OSHA Residential Fall Protection

[johntrent]

Anyone else seen this? I recieved this from one of my builders today.

Please read the following and go the following links if you need more information for your company.

As some of you may be aware, OSHA has rescinded the interim fall protection standard STD 3.01A for residential construction that was in place for the last 16 years. Effective June 16, 2011 OSHA will begin enforcing the Residential Construction Fall Protection Standard 29 CFR 1926.501(b)(13). This standard is not new, but was supplemented with the STD 3.01A Compliance Guideline that allowed alternative methods of fall protection for residential construction. The new directive rescinds STD 3.01A and will require the more stringent Standard 29 CFR 1926 to be enforced. This standard calls for residential construction employers to ensure that employees working six feet or more above lower levels use guardrails, safety nets, or personal fall arrest systems. This will affect a significant number of trades working on our homes.

To reinforce this issue with our trades, we will attach an automatic note to appear on ALL POs printed from the system stating; "SUBCONTRACTORS MUST COMPLY WITH ALL OSHA SAFETY REGULATIONS, INCLUDING FALL PROTECTION SAFETY STANDARD 29 CFR 1926.50(b)(13)."

This note will appear at the bottom of POs starting immediately. Be advised that our Subcontractor Agreement calls for compliance with ALL OSHA safety standards and requires the subcontractor to indemnify the Builder against ALL OSHA claims resulting from the subcontractor's job activities.

For more information regarding this issue go to the following links:

http://www.osha.gov/doc/fall_protection_factsheet.html

http://www.osha.gov/doc/residential-...uction-qa.html

[chuck stevenson]

Does that address interior work as well?

[johntrent]

Chuck - I can't see anything that differentiates interior or exterior. I haven't read it word for word but don't think it matters whether it is inside or outside just whether it is above 6 ft or not.

[dhagin]

We're under our own state program here, WISHA. I believe we're still at 10', but will probably be lowering to 6' any day now... maybe i missed the memo.

Interior or exterior makes no difference. Height of potential fall is what matters.

[chuck stevenson]

John,

We have a lot of 10 - 12 foot ceilings and I typically work off horses and planks.

I will read your links tomorrow. Just a glance this evening,

[johntrent]

Chuck - the way I understand it & hope someone corrects me if I am wrong -- this still wouldn't apply to you unless your feet are more than 6' off the ground.

Am I reading that correct Dana?

[Chad Deiter Company]

Are we saying 6' from ground to feet. It's gotta be right ? I mean I can reach 6' with nothing at all.

[ceramictec]

I think this only pertains to a home being built. (ie: framed, no drywall,) or working on a roof.

once the house is dry-walled "walls & ceiling" you cant work 6' up above the first floor or you will be on the second. but anything outside on scaffolding or in a lift this would pertain to.



The Agency's interpretation of "residential construction" for purposes of 1926.501(b)(13) combines two elements – both of which must be satisfied for a project to fall under that provision:

The end-use of the structure being built must be as a home, i.e., a dwelling; and
The structure being built must be constructed using traditional wood frame construction materials and methods.

The limited use of structural steel in a predominantly wood-framed home, such as a steel I-beam to help support wood framing, does not disqualify a structure from being considered residential construction.

Traditional wood frame construction materials and methods will be characterized by:

Framing materials: Wood (or equivalent cold-formed sheet metal stud) framing, not steel or concrete; wooden floor joists and roof structures.
Exterior wall structure: Wood (or equivalent cold-formed sheet metal stud) framing or masonry brick or block.
Methods: Traditional wood frame construction techniques.

[Chad Deiter Company]

Your probably right Brian none of that whole thing makes any sense to me.

[dhagin]

Yes, support surface (or feet) above 6'. Interior or exterior. For interior, think 2 story foyers, or vaulted ceilings, or ... that big tall interior fireplace that the customer wants tiled.

[dhagin]

Originally Posted by Chuck

We have a lot of 10 - 12 foot ceilings and I typically work off horses and planks.

I'm 6' and build scaffolding about 7' or so lower than the ceiling I work on, so you should be OK there.

[chuck stevenson]

Thanks Dana.

We have some Baker we use on the taller interior jobs.

[Boilermaker 98]

Be careful and watch stairwells, stairways, lofts, anywhere the adjacent area is lower than above by 6'. These must be either protected by harness and lanyard, directional barriers 6' or more away from exposed edge or handrail/guardrail at 42" with bottom and midrails that can support a 200# lateral load.


Even if you are not the GC on the project and you are working on the job and you or your employees are exposed to the hazard, you will be cited. It is YOUR responsibility to protect you and your employees.

So if the GC just built a open stairwell to the basement and there are no rails, either build the rails yourself of leave the site. OSHA doesn't care if it was your scope of work or not.

[dhagin]

Good post Brian.

The 6' height might be new, but the "Fall protection & fall restraint" rules have been in place for a long time. Everyone here should know about them.

Your state may have it's own rules, and not be subject to OSHA. Might check into that too.

[custombuilt]

Actually the six foot has been in place for a very long time.... I guess possibly not enforced however.

I know because it was on a state roofing test I took last month. However that is to the bottom edge of the working platform. So if you are working on scaffold above that height you would need to have guardrails around it at 42 inches.

There are very few situations except possibly a very tall fireplace that this would matter on interiors jobs. I mean I can reach a pretty high shower ceiling off a five foot ladder.


Might affect those who are vertically challenged a bit more, LOL