Safety Gates. The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). Develop and implement a site-specific fall protection plan. How many points of contact does this worker have with the ladder? We are concerned about the fall protection required for workers engaged in residential "roofing work," as that term is described in the Directive, on a roof with a slope greater than 4 feet vertical to 12 feet horizontal. Let’s back up a moment. PO Box 20246 Question (2): Assuming the same scenario set forth in the first paragraph of Question (1), can controlled access zones be used for residential roofing activities when the roof slope is greater than 4 feet vertical to 12 feet horizontal? When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … As we explained in a letter to Mr. Barry Cole last year, we have determined that in the areas further back from the distances specified for the warning lines permitted under the standard, there is a point that is sufficiently far from the edge to warrant the application of a de minimis policy regarding non-conforming guardrails. In early 2016, the Los Angeles-based EC was installing solar panels on the roof of a Marine Corps air station hangar, using warning lines and a safety monitor to comply with what they thought were OSHA's fall protection requirements. (C) The line shall be attached at each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in adjacent sections before the stanchion tips over. * * * In that case, the fall protection requirements in §1926.760 would apply. Because warning line will never "catch" someone from falling off a roof, guardrail will need to be used in specific areas. View Info. In such a setting, can a roofing contractor use controlled access zones or warning lines when engaged in roofing activity on a roof with a slope greater than 4 feet vertical to 12 feet horizontal? Answer Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system. Also, at that distance, the failure of a barrier to restrain a worker from unintentionally crossing it would not place the worker in immediate risk of falling off the edge. Whenever using any type of accident prevention sign or tag, it is essential to understand all the requirements. This activity may be performed in a controlled decking zone as noted in Section 1926.760 Fall Protection: in Appendix D to this subpart. [ back to text ], 3 See Question (3) below for a discussion of the conventional fall protection provided for in the Standard for "Steep roofs." Mark Troxell, Director of Safety You ask about the use of warning lines or controlled access zones as fall protection for employees engaged in certain roofing activities. More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. The warning line should be rope, wire, or chain. 3. Furthermore, when these other trades use a warning line system in accordance with the policy described above, the workers must use conventional fall protection when they are outside the protection of the warning line system. However, where the employer can demonstrate that conventional fall protection is infeasible and that a warning line is the most protective alternative means of fall protection, it may be used as part of a residential construction Fall Protection Plan. This letter constitutes OSHA's interpretation of the requirements discussed. For general industry, employers must ensure that workers are protected at heights of 4 feet or more (1910.28(b)(1)(i)). This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). The Difference Between OSHA and ANSI. In a few, very specific situations (low-slope roof work, some leading edge work, precast concrete erection and residential construction), because of feasibility limitations, the standard permits the use of a warning line, in combination with other measures, instead of conventional fall protection (guardrail systems, personal fall arrest systems or safety net systems) to keep employees away from an edge. Please ensure that you are using your warning line system correctly to prevent fatal falls. A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. However, we have now had six years of experience with the application of Subpart M since it was published in 1994. Directorate of Construction, 1 STD3-01.A is the plain language rewrite of STD3.1, issued December 8, 1995, which in turn superseded, with respect to residential construction, the July 12, 1995, fall protection enforcement policy memorandum of Deputy Assistant Secretary James W. Stanley. A single free copy of an OSHA catalog, OSHA 2019, "OSHA Publications and Audiovisual Programs," may be obtained by mailing a self-addressed mailing label to the OSHA Publications Office, Room N3101, U.S. Department of Labor, Washington, DC 20210; telephone (202) 219-4667; facsimile (202)219-9266. A stairway has 6 steps. Warning-line systems consisting of ropes, wires or chains and supporting stanchions should be set up as follows: The warning line must be erected around all sides of the roofing work area. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. [ back to text ], 9 If this were done during and as part of a steel erection activity (§1926.750(b)(1)), then this work would be covered under the steel erection standard under §1926.750(b)(2). Nor does it include nonresidential roofing work as an activity for which a §1926.502(k) fall protection plan may be used as an alternative to conventional fall protection. Warning Line System Requirements. In the Midwest, you cannot simply paint a line on the roof—the first light snow would conceal it. at 40677: As the described roofing activities are not related to overhand brick laying, precast concrete work, or leading edge work6, the only potential in the Standard for use of a controlled access zone again arises in the context of a Fall Protection Plan for residential construction work. Answer This responds to your July 19, 1999 letter to the Occupational Safety and Health Administration (OSHA) requesting clarification on the use of fall protection for employees, other than roofers, working on low slope roofs. Under that section an employer may use a combination of warning lines 6 feet (and in some cases 10 feet) back from the edge in combination … OSHA requirements are set by statute, standards and regulations. Your letter was forwarded to this office for handling on April 7, 2003. Reg. which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. [07/25/2003] 1910.335 – Use of general protective equipment and tools by employees when working near exposed energized conductors or circuit parts in the workplace. However, in the rulemaking for Subpart M, OSHA determined that in certain very limited situations, warning lines are an appropriate means of protection. To meet OSHA requirements in the construction industry, employers must provide workers with fall protection whenever they work at heights of six feet or more above a lower level (29 CFR 1926.501(b)(1)). As such, the Directive does not provide a basis for an employer's use of a warning line system. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to … OSHA requires warning line systems to consist of ropes, wires, or chains with a minimum tensile strength of 500lbs. Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. August 1, 2000 Dayton, OH 45420-0246 Section 1926.500 defines a steep roof as follows: Section 1926.501(11) delineates the fall protection required for employees working on such roofs as follows: The Standard does not permit the use of controlled access zones, warning lines, or other alternative fall protection methods for nonresidential roofing activities on steep roofs. Also, from time to time we update our guidance in response to new information. Blandon, PA 19510 Our response to your company's question regarding the potential use of "controlled access zones" in conjunction with residential roofing activities parallels our answer to Question (1). If a worker works within 2 metres of the control zone i.e. In some circumstances, a warning line system may be used as part of a fall protection plan under §1926.502(k) where an employer demonstrates the infeasibility of conventional fall protection.4 However, as noted in §1926.502(k) itself, the fall protection plan alternative is only available to employees: The described work is not precast concrete erection work (see §1926.501(b)(12)). However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. Warning line is best used to keep people away from unnecessary areas on the roof as well as maintain a safe distance from any hazard. OSHA’s warning line set up requirements (OSHA’s 29 CFR 1926.502(f)) include: All warning lines must be flagged with a highly visible material and spacing must not exceed 6 feet intervals. Safety and health programs, known by a variety of names, are universal interventions that can substantially reduce the number and severity of workplace injuries and alleviate the associated financial burdens on U.S. workplaces. Instead, it should be a line that is 39 to 42 inches high. Also, from time to time we update our guidance in response to new information. That said, the agency’s standard for safety color codes (29 CFR 1910.144) offers some guidance for establishing a color-coded floor marking system. Answer Employers are expected to adhere to all OSHA requirements (see our checklist above). Question (3)(a): We are interested in the availability of alternative fall protection for roofing activities (such as tile, shingle, tar and felt) in the nonresidential construction arena (work not covered by STD 3-0.1A). Shop . Section 1926.500 defines leading edge activity in terms of a structural surface that forms an edge that advances/changes as additional sections are installed: The roofing work you describe (installing a weather-proofing material over a roof deck) is not within that definition, since it is not a structural surface that forms an edge of a walking/working surface. Reg. 40695 the Preamble emphasizes: In sum, §1926.501(b)(13) presumes feasibility. This letter constitutes OSHA's interpretation of the requirements discussed. Source credit is requested but not required. [This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.] Mr. Michael C. Wright, PE, CSP, CPE The Directive only applies to employees engaged in residential construction performing specified activities. 40682: However, at 59 Fed. In some cases warning lines may be used under these provisions. Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances. OSHA recognized that guardrail systems, safety net systems and personal fall arrest systems could pose feasibility problems during roofing work; therefore, the rule allows other choices of fall protection methods. Note that our enforcement guidance may be affected by changes to OSHA rules. Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. [ back to text ], 8 It should be noted that the definition of "Steep roof" and the conventional fall protection delineated in this Section would have equal application to the residential roofing activities referenced in Questions (1) and (2). Three. In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. You specifically ask if that type of procedure is acceptable to OSHA. If unapproved signs or tags are used, it not only puts those in the area at increased risk, but can also result in a citation from OSHA if it is discovered upon inspection. [ back to text ]. We apologize for the long delay in providing this response. Price $21.86. [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. Question (1): 29 CFR 1926.500-1926.503 and OSHA Directive Number STD 3-01.A set[s] forth OSHA's requirements with regard to fall protection for certain residential construction activities, including roofing. Specifically, under these circumstances, can we use warning lines instead of conventional fall protection for those workers? Dear Mr. Wright: Warning lines are to be supported so the lowest point of the sag is no less than 34 inches and no more than 39 inches from the walking/working surface. Implement at least one of the following measures: a. [ back to text ]. Russell B. Swanson, Director Main OSHA Warning Line System requirements – 1926.502 (f) Flagging on the warning line shall be of a highly visible material and spacing must not exceed 6′ – 1926.502 (f) (2) (i) The lowest point of sag shall not be less than 34″ or greater than 39″ – 1926.502 (f) (2) (ii) We have paraphrased your questions below: Section XII of the Directive sets forth alternative fall protection systems for certain defined residential roofing work.5 However, it does not include warning line systems as an alternative. By connecting the line from rail to the rail, … OSHA's fall protection standard for construction, 29 CFR 1926 Subpart M (beginning at §1926.500), generally requires fall protection when there is a fall distance of 6 feet or more. Erect and maintain an elevated warning line, barricade, or line of signs, in view of operator, at the required minimum approach distance (see detailed requirements in OSHA regulation). Some types of metal roofing are installed over a roof deck. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. Rather, the alternative fall protection systems listed are limited to safety monitors and slide guards. Yes. In your letter you state that other trades (for example, electricians and mechanical trades), when working on roofs, tie-off only when they go outside the warning line system. Although this "six foot rule" is widely touted as an acceptable threshold, remember that the laws of physics are immutable, and that … We apologize for the delay in responding. When is a handrail required for stairs? OSHA Requirements for Use of Taglines. Strength, Visibility Also Factors OSHA’s employee alarm systems standard 29 CFR 1910.165 applies to all employers that use an alarm system to satisfy any OSHA standard that requires employers to provide an early warning for emergency action, or reaction time for employees to safely escape the work place, the immediate work area, or both. Foremen and superintendents need to ensure a proper warning-line system setup. Section 1926.501 defines a warning line as: Section 1926.502 (fall protections systems criteria and practices) provides: Significantly, the definition and the referenced §1926.501(b)(10) both refer to or relate to roofing work. Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs Many states have requirements or voluntary guidelines for workplace safety and health programs. We see the bigger picture, and … 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. View Product Details Spec Data. Answer As outlined below, those circumstances, as relevant to your question, are affected by the following three factors: the activity involved (e.g., roofing); the slope of the roof; and the nature of the work (e.g., residential). OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. within 4 metres of the unguarded edge, a raised warning line or equally effective means of alerting the worker to the unguarded edge is required (see Figure 9.25). 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