Fall Protection
Frequently Asked Questions
Page 2
Question 4:
Do vendors
supplying roofing materials have to use conventional fall protection when
delivering material to roof tops?
Answer 4:
The Agency''s
policy was clearly stated in an Advance Notice of Proposed Rulemaking (ANPR),
which was published in the Federal Register on July 14, 1999 (volume 64, page
38,077). In the ANPR, OSHA stated that it will not require the vendor's
employees to install an anchorage point for fall protection [when distributing
roofing materials] regardless of the slope of the roof or the fall distance.
However, if an anchorage point is already available on the roof, the employees
must use fall protection equipment.
See Letter of Interpretation
Question 5:
Can we use fall
restraint instead of personal fall arrest systems?
Answer 5:
Although the
standard does not mention them, we do accept properly utilized fall restraint
systems in lieu of fall arrest systems when the restraint system is rigged in
such a way that the employee cannot get to the fall hazard. We suggest that, as
a minimum, fall restraint systems have the capacity to withstand at least three
thousand (3000) pounds of force or twice the maximum expected force that is
needed to restrain the person from exposure to the fall hazard. In determining
this force, consideration should be given to site-specific factors such as the
force generated by a person walking, leaning, or sliding down the work surface.
See Letter of Interpretation
Question 6:
Do I need fall
protection around residential basement foundation excavations deeper than six
feet?
Answer 6:
Paragraph
1926.501(b)(7) requires fall protection around excavations only when the
excavations are not readily seen because of plant growth or other visual
barrier. Typically in residential construction, plant growth and other visual
barriers is not an issue.
See Letter of Interpretation
Question 7:
Do you need a
safety monitor when employees are working within the perimeter of the warning
line system?
Answer 7:
As addressed in 29
CFR 1926.501(b)(10), individuals involved in roofing work on low-slope roofs
must be protected from falling when exposed to unprotected sides and edges 6
feet or more above lower levels. This section gives several means of protection,
one of which is the combination of a warning line system and a safety monitoring
system. The warning line system is in place to protect those working within its
perimeter, and only at the time when workers are required to go beyond this
system would the monitor be needed to perform those functions listed in
paragraph 1926.502(h).
See Letter of Interpretation
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Region
IV
