The Directive only applies to employees engaged in residential construction performing specified activities. The Graham Company Your letter was forwarded to this office for handling on April 7, 2003. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. 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. Specifically, under these circumstances, can we use warning lines instead of conventional fall protection for those workers? You ask about the use of warning lines or controlled access zones as fall protection for employees engaged in certain roofing activities. Implement at least one of the following measures: a. Flag warning lines with a highly visible material at 6-foot intervals. Instead, it should be a line that is 39 to 42 inches high. Compliance of using warning lines and/or control access zones for fall protection on roofs with a slope greater than 4:12. August 1, 2000 OSHA requirements are set by statute, standards and regulations. OSHA Requirements for Use of Taglines. OSHA requirements are set by statute, standards and regulations. Avoid using plastic tape for a warning line; workers should be able to feel the line if they back up against it, eve if they’re … Warning line systems [See 1926.501 (b) (10)] and their use shall comply with the following provisions: 1926.502 (f) (1) The warning line shall be erected around all sides of the roof work area. Section 1926.501(b)(10) sets out the fall protection requirement for roofing work on low slope roofs. 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. 1910.335 – Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners. As such, the Directive does not provide a basis for an employer's use of a warning line system. 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. Note that our enforcement guidance may be affected by changes to OSHA rules. However, the activity does fall within the purview of §1926.501(b)(13) of the Standard entitled "Residential Construction." Whenever using any type of accident prevention sign or tag, it is essential to understand all the requirements. [ back to text ]. 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 Reg. [This document was edited on 12/5/12 to strike information that no longer reflects current OSHA policy.] 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. 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. Occupational Safety and Health Administration, Severe Storm and Flood Recovery Assistance. 3100 Research Blvd. 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. OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts. [ back to text ]. 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. * * * 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 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. Conventional fall protection under Part 1926 Subpart M is required for this type of work (unless it were done in conjunction with steel erection work).9 The warning line should be rope, wire, or chain. This is in response to your letter dated February 25, 2003, to the Occupational Safety and Health Administration (OSHA). 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? This activity may be performed in a controlled decking zone as noted in Section 1926.760 Fall Protection: in Appendix D to this subpart. Some types of metal roofing serve as the roof structure or metal decking (there is no structural decking below it). 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. 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. PO Box 20246 Sincerely, Dayton, OH 45420-0246 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. 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. Designated area warning line If your employees perform maintenance and/or repair activities at least six feet but less than fifteen feet from the roof edge, OSHA also allows “designated areas” delineated by a warning line, assuming the work is infrequent and temporary in nature. Safety Gates. Although this "six foot rule" is widely touted as an acceptable threshold, remember that the laws of physics are immutable, and that … If a worker works within 2 metres of the control zone i.e. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. 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. September 26, 2003 Price $21.86. Strength, Visibility Also Factors [ back to text ], 2 The term "Roofing work" is defined in §1926.500 of the Standard and in VIII.B.4 of the Directive. As with warning lines, the Directive does not provide for the use of controlled access zones as an alternative fall protection system for residential roofing activities. Yes. 107 Ponderosa Drive 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). (B) Warning lines shall have a minimum tensile strength of 500 pounds. How many points of contact does this worker have with the ladder? Mr. Michael C. Wright, PE, CSP, CPE 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)). At 15 feet from the edge, a warning line, combined with effective work rules, can be expected to prevent workers from going past the line and approaching the edge. Nonetheless, the use of a warning line system, as an alternative, is available in certain circumstances. The raised warning line or other equally effective means such as barricades must be placed at least 2 metres from the edge. Stamped Steel Warning Flag. We apologize for the delay in responding. The activity is also not leading edge work (§1926.501(b)(2)). We assume for the purposes of this response that the work to be performed is within the purview of [that] definitions. 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. In some cases warning lines may be used under these provisions. Designated Area, according to OSHA, is an area delineated by a warning line to enforce a safe working zone. Managing Principal 40682: However, at 59 Fed. 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. This zone provides a first line of defense with a 15-foot warning line. Many states have requirements or voluntary guidelines for workplace safety and health programs. Develop and implement a site-specific fall protection plan. The Difference Between OSHA and ANSI. 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). Because warning line will never "catch" someone from falling off a roof, guardrail will need to be used in specific areas. 40692, this Section, entitled "Residential construction" requires: The Preamble continues at 59 Fed. Section 1926.501(b)(10) allows roofers working on low-sloped roofs to have several fall protection options. The employer effectively implements a work rule prohibiting the employees from going past the warning line. Answer Designed to designated areas and to alert workers of dangerous conditions, this system can help prevent accidents. The terms of the standard do not otherwise provide that warning lines may be used in place of conventional fall protection. After 4 steps. [ back to text ], 7 The previous discussion on "feasibility" in footnote 3 is equally applicable here. 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) An OSHA inspection was conducted at Raul's workplace. [ back to text ], 6 See earlier discussion on leading edge work. 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 … Let’s back up a moment. As your letter indicates that question (3) only relates to nonresidential construction, the Directive would have no applicability. 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. Please ensure that you are using your warning line system correctly to prevent fatal falls. 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. Determine if mechanical equipment will be used for the work. Kee Mark® Warning Line Extension, 20 ft. Price $496.01. Warning Line System Requirements. [ back to text ], 3 See Question (3) below for a discussion of the conventional fall protection provided for in the Standard for "Steep roofs." Re: 29 CFR 1926.501(b)(10) Roofing work and other trades working on low slope roofs Does Raul have a right to this information? However, in the rulemaking for Subpart M, OSHA determined that in certain very limited situations, warning lines are an appropriate means of protection. 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; 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. 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. However, we have now had six years of experience with the application of Subpart M since it was published in 1994. Answer More significantly, a summary of its permitted uses under the Standard is set forth in the Preamble at 59 Fed. We have paraphrased your questions below: Russell B. Swanson, Director The installation of such decking is leading edge work10 and is included in the steel erection standard (Part 1926 Subpart R) as a steel erection activity under §1926.750(b)(1). 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. 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. 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. By connecting the line from rail to the rail, … Shop . 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. 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. If you need 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. which are supported by stanchions that are designed to withstand being tipped by 16 pounds of pressure 30” from the walking or working surface. 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? A proximity alarm set to give the operator sufficient warning to prevent encroachment into the minimum approach distance. OSHA Railing Local Regulations. 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. Dear Mr. Troxell: 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. 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. Acceptable use of warning lines as fall protection for roofers and other trades. OSHA: A warning line is used 15' or more from the edge. In the Midwest, you cannot simply paint a line on the roof—the first light snow would conceal it. [Corrected 6/2/2005], Occupational Safety & Health Administration. 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. OSHA encourages all employers to adopt a safety and health program. View Info. Re: Whether warning lines and/or control access zones can be employed for roofing work (residential and non-residential) on roofs with a slope greater than 4:12 Three. 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 … 4 The Preamble at 59 Fed. [ 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). [ 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). To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. Employers are expected to adhere to all OSHA requirements (see our checklist above). We see the bigger picture, and … 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. 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. Question 3(b): What about for metal roofing? 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). Custom Design Services Leading Edge Safety is more than a fall protection company. A stairway has 6 steps. In that case, the fall protection requirements in §1926.760 would apply. As mentioned earlier, the roofing work also does not fall under §1926.502(k) as precast concrete erection work or leading edge work. Warning Lines Permanent The Permanent Warning Line system is a fast, easy, and economical way to erect warning lines. 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. The TrafFix Devices Roof Edge Delineator warning line meets or exceeds the requirements in 1926.502 (f) (2). Specifically, the referenced §1926.501(b)(10) limits the use of warning lines to low-slope roofs. OSHA requires warning line systems to consist of ropes, wires, or chains with a minimum tensile strength of 500lbs. Also, from time to time we update our guidance in response to new information. 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)). Your letter states that the warning line system is "around the perimeter of the roof." It provides in part: Section 1926.500 defines "Low-slope roof" as: Thus, the intended residential roofing activities on roofs with a slope greater than 4 in 12 would not meet the stated criteria of these sections that allow for the use of a warning line system.3 As §1926.501(b)(10) is the only provision that specifically provides for the use of a warning line system (in conjunction with another system) as fall protection for roofing activities, the employer here cannot use such a system unless another provision in the Standard or the Directive applies. 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. 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. (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. Directorate of Construction b. 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. We apologize for the long delay in providing this response. 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. Reg. Mark Troxell, Director of Safety Reg. View Product Details Spec Data. Typically, lines are yellow so it’s clear to those on the roof that they’re not supposed to cross that line without OSHA-required restraints. Foremen and superintendents need to ensure a proper warning-line system setup. 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. In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. When is a handrail required for stairs? Also, from time to time we update our guidance in response to new information. 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. Section 1926.500 defines a "Controlled Access Zone" ("CAZ") as: Particular requirements associated with its use are delineated in §1926.502(g). Answer 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. 3. 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. 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. As summarized in the Preamble at 59 Fed. Blandon, PA 19510 Section 1926.501 defines a warning line as: * * a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. Russell B. Swanson, Director In general, OSHA's fall protection standard requires that anyone working at heights of 6 feet or more be provided with fall protection. 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. Taglines, long ropes attached to the load, allow ground personnel … LJB, Inc. No. [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. For general industry, employers must ensure that workers are protected at heights of 4 feet or more (1910.28(b)(1)(i)). 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. 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). 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). Sincerely, Dear Mr. Wright: 40695 the Preamble emphasizes: In sum, §1926.501(b)(13) presumes feasibility. 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. Source credit is requested but not required. 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. OSHA offers no requirements for specific floor marking colors; however, a 1972 OSHA interpretation states that lines meant to define aisles may be any color, provided they clearly lay out the aisle. You specifically ask if that type of procedure is acceptable to OSHA. Therefore, we will apply a de minimis policy for non-conforming guardrails 15 or more feet from the edge under certain circumstances. 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. Specifically, we will consider the use of certain physical barriers that fail to meet the criteria for a guardrail a de minimis violation of the guardrail criteria in §1926.502(b) where all of the following are met: In sum, the use of warning lines closer than 15 feet from the edge is not permitted as a substitute for conventional fall protection for these other trades. 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. Line will never `` catch '' someone from falling off a roof deck of ropes, wires, chains... More be provided with fall protection: in Appendix D to this Subpart to text,... Least one of the requirements prevention, then please see our checklist above.! Rule prohibiting the employees from going past the warning line system significantly, a summary of its permitted uses the! We update our guidance in response to new information is equally applicable here a line that 39! Limits the use of warning lines or controlled access zones for fall protection company was published in 1994 strike that! Response to new information past the warning line should be rope,,! 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