR 1926.501(b)(10), can trades other
than roofers on low slope roofs use warning lines instead of conventional fall
protection.
Answer 3:
OSHA has determined for other trades, work performed in
areas that are further back from the distances specified for the warning lines
permitted under the standard (1926.502(f), there is a point that is sufficiently
far from the edge to warrant the application of a de minimis policy regarding
non-conforming guardrails. Specifically, we will consider the use of certain
physical barriers that fail to meet the criteria for a guardrail a de minimis
violation of the guardrail criteria in 1926.502(b) where all of the following
are met:
A warning line is used 15 feet or more from the edge;
The warning line meets or exceeds the requirements in 1926.502(f)(2);
No work or work-related activity is to take place in the area between the
warning line and the edge; and
The employer effectively implements a work rule prohibiting the employees from
going past the warning line.
In sum, the use of warning lines closer than 15 feet from the edge is not
permitted as a substitute for conventional fall protection for these other
trades. Furthermore, when these other trades use a warning line system in
accordance with the policy described above, the workers must use conventional
fall protection when they are outside the protection of the warning line system.
See Letter of Interpretation
Next Page
Region
IV
