OSHA Auditing: Federal Compliance: Construction: The Complete Health and Safety Audit Checklist

Sample OSHA Auditing: Federal Compliance: Construction:

The Complete Safety and Health Audit Checklist

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OSHA Auditing:

Federal Compliance Guide – Construction

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OSHA Auditing: Federal Compliance Guide – Construction

A tool for assessing a facility’s compliance with the Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1926 and the general record-keeping requirements of 29 CFR 1904

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Users of This Guide Include

• General construction and demolition contractors

• Specialty construction contractors and developers

• Construction and state inspectors

• Engineering consultants • Utility and larger

corporations • And many more…

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Features of This Guide

• Field-tested by recognized experts

• Helps ensure compliance • Helps avoid citations and

fines • Allows experienced auditors

to expedite their assessment • Allows less experienced

auditors to review detailed instructions

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Features of This Guide

• Saves time and reduces compliance and audit costs

• Demonstrates due diligence • Customizable to site-specific

requirements • Applicability Tables • Pre-audit Preparation • Rulebooks • Scoresheets

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Comprehensive Topic Areas

• General safety and health • General recordkeeping and

posting • Occupational exposures and

environmental controls • Hazardous waste operations

and emergency response • Process safety • Personal protective and life

saving equipment

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Comprehensive Topic Areas

• Fire protection and prevention

• Signs, signals and barricades • Materials handling • Hand and power tools • Welding and cutting • Electrical • Scaffolds • Fall protection • Demolition

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Features – Applicability Tables

Use multi-level questions to quickly determine which regulations and sections of the rulebooks apply to specific facilities or operations

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Sample Applicability Table

BLASTING AND USE OF EXPLOSIVES.

Applicability of This Module

.PART 1: INTRODUCTION

Use the following General Applicability Checklist to determine whether a rulebook and its sectionsapply to your operation.

If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for arulebook exemption.

Once you determine that the rulebook does apply to your operation, you must answer the sectionquestions. If a section question does not exist, then that section applies if the rulebook applies. If youanswer YES to a section question, that section applies to you unless you answer YES for an exemptionfrom that section. If you answer YES to a rulebook or section exemption, then the rulebook or sectiondoes not apply.

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GENERAL APPLICABILITY CHECKLIST Applies Exempt.

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Rulebook: Blasting and Use of Explosives.

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Y NRULEBOOK: Do you handle, transport, use, or store explosives in construction activities?.

q q.............................................................................................................................................................................................................................................................. ........................... ...........................

Y NSection 2: Do you have employees who are blasters?.

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q q.............................................................................................................................................................................................................................................................. ........................... ...........................

Y NSection 3: Do your operations involve surface transportation of explosives?.

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Y NSection 4: Do your operations involve underground transportation of explosives?.

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Y NSection 5: Do your operations include storage of explosives or blasting agents at constructionsites? q q.

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Y NSection 6: Do your operations include loading or preparing explosive or blasting agents foruse? q q.

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Y NSection 7: Do your operations include initiating explosives charges with electricity?.

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Y NSection 8: Do your operations include initiating explosives charges with safety fuse?.

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Y NSection 9: Do your operations include initiating explosives charges with detonating cord?.

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q q

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Features – Pre-audit Preparation

Lists materials to be reviewed or prepared before conducting an audit

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Sample Pre-audit Preparation

SCAFFOLDS.

Items to consider getting in advance:

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.PART 2: PRE–AUDIT PREPARATION.

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• Access to the information in 29 CFR 1926 Subpart L.

• Access to the information in OSHA Directive CPL 02-01-023, “Inspection Procedures forEnforcing Subpart L, Scaffolds Used in Construction,” available online at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1528.

OSHA has also adopted the following third party standards. We have listed the standards that arecited in the regulations. We have provided contact information for each of the referenced thirdparties in the appendix to the general introduction (located at the beginning of this manual).

• The following standards of the American National Standard Institute (ANSI) and the ScaffoldingIndustry Association (SIA) (as provided in Appendix C to Subpart L):– ANSI/SIA A92.2-1990, “Vehicle Mounted Elevating and Rotating Aerial Devices,” including

Appendix.– ANSI/SIA A92.3-1990, “Manually Propelled Elevating Aerial Platforms.”– ANSI/SIA A92.5-1992, “Boom-Supported Elevating Work Platforms.”– ANSI/SIA A92.6-1990, “Self-Propelled Elevating Work Platforms.”– ANSI/SIA A92.7-1990, “Airline Ground Support Vehicle-Mounted Vertical Lift Devices.”– ANSI/SIA A92.8-1993, “Vehicle-Mounted Bridge Inspection and Maintenance Devices.”– ANSI A92.9-1993, “Mast-Climbing Work Platforms.” (Note: This Standard is not currently

available.)

• The following Standards of the American Welding Society (AWS):– AWS B3.0-41, “Welding Procedure and Performance Qualification.”– AWS D8.4-61, “Recommended Practices for Automotive Welding Design.” (Note: This

Standard has been withdrawn and has not been replaced.)– AWS D10.9-69, “Standard Qualification of Welding Procedures and Welders for Piping and

Tubing.”– AWS D2.0-69, “Specifications for Welding Highway and Railway Bridges.” (Note: This

Standard is not currently available.)

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Features – Rulebooks

Provide a comprehensive set of regulatory requirement statements, plus detailed guidance on compliance issues and inspection procedures

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Sample Rulebook

SCAFFOLDS.

1. Scaffold Capacity

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.PART 3: RULEBOOK

The requirements of this rulebook do not apply to crane or derrick suspended personnelplatforms. The criteria for aerial lifts are set out exclusively in 29 CFR 1926.453(see section 34).

All dimensions are nominal sizes as provided in the American Lumber Standards, except thatwhere rough sizes are noted, only rough or undressed lumber of the size specified will satisfyminimum requirements.

NOTE: OSHA has determined that standing on the guardrails of lifting equipment such asaerial lifts or scissor lifts is not a suitable substitute for the use of scaffolding, even if theemployee is wearing fall protection. There may be specific prohibitions in some regulations,but even in the absence of such regulations, the guardrails would have to meet allrequirements for scaffolding, including load requirements, and it is unlikely that these could bemet (OSHA Interpretation Letter, 10/23/02).

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1.1 Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a))

Guide Note• Review the design of each scaffold and scaffold component to ensure it is capable of supporting, without

failure, its own weight and at least four times the maximum intended load applied or transmitted to it, exceptas provided in 29 CFR 1926.451(a)(2) – (a)(5) and (g) (see section 7) (29 CFR 1926.451(a)(1)).

• Review the design to verify that direct connections to roofs and floors, and counterweights used to balanceadjustable suspension scaffolds are capable of resisting at least four times the tipping moment (the tendency tocause a tip) imposed by the scaffold operating at the rated load of the hoist, or at least 1.5 times the tippingmoment imposed by the scaffold operating at the stall load of the hoist, whichever is greater (29 CFR1926.451(a)(2)).

• Verify that each suspension rope, including connecting hardware, used on nonadjustable suspension scaffoldsis capable of supporting, without failure, at least six times the maximum intended load applied or transmittedto that rope (29 CFR 1926.451(a)(3)).

• Verify that each suspension rope, including connecting hardware, used on adjustable suspension scaffolds iscapable of supporting, without failure, at least six times the maximum intended load applied or transmitted tothat rope with the scaffold operating at either the rated load of the hoist, or at least two times the stall load ofthe hoist, whichever is greater (29 CFR 1926.451(a)(4)).

• Ensure that the stall load of any scaffold hoist does not exceed three times its rated load (29 CFR1926.451(a)(5)).

• Ensure that all scaffolds are designed by a qualified person and are constructed and loaded in accordance withthat design (see Key Compliance Definitions in the Introduction to this module for the definition of a“qualified person”) (29 CFR 1926.451(a)(6)).

NOTE: Non-mandatory Appendix A of this Subpart contains examples of construction, loading, and designcriteria for scaffolds.

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Features – Scoresheets

Enable quick recording of a facility’s compliance status for each requirement Scoresheets are customizable

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Sample Scoresheet

SCAFFOLDS.

Scaffold Capacity

Scaffold Platform Construction

Supported Scaffolds

Suspension Scaffolds

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.PART 4: SCORESHEET

SITE: DATE:Does not1.

. N/A Complies

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.

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. comply

1.1 Scaffolds must meet certain capacity requirements. (29 CFR 1926.451(a)) q q q

Does not2.. N/A Complies.... comply

2.1 Scaffold platforms must be fully planked or decked according to specific q q qrequirements. (29 CFR 1926.451(b)(1))

2.2 Scaffold platforms and walkways must be a certain width. (29 CFR 1926.451(b)(2)) q q q

2.3 The front edge and ends of platforms must be certain distances from the work and q q qfrom their supports. (29 CFR 1926.451(b)(3) – (b)(5))

2.4 Certain requirements must be met on scaffolds where planks are abutted and where q q qplatforms are overlapped. (29 CFR 1926.451(b)(6) – (b)(7))

2.5 Scaffold platforms that change direction must meet certain requirements. (29 CFR q q q1926.451(b)(8))

2.6 The coating used on wood platforms must be in accordance with specific q q qrequirements. (29 CFR 1926.451(b)(9))

2.7 Different scaffold components may be used only under certain circumstances. q q q(29 CFR 1926.451(b)(10) – (b)(11))


3.1 Supported scaffolds must meet certain criteria. (29 CFR 1926.451(c)) q q q


4.1 Resting surfaces for suspension scaffold support devices must meet certain q q qrequirements. (29 CFR 1926.451(d)(1))

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Sample Release Notes

OSHA Auditing: FederAl COmpliAnCe guide: COnStruCtiOn

Release #158

July 2012

new And nOtewOrtHy

• The Occupational Health and Safety Administration (OSHA) has issued a direct final rule that modifies the requirements for head protection contained in 29 CFR 1926.100(b). This change removes the 1969 edition of ANSI Z89.1 “Safety Requirements for Industrial Head Protection,” and allows compliance with the 1997, 2003, or 2009 editions of the ANSI Standard. This rule will become effective on September 20, 2012.

HigHligHtS OF tHiS releASe

• Personal Protective and Life Saving Equipment (Module E) Rulebook section 3 has been updated to reflect the OSHA change indicated in “New and Noteworthy” above.

• All sections of this Guide are being reviewed to ensure that the supplemental information which is included to assist customers in applying regulations is current, relevant, and clearly worded. Towards this end, the notes in the rulebooks that refer the user to OSHA Letters of Interpretation and Compliance Directives are being edited. Modules are also being edited to improve the clarity of the information they contain, the wording of the cross-references for users of paper editions of the publication, and the linking function for users of electronic versions.

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FALL PROTECTION.

Applicability of This Module

.PART 1: INTRODUCTION

Use the following General Applicability Checklist to determine whether a rulebook and its sectionsapply to your operation.If you answer YES to the rulebook question, the rulebook applies to you unless you answer YES for arulebook exemption.

Once you determine that the rulebook does apply to your operation, you must answer the sectionquestions. If a section question does not exist, then that section applies if the rulebook applies. If youanswer YES to a section question, that section applies to you unless you answer YES for an exemptionfrom that section. If you answer YES to a rulebook or section exemption, then the rulebook or sectiondoes not apply.

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Rulebook: Fall Protection.

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Y NRULEBOOK: Do you have situations at your construction site where employees may beexposed to a significant fall? q q.

Y NRULEBOOK Exemption: Do you meet any of the following exceptions:• employees making an inspection, investigation, or assessment of workplace conditions q q

prior to the actual start of construction work or after all construction work has beencompleted;

• employees work on scaffolds (see Scaffolds (Module M) Applicability Checklist);• employees work on certain cranes and derricks (see Cranes and Derricks in Construction

(Module CC) Applicability Checklist);• employees perform steel erection work (except towers and tanks) (see Steel Erection

(Module R) Applicability Checklist);• employees work on certain types of equipment used in tunneling operations (see

Underground Construction (Module S) Applicability Checklist);• employees are engaged in the erection of tanks and communication and broadcast towers

(see Personal Protective and Life Saving Equipment (Module E) Applicability Checklist);• employees are engaged in construction of electric transmission and distribution lines and

equipment (see Power Transmission and Distribution (Module V) ApplicabilityChecklist); or

• employees work on stairways and ladders (see Stairways and Ladders (Module X)Applicability Checklist)?

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Y NSection 3: Do you utilize personal fall arrest systems for fall protection?.

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Y NSection 4: Do you utilize positioning systems for fall protection?.

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Y NSection 5: Do you conduct roof work requiring the use of warning lines around roofs for fallprotection? q q.

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Y NSection 6: Do you utilize a controlled access zone as part of your fall protection system?.

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COA 3/12 ©STP FL/Part 1 - 1

Fall Protection Introduction. . .


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Y NSection 7: Do your construction activities involve the use of safety monitoring systems forfall protection? q q

NOTE: Employees engaged in roofing activities on low-slope roofs, with unprotectedsides and edges 6 feet (1.8 m) or more above lower levels must be protected from fallingby guardrail systems, safety net systems, personal fall arrest systems, or a combination ofwarning line system and guardrail system, warning line system and safety net system, orwarning line system and personal fall arrest system, or warning line system and safetymonitoring system. Or, on roofs 50 feet (15.25 m) or less in width (see 29 CFR 1926Subpart M Appendix A), the use of a safety monitoring system alone (i.e. without thewarning line system) is permitted (29 CFR 1926.510(b)(10)).

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Y NSection 8: Do your construction activities involve the use of covers on holes located inroadways or vehicle aisles? q q.

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Y NSection 9: Do your construction activities require the use of protection from falling objects?.

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q q.

FL/Part 1 - 2 COA 3/12 ©STP

Regulatory Summary

Fall Protection Introduction

This module covers fall protection regulations found in 29 CFR 1926 Subpart M, which includes29 CFR 1926.500 – 1926.503 and 29 CFR 1926 Appendix A – Appendix E. The federal regulationsthat apply are organized into the following major sections:• 29 CFR 1926.500 Scope, Application, and Definitions• 29 CFR 1926.501 Duty to Have Fall Protection• 29 CFR 1926.502 Fall Protection Systems Criteria and Practices• 29 CFR 1926.503 Training Requirements

The following non-mandatory appendices to 29 CFR 1926 Subpart M serve as guidelines to assistemployers in complying with the appropriate requirements of this subpart:• 29 CFR 1926 Appendix A, “Determining Roof Widths – Non-Mandatory Guidelines for

Complying with 29 CFR 1926.501(b)(10),” provides illustrations of roof plans and indicates whereeach roof or roof area is to be measured to determine its width for fall protection purposes.

• 29 CFR 1926 Appendix B, “Guardrail Systems – Non-Mandatory Guidelines for Complying with29 CFR 1926.502(b),” serves as a guideline and starting point to assist employers who aredesigning guardrail systems.

• 29 CFR 1926 Appendix C, “Personal Fall Arrest Systems – Non-Mandatory Guidelines forComplying with 29 CFR 1926.502(d),” provides test methods and other guidelines for personal fallarrest systems and positioning device systems. Guidelines for positioning device systems are alsocovered in 29 CFR 1926 Appendix D.

• 29 CFR 1926 Appendix D, “Positioning Device Systems – Non-Mandatory Guidelines forComplying with 29 CFR 1926.502(e),” provides testing methods and inspection considerations forpositioning device systems.

• 29 CFR 1926 Appendix E, “Sample Fall Protection Plan – Non-Mandatory Guidelines forComplying with 29 CFR 1926.502(k),” provides sample fall protection plans forprecast/prestressed concrete structures, residential construction, and leading edge work.

These federal regulations address fall protection requirements in construction work in states thatfollow the federal Occupational Safety and Health Administration (OSHA) program and in states thathave their own programs but have adopted the federal regulations. They also apply to federalemployees and any construction work performed on federally owned property, no matter where itoccurs.

Some states and local agencies impose requirements in addition to those listed in this module. Sinceemployers must meet all applicable requirements, it is important to review regulations at the state andlocal level as well.

OSHA frequently adopts third party standards by incorporating them by reference into the regulations.These standards are provided by other governmental, non-profit, or trade organizations (such as theAmerican National Standards Institute [ANSI]). Many of these third party standards have been revisedsince they were first incorporated into the regulations; however, because OSHA frequently has notadopted the updates, it typically cannot enforce the requirements contained in the most recent versionof the standard (unless imminent danger is present). Throughout this module, we refer to the thirdparty standards that are cited in the regulations, even though in many cases these standards have beenrevised, replaced, and/or deleted. We have provided contact information for each of the referencedthird party standards so that you can obtain the most recent information.


Key Compliance Definitions


The following definitions are derived from 29 CFR 1926.500(b) unless otherwise noted. Thedefinitions of some general terms discussed in this module may be found in module C, “GeneralSafety and Health.”

Anchorage – A secure point of attachment for lifelines, lanyards, or deceleration devices.

Body belt (Safety belt) – A strap with means both for securing it about the waist and for attaching it toa lanyard, lifeline, or deceleration device.

Body harness – Straps that, when secured about the employee, will distribute the fall arrest forcesover at least the thighs, pelvis, waist, chest, and shoulders and that have means for attaching theharness to other components of a personal fall arrest system.

NOTE: This definition does not require nor does it exclude the use of a waist or chest strap as part ofa full body harness, as long as the harness properly distributes the fall arrest forces (OSHAInterpretation and Compliance Letter 09/23/1999).

Buckle – Any device for holding the body belt or body harness closed around the employee’s body.

Connector – A device that is used to couple (connect) parts of the personal fall arrest system andpositioning device systems together. A connector may be an independent component of the system(such as a carabiner) or it may be an integral component of part of the system (such as a buckle ordee-ring sewn into a body belt or body harness, or a snap-hook spliced or sewn to a lanyard or self-retracting lanyard).

Controlled access zone (CAZ) – An area to which access is controlled and in which certain work (e.g.,overhand bricklaying) may take place without the use of guardrail systems, personal fall arrestsystems, or safety net systems.

Dangerous equipment – Equipment (such as pickling or galvanizing tanks, degreasing units,machinery, electrical equipment, and other units) that, because of form or function, may be hazardousto employees who fall onto or into such equipment.

Deceleration device – Any mechanism that serves to dissipate a substantial amount of energy during afall arrest or otherwise limit the energy imposed on an employee during fall arrest. Decelerationdevices include but are not limited to rope grabs, rip-stitch lanyards, specially woven lanyards, tearingor deforming lanyards, and automatic self-retracting lifelines/lanyards.

Deceleration distance – The vertical distance a falling employee travels before stopping, excludinglifeline elongation and free fall distance, from the point at which the deceleration device begins tooperate. Deceleration distance is measured as the distance between the location of an employee’sbody belt or body harness attachment point at the moment of activation (at the onset of fall arrestforces) of the deceleration device during a fall, and the location of that attachment point after theemployee comes to a full stop.

Equivalent – Alternative designs, materials, or methods that protect against a hazard and that theemployer can demonstrate will provide an equal or greater degree of safety for employees than themethods, materials, or designs specified in the standard.



Failure – The occurrence of load refusal, breakage, or separation of component parts. (Load refusal isthe point where the structural members lose their ability to carry the load.)

Free fall – The act of falling before a personal fall arrest system begins to apply force to arrest thefall.

Free fall distance – The vertical displacement of the fall arrest attachment point on the employee’sbody belt or body harness between onset of the fall and the time that the system begins to apply forceto arrest the fall. This distance excludes deceleration distance and lifeline/lanyard elongation, butincludes any deceleration device slide distance or self-retracting lifeline/lanyard extension that occursbefore the fall arrest forces begin.

Guardrail system – A barrier erected to prevent employees from falling to lower levels.

Hole – A gap or void that is 2 inches (5.1 cm) or more in its least dimension and that is located in afloor, roof, or other walking/working surface.

Infeasible – Impossible to perform the construction work using a conventional fall protection system(i.e., guardrail system, safety net system, or personal fall arrest system) or technologically impossibleto use any conventional fall protection system to provide fall protection.

Lanyard – A flexible rope, wire rope, or strap that generally has a connector at each end forconnecting the body belt or body harness to a deceleration device, lifeline, or anchorage.

Leading edge – The edge of a floor, roof, or formwork for a floor or other walking/working surface(such as the deck) that changes location as additional floor, roof, decking, or formwork sections areplaced, formed, or constructed. A leading edge is considered an unprotected side and edge duringperiods when it is not actively and continuously under construction.

Lifeline – A flexible line that connects either to an anchorage at one end to hang vertically (verticallifeline) or anchorages at both ends to stretch horizontally (horizontal lifeline), and that serves toconnect other components of a personal fall arrest system to the anchorage.

Low-slope roof – A roof with a slope less than or equal to 4 to 12 (vertical to horizontal).

Lower levels – Those areas or surfaces to which an employee can fall. Such areas or surfaces include,but are not limited, to ground levels, floors, platforms, ramps, runways, excavations, pits, tanks,material, water, equipment, structures, or portions thereof.

Mechanical equipment – All motor or human propelled wheeled equipment used for roofing work,except wheelbarrows and mopcarts.

Opening – A gap or void 30 inches (76 cm) or more high and 18 inches (48 cm) or more wide that islocated in a wall or partition through which employees can fall to a lower level.

Overhand bricklaying and related work – The process of laying bricks and masonry units such thatthe surface of the wall to be jointed is on the opposite side of the wall from the mason, requiring themason to lean over the wall to complete the work. Related work includes mason tending and electricalinstallation incorporated into the brick wall during the overhand bricklaying process.



Personal fall arrest system – A system used to arrest an employee in a fall from a working level.Personal fall arrest systems consist of an anchorage, connectors, and a body belt or body harness andmay include a lanyard, deceleration device, lifeline, or suitable combinations of these. As ofJanuary 1, 1998, the use of a body belt for fall arrest is prohibited.

Positioning device system – A body belt or body harness system rigged to allow an employee to besupported on an elevated vertical surface, such as a wall, and work with both hands free whileleaning.

Roof – The exterior surface on the top of a building. The term roof does not include floors orformwork that, because a building has not been completed, temporarily become the top surface of abuilding.

Roofing work – The hoisting, storage, application, and removal of roofing materials and equipment,including related insulation, sheet metal, and vapor barrier work, but not including the construction ofthe roof deck.

Rope grab – A deceleration device that travels on a lifeline and automatically, by friction, engages thelifeline and locks to arrest the fall of an employee. A rope grab usually employs the principle ofinertial locking, cam/level locking, or both.

Safety belt – See Body belt above.

Safety-monitoring system – A safety system in which a competent person is responsible forrecognizing and warning employees of fall hazards.

Self-retracting lifeline/lanyard – A deceleration device containing a drum-wound line that can beslowly extracted from, or retracted onto, the drum under slight tension during normal employeemovement, and that, after onset of a fall, automatically locks the drum and arrests the fall.

Snaphook – A connector comprised of a hook-shaped member with a normally closed keeper, orsimilar arrangement, that may be opened to permit the hook to receive an object and, when released,automatically closes to retain the object. Snaphooks are generally one of two types:• the locking type, with a self-closing, self-locking keeper that remains closed and locked until

unlocked and pressed open for connection or disconnection; or• the non-locking type, with a self-closing keeper that remains closed until pressed open for

connection or disconnection.

NOTE: As of January 1, 1998, the use of a non-locking snaphook as part of personal fall arrestsystems and positioning device systems is prohibited.

Steep roof – A roof having a slope greater than 4 to 12 (vertical to horizontal).

Toeboard – A low protective barrier that will prevent the fall of materials and equipment to lowerlevels and provide protection from falls for personnel.

Unprotected sides and edges – Any side or edge (except at entrances to points of access) of awalking/working surface (e.g., a floor, roof, ramp, or runway) where there is no wall or guardrailsystem at least 39 inches (1.0 m) high.



Walking/working surface – Any surface, whether horizontal or vertical, on which an employee walksor works, including but not limited to floors, roofs, ramps, bridges, runways, formwork, and concretereinforcing steel, but not including ladders, vehicles, or trailers on which employees must be locatedin order to perform their job duties.

Warning line system – A barrier erected on a roof that warns employees that they are approaching anunprotected roof side or edge and that designates an area in which roofing work may take placewithout the use of guardrail, body belt, or safety net systems to protect employees in the area.

Work area – That portion of a walking/working surface where job duties are being performed.


Appendices


Appendix 1: OSHA Compliance Letters

OSHA’S Enforcement Policy - Residential Construction

OSHA’s Standard Interpretation, 05/25/00, contains a memorandum from the Director, Directorate ofConstruction clarifying a number of questions regarding residential construction. (See also OSHA’srelated Standard Interpretation, 08/10/00.)

Q1: Is apartment construction considered residential construction?

Only if the apartment complex is constructed using the same materials and methods as aretraditionally used for wood framed single-family houses and townhouses (i.e., raising stick framedwalls, installing wood trusses and floor joists, etc.) would its construction be considered residential.An apartment constructed with precast concrete floors, structural steel, or other materials that are nottraditionally used in stick frame home construction would not be considered residential constructionand would be beyond the scope of STD 3-0.1A.

Q2: If residential construction materials and techniques are used for something other than aresidence, is the project considered residential construction? (Example: It looks like a house butwill be used as a dentist’s office.)

Yes. Note the answer to the next question.

Q3: Can you clarify the definition of residential construction?

This was a common request prior to the issuance of STD 3-0.1A. Section VIII of the new plainlanguage directive more thoroughly depicts what would constitute residential construction. It statesthat where the working environment, materials, methods, and procedures are essentially the same asthose used in building a typical single-family home or townhouse, the employer would be consideredengaged in residential construction. Wood framing (not steel or concrete), wooden floor joists androof structures are characteristic of the materials used, and traditional wood frame constructiontechniques are the methods used in residential construction. OSHA also recognizes metal studs as onefor one substitutions for the 2X4 wooden studs used in modern residential construction. Structures thatuse metal studs are considered residential construction if they meet the other criteria for residentialconstruction.

Q4: How do the appendices for the fall protection standard relate to residential construction?

The appendices are non-mandatory — there is no requirement that they be followed. However, inspecified circumstances, an employer that follows them will be considered to be in compliance withthe standard. When a residential contractor can demonstrate that conventional fall protection either isinfeasible or creates a greater hazard, section 1926.501(b)(13) permits the use of a fall protection plan,as outlined in 1926.502(k). Appendix E provides sample fall protection plans that contain the requiredelements.



Q5: What are the spacing requirements for slide guards on roofs?

The spacing requirements are listed in STD 3-0.1A, Section D. “Alternative Procedures for Group 1and Section G. – Alternative procedures for Group 4.” If an employer elects to follow STD 3-0.1A, oris operating under the Roof Sheathing Operations section of Appendix E (59 FR 40753), it mustfollow the spacing requirements in the Directive or the Appendix (they are the same). For a fullexplanation of these guidelines, refer to the June 18, 1999 directive.

Q6: If the slide guards are not properly spaced, what should we cite?

If an employer (engaged in residential construction) does not provide conventional fall protection, thecompliance officer must determine if STD 3-0.1A provides alternative procedures for the activity inquestion. If alternative procedures are available, the compliance officer must then determine whetherthey have been properly implemented. If they have not, cite 1926.501(b)(13). No other provision maybe cited for a fall hazard addressed by .501(b)(13). Deficiencies in training required by 1926.20 maybe cited where appropriate.

Q7: What fall protection is required when trusses and rafters are being placed?

For employers operating under STD 3-0.1A (or Appendix E), the procedures are listed in STD 3-0.1A, Section VIII, paragraph D.

Q8: In light of the fact that devices (such as the “Truss-T”) have been developed, can residentialconstruction employers still claim that it is infeasible or creates a greater hazard to useconventional fall protection equipment when performing this work? Will we continue to allowemployees to walk the walls, trusses, etc. without conventional fall protection equipment?

As long as STD 3-0.1A is in effect, employers may use the alternative procedures in the Directive forthe specified operations without showing that conventional fall protection is infeasible. The issue ofwhether this policy should continue is being examined through the Advanced Notice of ProposedRulemaking (ANPR) for subpart M. The ANPR sought public comment on many of the questions youhave asked.



Appendix 2: Suggestions for Fall Protection During Installation of Roof Framing, Trusses, andComponents

OSHA Standard Interpretation, 08/03/99, offers employers the following control suggestions to protectemployees during residential construction and installation of roof framing, trusses, and components.Additional information for residential construction may be found in the OSHA Directive, STD 3-0.1A, “Plain Language Revision of OSHA Instruction STD 3.1, Interim Fall Protection ComplianceGuidelines for Residential Construction” (effective June 18, 1999). (NOTE: STD 3-0.1A replacedSTD 3.1, “Interim Fall Protection Compliance Policy For Certain Residential Construction Activities,”published December 8, 1995.)

One method is to assemble the roof as a unit on the ground and then raise it by crane.

Another method involves the use of both roof anchors (permanent as well as removable anchors areavailable) and reusable truss braces. The reusable truss braces allow the trusses to be braced withoutbeing on them. In this type of system, one end of the device is attached to the truss on the ground; theother end has a rope attached to it. The truss is then erected either by crane or manually. Twomethods are commonly used to erect them manually. In both approaches workers at either end of thetruss work from ladders or platforms. In one approach the workers directly lift and place the truss onthe top plates. In the other approach, the truss is first placed upside down between the exterior walls.The workers then rotate it up into place on the top plates. In either case, one or more roof anchors arealso attached to one or more strategically located trusses before those trusses are erected.

Once the truss is raised, a worker on the floor level pulls the rope that is attached to the other end ofthe brace, which brings that end of the brace down onto the adjoining truss. At that point the brace islocked onto both trusses. The process is repeated as each truss is erected. Depending on the size of thetruss, two or more braces are used per truss.

With all the braces locked in place, the trusses can now be sheathed. The initial courses of sheathing,beginning at the eaves, are installed by workers who are on the inside of the structure on platforms.They remove the braces one at a time, as each sheet of sheathing is installed.

Some employers will install all but the last (top) course from platforms on the inside. The last courseis then sheathed by workers on the roof who are tied-off to the previously installed roof anchor(s).Others install added (wood) bracing sufficient to support a roof anchor so that the almost all of thesheathing courses can be installed by workers on the roof while tied-off. Once the sheathing is done,the weatherproofing material and roof-mounted equipment can be installed with workers tied-off tothe previously installed roof anchor(s).

There are a number of different types of roof anchors available for use during sheathing. Many aremade of metal and attach by screws or nails to a truss or framing members. Another type is comprisedof a D-ring attached to a fabric strap. The strap is nailed to and wrapped around one or more rooftrusses. The anchor is removed by cutting the D-ring from the strap or using double-headed nails toallow the nails and the strap to be removed.


FALL PROTECTION.

Items to consider getting in advance:

Items to have facility personnel prepare or gather in advance:

.

.PART 2: PRE–AUDIT PREPARATION

• Access to the information in 29 CFR 1926 Subpart M.• Access to the information in OSHA Directive STD 03-00-001, “Fall Protection Requirements for

Residential Construction,” available online at www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2288.

• Access to the information on OSHA’s Construction Fall Protection webpage atwww.osha.gov/SLTC/fallprotection/construction.html.

• Written certifications of fall protection training.• Fall protection training curriculum.• Equipment inspection and repair records. The next page has been removed from this sample.


www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2288

www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2288

www.osha.gov/SLTC/fallprotection/construction.html

Acronyms and Abbreviations Used in This Module

Fall Protection Pre–audit Preparation

ANPR Advanced Notice of Proposed kg kilogram(s)Rulemaking kN kilonewtons

ANSI American National Standards lb pound(s)Institute m meter(s)

CAZ controlled access zone N newton(s)CFR Code of Federal Regulations OSHA Occupational Safety and Healthcm centimeter(s) Administrationft foot/feet STD Standard


FALL PROTECTION.

1. Duty to Have Fall Protection

.

.PART 3: RULEBOOK

.

1.1 Walking/working surfaces must have the strength and structural integrity to support employeessafely. (29 CFR 1926.501(a)(2))Guide Note• Review procedures and interview employees to ensure that the walking/working surfaces on which employees

are to work have the strength and structural integrity to support employees safely (29 CFR 1926.501(a)(2)).• Verify that employees are allowed to work only on those surfaces that have the requisite strength and

structural integrity (29 CFR 1926.501(a)(2)).

1.2 Employees on a walking/working surface must be protected from falling under certaincircumstances. (29 CFR 1926.501(b)(1))Guide Note• Verify that each employee on a walking/working surface (horizontal and vertical) with an unprotected side or

edge that is 6 ft (1.8 m) or more above a lower level is protected from falling by the use of guardrail systems,safety net systems, or personal fall arrest systems (29 CFR 1926.501(b)(1)).NOTE 1: The edge of a completed swimming pool not yet filled with water is considered an unprotected sideor edge of a walking/working surface and conventional fall protection would be required if workers wereexposed to a fall of 6 ft or more (OSHA Standard Interpretation, 06/08/98).NOTE 2: This requirement also applies to fall protection during construction activities when employees areworking 6 ft or more above water (OSHA Standard Interpretation, 09/28/99).

1.3 Employees who are constructing leading edges or working nearby must be protected fromfalling. (29 CFR 1926.501(b)(2))Guide Note• Verify that each employee who is constructing a leading edge that is 6 ft (1.8 m) or more above lower levels is

protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems(29 CFR 1926.501(b)(2)(i)).NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use thesesystems, the employer must develop and implement a fall protection plan that meets the requirements of29 CFR 1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and willnot create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly,the burden of proof is on the employer to establish that it is appropriate to implement the fall protection planonly.

• Verify that each employee on a walking/working surface 6 ft (1.8 m) or more above a lower level whereleading edges are under construction, but who is not engaged in the leading edge work, is protected fromfalling by a guardrail system, safety net system, or personal fall arrest system (29 CFR 1926.501(b)(2)(ii)).NOTE: If a guardrail system is chosen to provide the fall protection, and a controlled access zone (CAZ) hasalready been established for leading edge work, the control line may be used in lieu of a guardrail along theedge that parallels the leading edge.

1.4 Employees in a hoist area must be protected from falling. (29 CFR 1926.501(b)(3))Guide Note• Verify that each employee in a hoist area is protected from falling 6 ft (1.8 m) or more to lower levels by

guardrail systems or personal fall arrest systems (29 CFR 1926.501(b)(3)).


Fall Protection Rulebook

• Review work practices to verify that if chains, gates, guardrail systems, or portions thereof are removed tofacilitate the hoist (e.g., during landing of materials), and if an employee must lean through the access openingor out over the edge (e.g., to receive or guide materials), then each employee is protected from fall hazards bya personal fall arrest system (29 CFR 1926.501(b)(3)).NOTE: When all or part of a guardrail has been removed, all employees must be protected by a personal fallarrest system, not just the employee(s) that must lean through the access (OSHA Standard Interpretation, Clipsused for wire rope guardrails; required fall protection in hoist area Question 2., 08/28/00).

1.5 Employees on walking/working surfaces with holes must be protected from falling. (29 CFR1926.501(b)(4))Guide Note• Verify that each employee on walking/working surfaces is protected from falling through holes (including

skylights) more than 6 ft (1.8 m) above lower levels by personal fall arrest systems, covers, or guardrailsystems erected over or around such holes (29 CFR 1926.501(b)(4)(i)).

• Verify that each employee on a walking/working surface is protected from tripping in or stepping into orthrough holes (including skylights) by covers (29 CFR 1926.501(b)(4)(ii)).NOTE 1: This provision does not specify a minimum depth for this requirement to apply (OSHA StandardInterpretation, 11/17/98).NOTE 2: OSHA clarifies the terms “hole” versus “unprotected sides or edges” in their Standard Interpretation,08/14/00.

• Verify that each employee on a walking/working surface is protected from objects falling through holes(including skylights) by covers (29 CFR 1926.501(b)(4)(iii)).NOTE: OSHA will treat a skylight as a cover if it is capable of supporting, without failure, at least twice theweight of employees, equipment, and materials that may be imposed on it at any one time (OSHA StandardInterpretation, 12/20/07).

1.6 Employees on the face of formwork or reinforcing steel must be protected from falling.(29 CFR 1926.501(b)(5))Guide Note• Verify that each employee on the face of formwork or reinforcing steel used in concrete structures is protected

from falling 6 ft (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, orpositioning device systems (29 CFR 1926.501(b)(5)).NOTE: Fall protection is not necessary for employees climbing or moving on built-in-place rebar assemblies atheights below 24 ft above lower levels, as the multiple hand holds and foot holds on rebar assemblies provideprotection similar to that of a fixed ladder. However, once employees have reached their work stations, or havemoved to points at least 24 ft above lower levels, fall protection is required (OSHA Standard Interpretation,05/19/97). On formwork, employees must be protected at all times where the fall distance is 6 ft or moreabove lower levels, including when employees are moving from point to point (OSHA Standard Interpretation,08/28/00).

1.7 Employees on ramps, runways, and other walkways must be protected from falling. (29 CFR1926.501(b)(6))Guide Note• Verify that each employee on ramps, runways, and other walkways is protected from falling 6 ft (1.8 m) or

more to lower levels by guardrail systems (29 CFR 1926.501(b)(6)).

1.8 Employees at the edge of excavations must be protected from falling. (29 CFR 1926.501(b)(7))Guide Note• Verify that each employee at the edge of excavations 6 ft (1.8 m) or more in depth is protected from falling by

guardrail systems, fences, or barricades when the excavations are not readily seen because of plant growth orother visual barrier (29 CFR 1926.501(b)(7)(i)).

• Verify that each employee at the edge of a well, pit, shaft, and similar excavation 6 ft (1.8 m) or more in depthis protected from falling by guardrail systems, fences, barricades, or covers (29 CFR 1926.501(b)(7)(ii)).



1.9 Employees above dangerous equipment must be protected from falling. (29 CFR1926.501(b)(8))Guide Note• Verify that each employee less than 6 ft (1.8 m) above dangerous equipment is protected from falling into or

onto the equipment by guardrails systems or by equipment guards (29 CFR 1926.501(b)(8)(i)).• Verify that each employee 6 ft (1.8 m) or more above dangerous equipment is protected from fall hazards by

guardrail systems, personal fall arrest systems, or safety net systems (29 CFR 1926.501(b)(8)(ii)).

1.10 Employees performing overhand bricklaying and related work must be protected from falling.(29 CFR 1926.501(b)(9))Guide Note• Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee

performing bricklaying and related work 6 ft (1.8 m) or more above lower levels is protected from falling byguardrail systems, safety net systems, or personal fall arrest systems or that the work is in a CAZ (29 CFR1926.501(b)(9)(i)).

• Review work practices to verify that employees reaching more than 10 inches (25 cm) below the level of thewalking/working surface on which they are working are protected from falling by a guardrail system, safetynet system, or personal fall arrest system (29 CFR 1926.501(b)(9)(ii)).NOTE: Bricklaying operations performed on scaffolds are regulated under 29 CFR 1926 Subpart L (seemodule L, “Scaffolding”).

1.11 Employees engaged in roofing activities on low-slope roofs must be protected from falling.(29 CFR 1926.501(b)(10))Guide Note• Except as otherwise provided in 29 CFR 1926.501(b) (see paragraphs 1.2 – 1.16), verify that each employee

engaged in roofing activities on low-sloped roofs, with unprotected sides and edges 6 ft (1.8 m) or more abovelower levels is protected from falling by any of the following (29 CFR 1926.501(b)(10)):– guardrail systems;– safety net systems;– personal fall arrest systems;– a combination of a warning line system and guardrail system;– a combination of a warning line system and safety net system;– a combination of a warning line system and personal fall arrest system; or– a combination of a warning line system and safety monitoring system.

NOTE 1: On roofs 50 ft (15.25 m) or less in width (see Appendix A to this subpart), the use of a safetymonitoring system alone (i.e., without the warning line system) is permitted. (See also OSHA StandardInterpretation, 01/16/01).NOTE 2: An employer may use a combination of warning lines 6 ft (and in some cases 10 ft) back fromthe edge in combination with monitors in place of personal fall protection equipment or guardrails (OSHAStandard Interpretation, 08/01/00).

1.12 Employees on a steep roof must be protected from falling. (29 CFR 1926.501(b)(11))Guide Note• Verify that each employee on a steep roof with unprotected sides and edges 6 ft (1.8 m) or more above lower

levels is protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrestsystems (29 CFR 1926.501(b)(11)).



1.13 Employees engaged in the erection of precast concrete members must be protected from falling.(29 CFR 1926.501(b)(12))Guide Note• Verify that each employee engaged in the erection of precast concrete members (including but not limited to

the erection of wall panels, columns beams, and floor and roof “tees”) and related operations (such as groutingof precast concrete members) who is 6 ft (1.8 m) or more above lower levels is protected from falling by anyof the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 – 1.16] provides for an alternative fallprotection measure) (29 CFR 1926.501(b)(12)):– guardrail systems;– safety net systems; or– personal fall arrest systems.

NOTE: When the employer can demonstrate that it is infeasible or creates a greater hazard to use thesesystems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not createa greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burdenof proof is on the employer to establish that it is appropriate to implement the fall protection plan only.

1.14 Employees engaged in residential construction must be protected from falling. (29 CFR1926.501(b)(13))Guide Note• Verify that each employee engaged in residential construction who is 6 ft (1.8 m) or more above lower levels

is protected from falling by any of the following (unless 29 CFR 1926.501(b) [see paragraph 1.2 to 1.16]provides for an alternative fall protection measure) (29 CFR 1926.501(b)(13)):– guardrail systems;– safety net systems; or– personal fall arrest systems.

NOTE 1: When the employer can demonstrate that it is infeasible or creates a greater hazard to use thesesystems, the employer can develop and implement a fall protection plan that meets the requirements of 29 CFR1926.502(k) (see paragraph 10.1 below). However, there is a presumption that it is feasible and will not createa greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the burdenof proof is on the employer to establish that it is appropriate to implement the fall protection plan only.NOTE 2: OSHA Instruction STD 03-00-001, “Interim Fall Protection Compliance Guidelines for ResidentialConstruction,” modifies the above requirements. It permits employers engaged in certain residentialconstruction activities (e.g., homebuilders and roofing contractors) to use alternative procedures routinelyinstead of conventional fall protection. Different alternate procedures are specified for different activities. Suchemployers do not have to demonstrate the infeasibility of conventional fall protection as a precondition tousing the STD 03-00-001 alternative procedures. They also do not have to put their fall protection plan inwriting, nor does the plan have to be site-specific .NOTE 3: See the Appendix in the introduction to this module for an OSHA Standard Interpretation, 05/25/00,providing further interpretation on OSHA’s enforcement policy for residential construction.

1.15 Employees working on, at, above, or near wall openings must be protected from falling.(29 CFR 1926.501(b)(14))Guide Note• If there are wall openings (including those with chutes attached) where the outside bottom edge of the wall

opening is 6 ft (1.8 m) or more above lower levels and the inside bottom edge of the wall opening is less than39 inches (1.0 m) above the walking/working surface, then verify that each employee working on, at, above, ornear such openings is protected from falling by any of the following (29 CFR 1926.501(b)(14)):– guardrail systems;– safety net systems; or– personal fall arrest systems.


2. Fall Protection Systems Criteria and Practices


1.16 Employees must be protected from falling on walking/working surfaces not otherwiseaddressed in this section. (29 CFR 1926.501(b)(15))Guide Note• Except as provided in 29 CFR 1926.500(a)(2) (see the Introduction to this module) or in 29 CFR

1926.501(b)(1) – (b)(14) (see paragraphs 1.2 – 1.15), verify that each employee on a walking/working surface6 feet (1.8 m) or more above lower levels is protected from falling by any of the following (29 CFR1926.501(b)(15)):– guardrail systems;– safety net systems; or– personal fall arrest systems.

1.17 Employers must provide protection from falling objects. (29 CFR 1926.501(c))Guide Note• Verify that when employees are exposed to falling objects, the employer has each employee wear a hard hat

and implements one of the following actions (29 CFR 1926.501(c)):– erects toeboards, screens, or guardrail systems to prevent objects from falling from higher levels;– erects a canopy structure and keeps potential fall objects far enough from the edge of the higher level

so that objects will not go over the edge if they are accidentally displaced; or– barricades the area to which objects could fall, prohibits employees from entering the barricaded area, and

keeps objects that may fall far enough away from the edge of the higher level so that those objects willnot go over the edge if they are accidentally displaced.

NOTE: Additional provisions for protection from falling objects are found in 29 CFR 1926.502(j) (see section9).

.

All fall protection systems must be designed according to these requirements and installedbefore employees begin the work requiring fall protection (29 CFR 1926.502(a)(2)).

2.1 Top edge height of top rails, or equivalent guardrail system members, must meet certainrequirements. (29 CFR 1926.502(b)(1))Guide Note• Verify that the top edge height of top rails, or equivalent guardrail system members, is 42 inches (1.1 m) .

± 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of the top edge mayexceed the 45 inch limit, provided the guardrail system meets all other criteria of 29 CFR 1926.502(b) (seealso paragraphs 2.2 – 2.7) (29 CFR 1926.502(b)(1)).NOTE: When employees are using stilts, the top edge height of the top rail, or equivalent member, must beincreased an amount equal to the height of the stilts.

2.2 Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structuralmembers must be installed according to certain requirements. (29 CFR 1926.502(b)(2))Guide Note• Verify that midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members are installed between the top edge of the guardrail system and the walking/working surface whenthere is no wall or parapet wall at least 21 inches (53 cm) high (29 CFR 1926.502(b)(2)). When midrails areused, verify that they are installed midway between the top edge of the guardrail system and thewalking/working level (29 CFR 1926.502(b)(2)(i)).

• Verify that screens and mesh, when used, extend from the top rail to the walking/working level and along theentire opening between top rail supports (29 CFR 1926.502(b)(2)(ii)).

• Verify that intermediate members (such as balusters), when used between posts, are no more than 19 inches(48 cm) apart (29 CFR 1926.502(b)(2)(iii)).

• Verify that other structural members (such as additional midrails and architectural panels) are installed so thatthere are no openings in the guardrail system more than 19 inches (48 cm) wide (29 CFR 1926.502(b)(2)(iv)).



2.3 Guardrail systems must be able to withstand a specified amount of force and pressure. (29 CFR1926.502(b)(3) – (b)(4))Guide Note• Verify that all guardrail systems are capable of withstanding, without failure, a force of at least 200 lb (890 N)

applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along thetop edge (29 CFR 1926.502(b)(3)).

• Verify that when the 200 lb (890 N) test load is applied in a downward direction, the top edge of the guardraildoes not deflect to a height less than 39 inches (1.0 m) above the walking/working level (29 CFR1926.502(b)(4)).NOTE: Guardrail system components selected and constructed in accordance with Appendix B to this subpartmeet this requirement.

2.4 Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structuralmembers must be able to withstand a specified amount of force. (29 CFR 1926.502(b)(5))Guide Note• Verify that midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural

members are capable of withstanding, without failure, a force of at least 150 lb (666 N) applied in anydownward or outward direction at any point along the midrail or other member (29 CFR 1926.502(b)(5)).

2.5 Guardrail systems must be properly constructed to prevent injury. (29 CFR 1926.502(b)(6) –(b)(10) and (b)(14))Guide Note• Verify that guardrail systems are surfaced to prevent injury to an employee from punctures or lacerations and

to prevent snagging of clothing (29 CFR 1926.502(b)(6)).• Verify that the ends of all top rails and midrails do not overhang the terminal posts, except where the overhang

does not constitute a projection hazard (29 CFR 1926.502(b)(7)).• Verify that steel banding and plastic banding are not used as top rails or midrails (29 CFR 1926.502(b)(8)).• Verify that top rails and midrails are at least 1/4 inch (0.6 cm) nominal diameter or thickness to prevent cuts

and lacerations (29 CFR 1926.502(b)(9)).• If wire rope is used for top rails, verify that it is flagged at not more than 6-ft intervals with high-visibility

material (29 CFR 1926.502(b)(9)).• When guardrail systems are used at hoisting areas, verify that a chain, gate, or removable guardrail section is

placed across the access opening between guardrail sections when hoisting operations are not taking place(29 CFR 1926.502(b)(10)).

• Verify that guardrail systems used on ramps and runways are erected along each unprotected side or edge(29 CFR 1926.502(b)(14)).

2.6 Guardrail systems around holes must meet certain requirements. (29 CFR 1926.502(b)(11) –(b)(13))Guide Note• When guardrail systems are used at holes, verify that they are erected on all unprotected sides or edges of the

hole (29 CFR 1926.502(b)(11)).• When guardrail systems are used around holes used for the passage of materials, verify that no more than two

sides of the hole are provided with removable guardrail sections to allow the passage of materials (29 CFR1926.502(b)(12)).

• When the hole is not in use, verify that it is closed over with a cover or that a guardrail system is providedalong all unprotected sides or edges (29 CFR 1926.502(b)(12)).

• When guardrail systems are used around holes that are used as points of access (such as ladderways), verifythat they are provided with a gate, or are so offset that a person cannot walk directly into the hole (29 CFR1926.502(b)(13)).



2.7 Manila, plastic, or synthetic rope must meet certain strength requirements. (29 CFR1926.502(b)(15))Guide Note• Verify that manila, plastic, or synthetic rope being used for top rails or midrails is inspected as frequently as

necessary to verify that it continues to meet the strength requirements of 29 CFR 1926.502(b)(3) (seeparagraph 2.3) (29 CFR 1926.502(b)(15)).NOTE: The OSHA standard does not specify a minimum number of clips when using wire rope as a guardrail.However, as a practical matter, it is unlikely you could meet the specific requirements under 29 CFR1926.502(b) unless you follow the manufacturer’s recommendations for the number of clips to be used on wireropes of different diameters (OSHA Interpretation Letter, 08/28/00).

2.8 Safety net systems must be installed and used according to certain requirements. (29 CFR1926.502(c)(1) – (c)(3))Guide Note• Inspect safety nets to ensure they are installed as close as practicable under the walking/working surface on

which employees are working, but no more than 30 ft (9.1 m) below such level (29 CFR 1926.502(c)(1)).• When nets are used on bridges, verify that the potential fall area from the walking/working surface to the net is

unobstructed (29 CFR 1926.502(c)(1)).• Inspect safety nets to ensure they extend outward from the outermost projection of the work surface as

indicated in Table 1 (29 CFR 1926.502(c)(2)).• Verify that safety nets are installed with sufficient clearance under them to prevent contact with the surface or

structures below when subjected to an impact force equal to the drop test specified in 29 CFR1926.502(c)(4)(i) (see paragraph 2.9) (29 CFR 1926.502(c)(3)).

Table 1: Horizontal Extension of Safety Nets from Work Surface

Vertical distance from working level to Minimum required horizontal distance of outerhorizontal plane of net edge of net from the edge of the working surface

Up to 5 ft 8 ft5 ft – 10 ft 10 ft

More than 10 ft 13 ftSource: 29 CFR 1926.502(c)(2)

2.9 Safety nets and safety net installations must be drop-tested. (29 CFR 1926.502(c)(4))Guide Note• Verify that safety nets and their installations are capable of absorbing an impact force equal to that produced

by the drop test specified in 29 CFR 1926.502(c)(4)(i) (29 CFR 1926.502(c)(4)).• Verify that safety nets and safety net installations are drop-tested at the jobsite at the following times (29 CFR

1926.502(c)(4)(i)):– after initial installation and before being used as a fall protection system;– whenever they are relocated;– after major repair; and– at six-month intervals if left in one place.

• Review procedures to ensure that the drop-test consists of a 400 lb (180 kg) bag of sand 30 inches ± 2 inches(76 cm ± 5 cm) in diameter dropped into the net from at least 42 inches (1.1 m) above the highestwalking/working surface at which employees are exposed to hazards (29 CFR 1926.502(c)(4)(i)).

• When the employer can demonstrate that it is unreasonable to perform the drop-test, verify that the employercertifies that the net and net installation is in compliance with the provisions of 29 CFR 1926.502(c)(3) and(c)(4)(i) (see paragraph 2.8) by preparing a certification record prior to the net being used as a fall protectionsystem. The most recent certification record for each net and net installation must be available at the jobsitefor inspection and must include the following (29 CFR 1926.502(c)(4))(ii)):– an identification of the net and net installation for which the certification record is being prepared;– the date that it was determined that the identified net and net installation were in compliance; and– the signature of the person making the determination and certification.


3. Personal Fall Arrest Systems


2.10 Safety nets and safety net systems must be inspected for wear, damage, deterioration, anddefects. (29 CFR 1926.502(c)(5))Guide Note• Verify that safety nets are inspected at least once a week for wear, damage, and other deterioration (29 CFR

1926.502(c)(5)).• Verify that safety nets are inspected after any occurrence that could affect the integrity of the safety net system

(29 CFR 1926.502(c)(5)).• Verify that defective nets are not used and that defective components are removed from service (29 CFR

1926.502(c)(5)).

2.11 Objects that fall into safety nets must be removed as soon as possible. (29 CFR 1926.502(c)(6))Guide Note• Verify that materials, scrap pieces, equipment, and tools that have fallen into safety nets are removed as soon

as possible from the net and at least before the next work shift (29 CFR 1926.502(c)(6)).

2.12 Safety nets must be constructed according to certain requirements. (29 CFR 1926.502(c)(7) –(c)(9))Guide Note• Measure the maximum size of each safety net mesh opening to ensure it conforms to the following

requirements (29 CFR 1926.502(c)(7)):– Each opening must not exceed 36 sq inches (230 cm2) nor be longer than 6 inches (15 cm) on any side.– The opening, measured center-to-center of mesh ropes or webbing, must not be longer than 6 inches

(15 cm).– All mesh crossings must be secured to prevent enlargement of the mesh opening.

• Verify that each safety net (or section of it) has a border rope for webbing with a minimum breaking strengthof 5,000 lb (22.2 kN) (29 CFR 1926.502(c)(8)).

• Ensure that connections between safety net panels are as strong as integral net components and are not spacedmore than 6 inches (15 cm) apart (29 CFR 1926.502(c)(9)).

.

Effective January 1, 1998, body belts are not acceptable as part of a personal fall arrestsystem. The use of a body belt in a positioning device system is acceptable and is regulatedunder 29 CFR 1926.502(e) (see section 4 below) (29 CFR 1926.502(d)).

3.1 Connectors for personal fall arrest systems must meet certain requirements. (29 CFR1926.502(d)(1) – (d)(6))Guide Note• Inspect connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalent materials

(29 CFR 1926.502(d)(1)).• Inspect connectors to verify that they have a corrosion-resistant finish and that all surfaces and edges are

smooth to prevent damage to interfacing parts of the system (29 CFR 1926.502(d)(2)).• Verify that dee-rings and snaphooks have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR

1926.502(d)(3)).• Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without

cracking, breaking, or taking permanent deformation (29 CFR 1926.502(d)(4)).• Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR

1926.502(d)(5)):– Snaphooks are a compatible size for the member to which they are connected.– Only locking type snaphooks are used.



• Verify that unless snaphooks are a locking type and are designed for the following connections, the snaphooksare not engaged (29 CFR 1926.502(d)(6)):– directly to webbing, rope, or wire rope;– to each other;– to a dee-ring to which another snaphook or other connector is attached;– to a horizontal lifeline; or– to any object that is incompatibly shaped or dimensioned in relation to the snaphook such that

unintentional disengagement could occur by the connected object depressing the snaphook keeper andreleasing itself.

3.2 Lifelines for personal fall protection systems must meet certain requirements. (29 CFR1926.502(d)(7) – (d)(14))Guide Note• Verify that on suspended scaffolds or similar work platforms with horizontal lifelines that may become vertical

lifelines, the devices used to connect to a horizontal lifeline are capable of locking in both directions on thelifeline (29 CFR 1926.502(d)(7)).

• Verify that horizontal lifelines are designed, installed, and used under the supervision of a qualified person aspart of a complete personal fall arrest system that maintains a safety factor of at least 2 (29 CFR1926.502(d)(8)).

• Verify that lanyards and vertical lifelines have a minimum breaking strength of 5,000 lb (22.2 kN) (29 CFR1926.502(d)(9)).

• Verify that when vertical lifelines are used, each employee is attached to a separate lifeline (29 CFR1926.502(d)(10)(i)).EXCEPTION: During the construction of elevator shafts, 2 employees may be attached to the same lifeline inthe hoistway, provided that all of the following conditions are met (29 CFR 1926.502(d)(10)(ii)):– Both employees are working atop a false car that is equipped with guardrails.– The strength of the lifeline is 10,000 lb (44.4 kN) (5,000 lb per employee attached).– All other criteria specified in 29 CFR 1926.502(d) (see section 3) for lifelines have been met.

• Verify that lifelines are protected against being cut or abraded (29 CFR 1926.502(d)(11)).• Verify that self-retracting lifelines and lanyards that automatically limit free fall distance to 2 ft (0.61 m) or

less are capable of sustaining a minimum tensile load of 3,000 lb (13.3 kN) applied to the device with thelifeline or lanyard in the fully extended position (29 CFR 1926.502(d)(12)).

• Verify that self-retracting lifelines and lanyards that do not limit free fall distance to 2 ft (0.61 m) or less,ripstitch lanyards, and tearing and deforming lanyards are capable of sustaining a minimum tensile load of5,000 lb (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position (29 CFR1926.502(d)(13)).

• Verify that ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts andbody harnesses are made from synthetic fibers (29 CFR 1926.502(d)(14)).

3.3 Anchorages used for attachment of personal fall arrest systems must be designed, installed, andused according to certain requirements. (29 CFR 1926.502(d)(15))Guide Note• Verify that anchorages used for attachment of personal fall arrest equipment meet either of the following

conditions (29 CFR 1926.502(d)(15)):– The anchorages are independent of any anchorage being used to support or suspend platforms and are

capable of supporting at least 5,000 lb (22.2 kN) per employee attached.– The anchorages are designed, installed, and used under the supervision of a qualified person as part of a

complete personal fall arrest system that maintains a safety factor of at least 2.NOTE: OSHA allows scaffolding to function as a suitable anchorage for fall arrest systems when thescaffolding used is erected and braced such that the criteria of 29 CFR 1926.502(d)(15) are met. This applieswhether the scaffold is partially built (i.e., being erected or disassembled) or completely built (OSHA StandardInterpretation, 04/02/98).



3.4 When stopping a fall, personal fall arrest systems must meet certain requirements. (29 CFR1926.502(d)(16))Guide Note• Verify that when stopping a fall, personal fall arrest systems (29 CFR 1926.502(d)(16)):

– limit maximum arresting force on an employee to 900 lb (4 kN) when used with a body belt;– limit maximum arresting force on an employee to 1,800 lb (8 kN) when used with a body harness;– be rigged such that an employee can neither free fall more than 6 ft (1.8 m) nor contact any lower level;– bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5

ft (1.07 m); and– have sufficient strength to withstand twice the potential impact energy of an employee free falling a

distance of 6 ft (1.8 m) or the free fall distance permitted by the system, whichever is less.NOTE 1: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to thissubpart, and if the system is being used by an employee with a combined person and tool weight of less than310 lb (140 kg), the system will be considered to be in compliance with the provisions of 29 CFR1926.502(d)(16) (see guide notes above). If the system is used by an employee with a combined tool and bodyweight of 310 lb (140 kg) or more, then the employer must appropriately modify the criteria and protocols ofthe appendix to provide proper protection for such heavier weights, or the system will not be deemed to be incompliance.NOTE 2: Shock-absorbing lanyards are not mandatory but may be used to comply with this provision (OSHAStandard Interpretation, 06/03/98).NOTE 3: A body harness used as a component of a personal fall arrest system does not require nor does itexclude the use of a waist or chest strap as part of a full body harness, as long as the harness properlydistributes the fall arrest forces (OSHA Standard Interpretation, 09/23/99).

3.5 Body belts and harnesses on personal fall arrest systems must meet certain requirements.(29 CFR 1926.502(d)(17) – (d)(18) and (d)(22))Guide Note• Verify that the attachment point of a body belt is located in the center of the wearer’s back (29 CFR

1926.502(d)(17)).• Verify that the attachment point of a body harness is located in the center of the wearer’s back near shoulder

level or above the wearer’s head (29 CFR 1926.502(d)(17)).• Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal

fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(d)(18)).NOTE: If any component of the rigging system, such as a shackle, wire rope, or synthetic sling was or is usedto hoist materials, these components are not be used as part of a fall protection system (OSHA StandardInterpretation, 11/03/00, Question 4).

• Inspect all body belts to ensure they are at least 1 5/8 inches (4.1 cm) wide (29 CFR 1926.502(d)(22)).

3.6 Personal fall arrest systems and components must be inspected under certain conditions.(29 CFR 1926.502(d)(19) and (d)(21))Guide Note• Verify that personal fall arrest systems and components subjected to impact loading are immediately removed

from service and are not used again for employee protection until inspected and determined by a competentperson to be undamaged and suitable for reuse (29 CFR 1926.502(d)(19)).

• Review procedures to ensure that personal fall arrest systems are inspected prior to each use for wear, damage,and other deterioration and that defective components are removed from service (29 CFR 1926.502(d)(21)).

3.7 Personal fall arrest systems must not be attached to guardrail systems or hoists, except asspecified in this subpart. (29 CFR 1926.502(d)(23))Guide Note• Verify that personal fall arrest systems are not attached to guardrail systems (29 CFR 1926.502(d)(23)).• Verify that fall arrest systems are not attached to hoists, except as specified in other subparts of 29 CFR 1926

(29 CFR 1926.502(d)(23)).


4. Positioning Device Systems


3.8 A personal fall arrest system used at hoist areas must be rigged according to certainrequirements. (29 CFR 1926.502(d)(24))Guide Note• When a personal fall arrest system is used at hoist areas, verify that it is rigged to allow the movement of the

employee only as far as the edge of the walking/working surface (29 CFR 1926.502(d)(24)).

3.9 In the event of a fall by an employee, prompt rescue must be executed. (29 CFR1926.502(d)(20))Guide Note• In the event of a fall, verify that the employer provides for the prompt rescue of employees or that employees

are able to rescue themselves (29 CFR 1926.502(d)(20)).

.

4.1 Positioning device systems and their use must comply with certain requirements. (29 CFR1926.502(e)(1) – (e)(5))Guide Note• Verify that positioning devices are rigged such that an employee cannot free fall more than 2 ft (0.9 m)

(29 CFR 1926.502(e)(1)).• Inspect the positioning devices to ensure they are secured to an anchorage capable of supporting at least twice

the potential impact load of an employee’s fall or 3,000 lb (13.3 kN), whichever is greater (29 CFR1926.502(e)(2)).

• Inspect the connectors to ensure they are drop forged, pressed, or formed steel or are made of equivalentmaterials (29 CFR 1926.502(e)(3)).

• Inspect the connectors to ensure they have a corrosion-resistant finish and that all surfaces and edges aresmooth to prevent damage to interfacing parts of this system (29 CFR 1926.502(e)(4)).

• Verify that connecting assemblies have a minimum tensile strength of 5,000 lb (22.2 kN) (29 CFR1926.502(e)(5)).

4.2 Dee-rings and snaphooks must be properly tested and used. (29 CFR 1926.502(e)(6) – (e)(8))Guide Note• Verify that dee-rings and snaphooks are proof-tested to a minimum tensile load of 3,600 lb (16 kN) without

cracking, breaking, or taking permanent deformation (29 CFR 1926.502(e)(6)).• Verify that unintentional disengagement of snaphooks is prevented by either of the following means (29 CFR

1926.502(e)(7)):– Snaphooks are a compatible size for the member to which they are connected.– Locking type snaphooks are used.

NOTE: Effective January 1, 1998, only locking type snaphooks may be used.• Verify that unless the snaphook is a locking type and is designed for the following connections, snaphooks are

not engaged (29 CFR 1926.502(e)(8)):– directly to webbing, rope, or wire rope;– to each other;– to a dee-ring to which another snaphook or other connector is attached;– to a horizontal lifeline; or– to any object that is incompatibly shaped or dimensional in relation to the snaphook such that

unintentional disengagement could occur by the connected object depressing the snaphook keeper andreleasing itself.


5. Warning Line Systems


4.3 Positioning device systems and components must be inspected under certain conditions.(29 CFR 1926.502(e)(9))Guide Note• Verify that positioning device systems are inspected prior to each use for wear, damage, and other

deterioration and that defective components are removed from service (29 CFR 1926.502(e)(9)).

4.4 Body belts, harnesses, and components must not be used to hoist materials. (29 CFR1926.502(e)(10))Guide Note• Verify that body belts, harnesses, and components are used only for employee protection (as part of a personal

fall arrest system or positioning device system) and not to hoist materials (29 CFR 1926.502(e)(10)).NOTE: Personal fall arrest systems must have the lanyard attached to a dee-ring at the back to minimize injuryto the wearer. Belts used for fall arrest with side dee-rings are not in compliance and are dangerous to thewearer. Belts worn with the dee-rings(s) at the side(s) are suitable only as positioning devices. (OSHAStandard Interpretation, 09/25/95).

.

5.1 Warning lines around all sides of a roof work area must meet certain requirements. (29 CFR1926.502(f)(1))Guide Note• Verify that a warning line is erected around all sides of the roof work area according to the following

requirements (29 CFR 1926.502(f)(1)):– When mechanical equipment is not being used, the warning line must be erected no less than 6 ft (1.8 m)

from the roof edge.– When mechanical equipment is being used, the warning line must be erected no less than 6 ft (1.8 m)

from the roof edge that is parallel to the direction of mechanical equipment operation, and not less than10 ft (3.1 m) from the roof edge that is perpendicular to the direction of mechanical equipment operation.NOTE: OSHA further defines and clarifies the use of mechanical equipment in its Standard Interpretation,10/17/00.

– Points of access, materials handling areas, storage areas, and hoisting areas must be connected to the workarea by an access path formed by two warning lines.

– When the path to a point of access is not in use, either of the following must occur so that a person cannotwalk directly into the work area:1) a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line, must be

placed across the path at the point where the path intersects the warning line; or2) the path must be offset such that a person cannot walk directly into the work area.

5.2 Warning lines must consist of ropes, wires, or chains, and supporting stanchions, and must beerected according to certain requirements. (29 CFR 1926.502(f)(2))Guide Note• Verify that warning lines consist of ropes, wires, or chains and supporting stanchions and are erected as

follows (29 CFR 1926.502(f)(2)):– The rope, wire, or chain must be flagged at not more than 6-ft (1.8 m) intervals with high-visibility

material.– The rope, wire, or chain must be rigged and supported in such a way that its lowest point (including sag)

is no less than 34 inches (0.9 m) from the walking/working surface and its highest point is no more than39 inches (1.0 m) from the walking/working surface.

– After being erected and with the rope, wire, or chain attached, stanchions must be capable of resisting,without tipping over, a force of at least 16 lb (71 N) that is applied horizontally against the stanchion andperpendicular to the warning line, 30 inches (0.8 m) above the walking/working surface in the direction ofthe floor, roof, or platform edge.


6. Controlled Access Zones


– The rope, wire, or chain must have a minimum tensile strength of 500 lb (2.22 kN) and, after beingattached to the stanchions, must be capable of supporting, without breaking, the loads applied to thestanchions as prescribed in 29 CFR 1926.502(f)(2)(iii) (see third dashed point above).

– The line must be attached at each stanchion in such a way that pulling on one section of the line betweenstanchions will not result in slack being taken up in adjacent sections before the stanchion tips over.

5.3 Only authorized employees are allowed in the area between a roof edge and a warning line.(29 CFR 1926.502(f)(3))Guide Note• Review procedures to ensure that no employee is allowed in the area between a roof edge and a warning line

unless the employee is performing roofing work in that area (29 CFR 1926.502(f)(3)).

5.4 Employees must be protected from mechanical equipment on roofs. (29 CFR 1926.502(f)(4))Guide Note• Verify that mechanical equipment on roofs is used or stored only in areas where employees are protected by a

warning line system, guardrail system, or personal fall arrest system (29 CFR 1926.502(f)(4)).

.

6.1 CAZs must de defined where leading edge and other operations are taking place. (29 CFR1926.502(g)(1))Guide Note• Verify that when a CAZ is used to control access to areas where leading edge and other operations are taking

place, the CAZ is defined by a control line or by any other means that restricts access (29 CFR1926.502(g)(1)).

• If control lines are used to control access to areas where leading edge and other operations are taking place,verify that they are erected according to the following requirements (29 CFR 1926.502(g)(1)):– Control lines must be erected not less than 6 ft (1.8 m) nor more than 25 ft (7.7 m) from the unprotected

or leading edge, except when erecting precast concrete members.– When erecting precast concrete members, the control line must be erected either not less than 6 ft (1.8 m)

nor more than 60 ft (18 m) from the leading edge or half the length of the member being erected from theleading edge, whichever is less.

– The control line must extend along the entire length of the unprotected or leading edge and must beapproximately parallel to the unprotected or leading edge.

– The control line must be connected on each side to a guardrail system or wall.

6.2 CAZs used to control access to areas where overhand bricklaying and related work are takingplace must meet certain requirements. (29 CFR 1926.502(g)(2))Guide Note• When CAZs are used to control access to areas where overhand bricklaying and related work are taking place,

verify that the following requirements are met (29 CFR 1926.502(g)(2)):– The CAZ is defined by a control line erected not less than 10 ft (3.1 m) nor more than 15 ft (4.5 m) from

the working edge.– The control line extends for a distance sufficient for the CAZ to enclose all employees performing

overhand bricklaying and related work at the working edge and must be approximately parallel to theworking edge.

– Additional control lines are erected at each end to enclose the CAZ.– Only employees engaged in overhand bricklaying or related work are permitted in the CAZ.


7. Safety Monitoring Systems


6.3 Control lines must consist of ropes, wires, tapes, or equivalent materials, and supportingstanchions, and must meet certain requirements. (29 CFR 1926.502(g)(3))Guide Note• Verify that control lines consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions as

follows (29 CFR 1926.502(g)(3)):– Each line must be flagged or otherwise clearly marked at not more than 6 ft (1.8 m) intervals with high-

visibility material.– Each line must be rigged and supported in such a way that its lowest point (including sag) is not less than

39 inches (1 m) from the walking/working surface and its highest point is not more than 45 inches (1.3 m)from the walking/working surface.NOTE: When overhand bricklaying operations are being performed, the line’s highest point must not bemore than 50 inches (1.3 m) from the walking/working surface.

– Each line must have a minimum breaking strength of 200 lb (0.88 kN).

6.4 Floors and roofs in CAZs must be properly constructed for bricklaying operations. (29 CFR1926.502(g)(4) – (g)(5))Guide Note• Verify that on floors and roofs where guardrail systems are not in place prior to the beginning of overhand

bricklaying operations, CAZs are enlarged as necessary to enclose all points of access, material handling areas,and storage areas (29 CFR 1926.502(g)(4)).

• Verify that on floors and roofs where guardrail systems are in place but need to be removed to allow overhandbricklaying work or leading edge work to take place, only that portion of the guardrail necessary to accomplishthat day’s work is removed (29 CFR 1926.502(g)(5)).

.

7.1 Safety monitoring systems must meet certain requirements. (29 CFR 1926.502(h))Guide Note• Interview employees to verify that the employer designates a competent person to monitor the safety of other

employees and that the employer ensures that the safety monitor complies with all of the followingrequirements (29 CFR 1926.502(h)(1)):– The safety monitor must be competent to recognize fall hazards.– The safety monitor must warn the employee when it appears that the employee is unaware of a fall hazard

or is acting in an unsafe manner.– The safety monitor must be on the same walking/working surface and within visual sighting distance of

the employee being monitored.– The safety monitor must be close enough to communicate orally with the employee.– The safety monitor must not have other responsibilities that could take the monitor’s attention from the

monitoring function.• Verify that mechanical equipment is not used or stored in areas where safety monitoring systems are being

used to monitor employees engaged in roofing operations on low-slope roofs (29 CFR 1926.502(h)(2)).• Review employee work practices to verify that no employee, other than an employee engaged in roofing work

on low-sloped roofs or an employee covered by a fall protection plan, is allowed in an area where an employeeis being protected by a safety monitoring system (29 CFR 1926.502(h)(3)).

• Verify that each employee working in a CAZ is directed to comply promptly with fall hazard warnings fromsafety monitors (29 CFR 1926.502(h)(4)).


8. Covers

9. Protection from Falling Objects


.

8.1 Covers for holes must meet certain requirements. (29 CFR 1926.502(i))Guide Note• Verify that covers located in roadways and vehicular aisles are capable of supporting, without failure, at least

twice the maximum axle load of the largest vehicle expected to cross over the cover (29 CFR 1926.502(i)(1)).• Verify that all other covers are capable of supporting, without failure, at least twice the weight of employees,

equipment, and materials that may be imposed on the cover at any one time (29 CFR 1926.502(i)(2)).• Verify that all covers are secured when installed to prevent accidental displacement by the wind, equipment, or

employees (29 CFR 1926.502(i)(3)).• Verify that all covers are color coded, or that they are marked with the word “Hole” or “Cover” to provide

warning of the hazard (29 CFR 1926.502(i)(4)).NOTE: This provision does not apply to cast iron manhole covers or steel grates used on streets or roadways.

.

NOTE: Additional provisions for protection from falling objects are found in 29 CFR1926.501(c) (see paragraph 1.17 above)

9.1 Toeboards, when used as falling object protection, must meet certain requirements. (29 CFR1926.502(j)(1) – (j)(4))Guide Note• Verify that toeboards, when used as falling object protection, are erected along the edge of the overhead

walking/working surface for a distance sufficient to protect employees below (29 CFR 1926.502(j)(1)).• Verify that toeboards are capable of withstanding, without failure, a force of at least 50 lb (222 N) applied in

any downward or outward direction at any point along the toeboard (29 CFR 1926.502(j)(2)).• Inspect the toeboards to ensure they meet the following requirements (29 CFR 1926.502(j)(3)):

– They are a minimum of 3½ inches (9 cm) in vertical height from their top edge to the edge of thewalking/working surface.

– They are no more than ¼ inch (0.6 cm) clearance above the walking/working surface.– They are solid or have openings no greater than 1 inch (2.5 cm) in any dimension.

• Where tools, equipment, or materials are piled higher than the top edge of a toeboard, verify that paneling orscreening is erected from the walking/working surface or toeboard to the top of a guardrail system’s top rail ormidrail, for a distance sufficient to protect employees below (29 CFR 1926.502(j)(4)).

9.2 Guard rail systems, when used as falling object protection, must meet certain requirements.(29 CFR 1926.502(j)(5))Guide Note• Verify that guardrail systems, when used as falling object protection, have all openings small enough to

prevent passage of potential falling objects (29 CFR 1926.502(j)(5)).

9.3 Certain requirements must be met during the performance of bricklaying and related work.(29 CFR 1926.502(j)(6))Guide Note• Verify that no equipment except masonry and mortar are stored within 4 ft (1.2 m) of the working edge

(29 CFR 1926.502(j)(6)(i)).• Verify that excess mortar, broken or scattered masonry units, and all other materials and debris are removed

from the work area at regular intervals (29 CFR 1926.502(j)(6)(ii)).


10. Fall Protection Plans


9.4 Certain requirements must be met during the performance of roofing work. (29 CFR1926.502(j)(7))Guide Note• Verify that equipment and materials are not stored within 6 ft (1.8 m) of a roof edge unless guardrails are

erected at the edge (29 CFR 1926.502(j)(7)(i)).• Verify that piled, grouped, or stacked materials near a roof are stable and self-supporting (29 CFR

1926.502(j)(7)(ii)).

9.5 Canopies used as falling object protection must meet certain requirements. (29 CFR1926.502(j)(8))Guide Note• Verify that canopies, when used as falling object protection, are strong enough to prevent collapse and to

prevent penetration by any objects that may fall onto the canopy (29 CFR 1926.502(j)(8)).

.

10.1 Fall protection plans must meet certain requirements. (29 CFR 1926.502(k))Guide Note

NOTE: The option for using a fall protection plan is available only to employees engaged in leading edgework, precast concrete erection work, or residential construction work who can demonstrate that it is infeasibleor it creates a greater hazard to use conventional fall protection equipment (29 CFR 1926.502(k)).

• Verify that the fall protection plan is prepared by a qualified person and developed specifically for the sitewhere the work is being performed and that the plan is maintained up-to-date. Any changes to the fallprotection plan must be approved by a qualified person (29 CFR 1926.502(k)(1) – (k)(2)).

• Verify that a copy of the fall protection plan with all approved changes is maintained at the job site (29 CFR1926.502(k)(3)).

• Verify that the implementation of the fall protection plan is under the supervision of a competent person(29 CFR 1926.502(k)(4)).

• Verify that the fall protection plan documents the reasons why the use of conventional fall protection systems(guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use wouldcreate a greater hazard (29 CFR 1926.502(k)(5)).

• Review the fall protection plan to ensure it includes a written discussion of other measures that will be takento reduce or eliminate the fall hazard for workers who cannot be provided with protection from theconventional fall protection systems (29 CFR 1926.502(k)(6)).

• Review the fall protection plan to ensure it identifies each location where conventional fall protection methodscannot be used. These locations must then be classified as CAZs and the employer must comply with thecriteria in 29 CFR 1926.502(g) (see section 6 above) (29 CFR 1926.502(k)(7)).

• Verify that where no other alternative measure has been implemented, the employer implements a safetymonitoring system in conformance with 29 CFR 1926.502(h) (see paragraph 7.1 above) (29 CFR1926.502(k)(8)).

• Verify that the fall protection plan includes a statement that provides the name or other method ofidentification for each employee who is designated to work in CAZs. No other employees may enter CAZs(29 CFR 1926.502(k)(9)).

• If an employee falls or some other related, serious incident occurs (e.g., a near miss), verify that the employerinvestigates the circumstances of the incident to determine if the fall protection plan needs to be changed (e.g.,by new practices, procedures, or training) and implements those changes to prevent similar types of falls orincidents (29 CFR 1926.502(k)(10)).


11. Training Requirements


.

11.1 Employers must provide a fall prevention training program for each employee who might beexposed to fall hazards. (29 CFR 1926.503(a))Guide Note• Interview employees to verify that the employer provides a training program for each employee who might be

exposed to fall hazards. The training program must include recognition of the hazards of falling andprocedures to follow to minimize these hazards (29 CFR 1926.503(a)(1)).

• Verify that each employee has been trained as necessary by a competent person qualified in the followingareas (29 CFR 1926.503(a)(2)):– the nature of fall hazards in the work area;– the correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems

to be used;– the use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line

systems, safety monitoring systems, CAZs, and other protection to be used;– the role of each employee in the safety monitoring system when this system is used;– the limitations on the use of mechanical equipment during the performance of roofing work on low-sloped

roofs;– the correct procedures for the handling and storage of equipment and materials and the erection of

overhead protection;– the role of employees in fall protection plans;– the requirements contained in 29 CFR 1926 Subpart M.

11.2 Employers must maintain written certification records for employee training. (29 CFR1926.503(b))Guide Note• Verify the employer maintains a written certification record for employee training that meets the requirements

of 29 CFR 1926.503(a) (see paragraph 11.1 above). The record must contain the following information(29 CFR 1926.503(b)(1)):– the name or other identity of the employee trained– the date(s) of the training; and– the signature of the person who conducted the training or the signature of the employer.

NOTE: If the employer relies on training conducted by another employer or completed prior toAugust 9, 1994, the certification record must indicate the date the employer determined the prior training wasadequate rather than the date of actual training.

• Verify that the latest training certification is maintained (29 CFR 1926.503(b)(2)).

11.3 Employers must provide retraining when necessary. (29 CFR 1926.503(c))Guide Note• Verify that when the employer has reason to believe that any affected employee who has already been trained

does not have the understanding and skill required by 29 CFR 1926.503(a) (see paragraph 11.1 above), theemployer retrains that employee. Retraining is required at least in the following circumstances (29 CFR1926.503(c)(1) – (c)(3)):– changes in the workplace render previous training obsolete;– changes in the types of fall protection systems or equipment to be used render previous training .

obsolete; or– inadequacies in an affected employee’s knowledge or use of fall protection systems or equipment indicate

that the employee has not retained the requisite understanding or skill.


FALL PROTECTION.

Duty to Have Fall Protection

Fall Protection Systems Criteria and Practices

.

.PART 4: SCORESHEET

SITE: DATE:Does not1.

. N/A Complies

.

.

.

. comply

1.1 Walking/working surfaces must have the strength and structural integrity to support q q qemployees safely. (29 CFR 1926.501(a)(2))

1.2 Employees on a walking/working surface must be protected from falling under q q qcertain circumstances. (29 CFR 1926.501(b)(1))

1.3 Employees who are constructing leading edges or working nearby must be protected q q qfrom falling. (29 CFR 1926.501(b)(2))

1.4 Employees in a hoist area must be protected from falling. (29 CFR 1926.501(b)(3)) q q q

1.5 Employees on walking/working surfaces with holes must be protected from falling. q q q(29 CFR 1926.501(b)(4))

1.6 Employees on the face of formwork or reinforcing steel must be protected from q q qfalling. (29 CFR 1926.501(b)(5))

1.7 Employees on ramps, runways, and other walkways must be protected from falling. q q q(29 CFR 1926.501(b)(6))

1.8 Employees at the edge of excavations must be protected from falling. (29 CFR q q q1926.501(b)(7))

1.9 Employees above dangerous equipment must be protected from falling. (29 CFR q q q1926.501(b)(8))

1.10 Employees performing overhand bricklaying and related work must be protected q q qfrom falling. (29 CFR 1926.501(b)(9))

1.11 Employees engaged in roofing activities on low-slope roofs must be protected from q q qfalling. (29 CFR 1926.501(b)(10))

1.12 Employees on a steep roof must be protected from falling. (29 CFR 1926.501(b)(11)) q q q

1.13 Employees engaged in the erection of precast concrete members must be protected q q qfrom falling. (29 CFR 1926.501(b)(12))

1.14 Employees engaged in residential construction must be protected from falling. q q q(29 CFR 1926.501(b)(13))

1.15 Employees working on, at, above, or near wall openings must be protected from q q qfalling. (29 CFR 1926.501(b)(14))

1.16 Employees must be protected from falling on walking/working surfaces not q q qotherwise addressed in this section. (29 CFR 1926.501(b)(15))

1.17 Employers must provide protection from falling objects. (29 CFR 1926.501(c)) q q q


2.1 Top edge height of top rails, or equivalent guardrail system members, must meet q q qcertain requirements. (29 CFR 1926.502(b)(1))


Personal Fall Arrest Systems

Positioning Device Systems

Fall Protection Scoresheet

2.2 Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate q q qstructural members must be installed according to certain requirements. (29 CFR1926.502(b)(2))

2.3 Guardrail systems must be able to withstand a specified amount of force and q q qpressure. (29 CFR 1926.502(b)(3) – (b)(4))

2.4 Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent q q qstructural members must be able to withstand a specified amount of force. (29 CFR1926.502(b)(5))

2.5 Guardrail systems must be properly constructed to prevent injury. (29 CFR q q q1926.502(b)(6) – (b)(10) and (b)(14))

2.6 Guardrail systems around holes must meet certain requirements. (29 CFR q q q1926.502(b)(11) – (b)(13))

2.7 Manila, plastic, or synthetic rope must meet certain strength requirements. (29 CFR q q q1926.502(b)(15))

2.8 Safety net systems must be installed and used according to certain requirements. q q q(29 CFR 1926.502(c)(1) – (c)(3))

2.9 Safety nets and safety net installations must be drop-tested. (29 CFR 1926.502(c)(4)) q q q

2.10 Safety nets and safety net systems must be inspected for wear, damage, deterioration, q q qand defects. (29 CFR 1926.502(c)(5))

2.11 Objects that fall into safety nets must be removed as soon as possible. (29 CFR q q q1926.502(c)(6))

2.12 Safety nets must be constructed according to certain requirements. (29 CFR q q q1926.502(c)(7) – (c)(9))


3.1 Connectors for personal fall arrest systems must meet certain requirements. (29 CFR q q q1926.502(d)(1) – (d)(6))

3.2 Lifelines for personal fall protection systems must meet certain requirements. q q q(29 CFR 1926.502(d)(7) – (d)(14))

3.3 Anchorages used for attachment of personal fall arrest systems must be designed, q q qinstalled, and used according to certain requirements. (29 CFR 1926.502(d)(15))

3.4 When stopping a fall, personal fall arrest systems must meet certain requirements. q q q(29 CFR 1926.502(d)(16))

3.5 Body belts and harnesses on personal fall arrest systems must meet certain q q qrequirements. (29 CFR 1926.502(d)(17) – (d)(18) and (d)(22))

3.6 Personal fall arrest systems and components must be inspected under certain q q qconditions. (29 CFR 1926.502(d)(19) and (d)(21))

3.7 Personal fall arrest systems must not be attached to guardrail systems or hoists, q q qexcept as specified in this subpart. (29 CFR 1926.502(d)(23))

3.8 A personal fall arrest system used at hoist areas must be rigged according to certain q q qrequirements. (29 CFR 1926.502(d)(24))

3.9 In the event of a fall by an employee, prompt rescue must be executed. (29 CFR q q q1926.502(d)(20))



Warning Line Systems

Controlled Access Zones


4.1 Positioning device systems and their use must comply with certain requirements. q q q(29 CFR 1926.502(e)(1) – (e)(5))

4.2 Dee-rings and snaphooks must be properly tested and used. (29 CFR q q q1926.502(e)(6) – (e)(8))

4.3 Positioning device systems and components must be inspected under certain q q qconditions. (29 CFR 1926.502(e)(9))

4.4 Body belts, harnesses, and components must not be used to hoist materials. (29 CFR q q q1926.502(e)(10))


5.1 Warning lines around all sides of a roof work area must meet certain requirements. q q q(29 CFR 1926.502(f)(1))

5.2 Warning lines must consist of ropes, wires, or chains, and supporting stanchions, and q q qmust be erected according to certain requirements. (29 CFR 1926.502(f)(2))

5.3 Only authorized employees are allowed in the area between a roof edge and a q q qwarning line. (29 CFR 1926.502(f)(3))

5.4 Employees must be protected from mechanical equipment on roofs. (29 CFR q q q1926.502(f)(4))


6.1 CAZs must de defined where leading edge and other operations are taking place. q q q(29 CFR 1926.502(g)(1))

6.2 CAZs used to control access to areas where overhand bricklaying and related work q q qare taking place must meet certain requirements. (29 CFR 1926.502(g)(2))

6.3 Control lines must consist of ropes, wires, tapes, or equivalent materials, and q q qsupporting stanchions, and must meet certain requirements. (29 CFR 1926.502(g)(3))

6.4 Floors and roofs in CAZs must be properly constructed for bricklaying operations. q q q(29 CFR 1926.502(g)(4) – (g)(5))


Safety Monitoring Systems

Covers

Protection from Falling Objects

Fall Protection Plans

Training Requirements



7.1 Safety monitoring systems must meet certain requirements. (29 CFR 1926.502(h)) q q q


8.1 Covers for holes must meet certain requirements. (29 CFR 1926.502(i)) q q q


9.1 Toeboards, when used as falling object protection, must meet certain requirements. q q q(29 CFR 1926.502(j)(1) – (j)(4))

9.2 Guard rail systems, when used as falling object protection, must meet certain q q qrequirements. (29 CFR 1926.502(j)(5))

9.3 Certain requirements must be met during the performance of bricklaying and related q q qwork. (29 CFR 1926.502(j)(6))

9.4 Certain requirements must be met during the performance of roofing work. (29 CFR q q q1926.502(j)(7))

9.5 Canopies used as falling object protection must meet certain requirements. (29 CFR q q q1926.502(j)(8))


10.1 Fall protection plans must meet certain requirements. (29 CFR 1926.502(k)) q q q


11.1 Employers must provide a fall prevention training program for each employee who q q qmight be exposed to fall hazards. (29 CFR 1926.503(a))

11.2 Employers must maintain written certification records for employee training. q q q(29 CFR 1926.503(b))

11.3 Employers must provide retraining when necessary. (29 CFR 1926.503(c)) q q q

END OF SCORESHEET


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OSHA Auditing: Federal Compliance: Construction: The Complete Health and Safety Audit Checklist

Business

fully extended

precast concrete

ptabledirectivesamp

minimum tensile

osha interpretation

intermediate

conventional

safety monitoring