In construction activities, fall protection is required when working at heights greater than 6 feet (with some exceptions). How far from the edge do you have to be before fall protection is required? The answer is it doesn’t matter how far from the edge. If there is a fall risk it needs to be addressed. How it is addressed depends on the type of work being done. Subpart M 1926.501 (b)(10) of the OSHA Construction Standards specifies that under certain conditions, roofing work can be conducted with a warning line in place 6 feet from the edge and a safety monitoring system.

But what if you are not working on roofing activities? Mr. Dan Steigerwald asks this question in a Standard Interpretation Letter to OSHA dated January 3, 2005. This Standard Interpretation Letter reaffirms other previously published Standard Interpretation Letters on the same subject. The letter states that at 15 feet from the edge or hole, a warning line combined with effective work rules can be used. All of the following work rules must be followed:

1. A warning line is used 15 feet or more from the edge (or nearest edge of a hole)

2. The warning line meets or exceeds the requirements in 1926.502(f)(2)

3. No work or work-related activity is to take place in the area between the warning line and the hole or edge; and

4. The employer effectively implements a work rule prohibiting the employees from going past the warning line.

If all of these work rules are followed, federal OSHA would consider the fall hazard a de minimis violation of 1926.501(b)(1) Unprotected Sides and Edges. It is stated in the letter that if the barrier did fail to restrain the worker from unintentionally crossing, it would not place the worker in immediate risk of falling off the edge.

Keep in mind that this is a Federal Standard Interpretation. State Plans such as Kentucky may not recognize this exception. Fall protection still must be used when setting up this warning line system or when the work rules discussed earlier can not be met. Hazards such as skylights are considered holes and must also be addressed. Some rooftop work may be considered service or maintenance and would be enforced under the 1910 General Industry Standards. Take a look at the Standard Interpretation Letters below.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24802

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23873

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24354

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24682

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24801

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24998