View Info. The installation of that type of metal roofing is not leading edge work, since it is not structural, and does not form an edge of a walking/working surface. Under paragraph 1926.501(b)(2), 1926.501(b)(12), and 1926.501(b)(13), employers engaged in other specified work, such as leading edge work, precast concrete erection, and residential construction may develop and implement a site specific fall protection plan that uses alternative fall protection methods if they can demonstrate infeasibility of conventional fall protection. This use is set forth in §1926.502(k)(7): Again, the option of a Fall Protection Plan is only available where the employer has overcome the presumption that conventional fall protection is feasible.7 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). 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. 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. 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 … Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances. OSHA's fall protection standard for construction, 29 CFR Part 1926 Subpart M (Fall Protection) ("Standard"), as well as its related Directive Number STD 3-01.A ("Directive")1 generally require[s] conventional fall protection (guardrail systems, personal fall arrest systems, or safety net systems) for work where there is a fall distance of 6 feet or more. After 4 steps. Despite this fact, pipe marking doesn’t need to be terribly difficult because you can follow one set of requirements that will help you satisfy all of the others: ANSI/ASME A13.1. 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. Sincerely, Foremen and superintendents need to ensure a proper warning-line system setup. The raised warning line or other equally effective means such as barricades must be placed at least 2 metres from the edge. Given the regulatory history and the presumptions set forth in the Standard, the potential for use of warning lines in this instance appears to be remote. Answer OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. In that case, the fall protection requirements in §1926.760 would apply. (B) Warning lines shall have a minimum tensile strength of 500 pounds. Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). Some types of metal roofing are installed over a roof deck. Yes. 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. Section 1926.501(b)(10) sets out the fall protection requirement for roofing work on low slope roofs. 1926.502 (f) (2) (i) The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with high-visibility material; OSHA Requirements for Use of Taglines. [ back to text ]. Directorate of Construction 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 … 3. 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. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail. [This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.] Because warning line will never "catch" someone from falling off a roof, guardrail will need to be used in specific areas. Implement at least one of the following measures: a. 1910.335 – Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners. 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). 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. He is curious about the results and wonders what actions his employers might have to take to fix any issues found during the inspection. 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. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. We see the bigger picture, and … Price $21.86. In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. Answer When is a handrail required for stairs? Safety Gates. By connecting the line from rail to the rail, … 1926.502 (f) (1) (i) When mechanical equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge. 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. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Answer Russell B. Swanson, Director Dayton, OH 45420-0246 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. Three. Dear Mr. Wright: 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. 3100 Research Blvd. Many states have requirements or voluntary guidelines for workplace safety and health programs. [ back to text ]. We apologize for the long delay in providing this response. Material contained in this publica-tion is in the public domain and may be reproduced, fully or partially, without the permission of the Federal Government. Thus, under the standard, warning line systems may be used as fall protection for some types of roofing work.2 However, as discussed below, a roof's slope and the residential nature of the work may affect the availability of this fall protection. We assume for the purposes of this response that the work to be performed is within the purview of [that] definitions. The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). In the Midwest, you cannot simply paint a line on the roof—the first light snow would conceal it. Also, from time to time we update our guidance in response to new information. Custom Design Services Leading Edge Safety is more than a fall protection company. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. Acceptable use of warning lines as fall protection for roofers and other trades. 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? How many points of contact does this worker have with the ladder? A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and. 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. More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Let’s back up a moment. The Directive only applies to employees engaged in residential construction performing specified activities. Warning lines have specification requirements that include: Warning lines can consist of rope, wire or similar material with a tensile strength of at least 500 pounds. 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 … 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. Mark Troxell, Director of Safety Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. Question 3(b): What about for metal roofing? The Difference Between OSHA and ANSI. If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. [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. Sincerely, 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. Note that our enforcement guidance may be affected by changes to OSHA rules. You specifically ask if that type of procedure is acceptable to OSHA. Mr. Michael C. Wright, PE, CSP, CPE The warning line shall be rigged and supported in such a way that its lowest point (including sag) is no less than 34 inches from the walking/working surface and its highest point is no more than 39 inches from the walking/working surface. Blandon, PA 19510 10 Section 1926.751 defines "Leading edge" as: Occupational Safety & Health Administration, Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. A warning line is used 15 feet or more from the edge; The warning line meets or exceeds the requirements in §1926.502(f)(2); No work or work-related activity is to take place in the area between the warning line and the edge; and ; The employer effectively implements a work rule prohibiting the employees from going past the warning line. This zone provides a first line of defense with a 15-foot warning line. which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. Kee Mark® Warning Line Extension, 20 ft. Price $496.01. 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. However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." 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 with monitors in place of personal fall protection equipment or guardrails. Specifically, the referenced §1926.501(b)(10) limits the use of warning lines to low-slope roofs. Reg.40685 notes: 5 As in the Standard, the Directive sets forth specific residential roofing variables reflecting slope and roof type that affect the availability of the alternative fall protection options. Taglines, long ropes attached to the load, allow ground personnel … The warning line should be rope, wire, or chain. 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) * * * [ 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). 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. Determine if mechanical equipment will be used for the work. However, we have now had six years of experience with the application of Subpart M since it was published in 1994. Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs Develop and implement a site-specific fall protection plan. A stairway has 6 steps. As mentioned earlier, the roofing work also does not fall under §1926.502(k) as precast concrete erection work or leading edge work. 4. OSHA requirements are set by statute, standards and regulations. 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). 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