In any industry where employees are required to work from an elevated height, the risks of falling must be taken into careful consideration. According to the U.S. Department of Labor, “Falls are one of the leading causes of traumatic occupational death, accounting for eight percent of all occupational fatalities from trauma.” Those working in shipyard employment, machine maintenance, the longshoring industry and especially the construction industry regularly deal with fall protection concerns. In fact, OSHA reports an average of 40 construction workers are killed each year from falls off of residential roofs alone.

New OSHA regulations

Because of the many dangers faced by construction workers, OSHA recently updated and increased fall protection regulations for residential construction workers. New regulations will take effect on June 16, 2011, and will replace interim standards implemented in 1995 and 1999. The new standards will still require employers to follow the original fall protection guidelines from 1995, known as subpart M (Reference OSHA 1926.500 - .503).

As stated in OSHA 1926.501, the new compliance requirements for residential construction mandate that workers who can fall six feet or more must be protected by fall protection equipment. Conventional fall protection includes guardrail systems, safety nets or personal fall arrest systems such as full body harnesses, deceleration devices or lanyards and anchor points. Some alternative fall protection measures are allowed for particular types of work.

In addition, workers on low-sloped roofs (defined as having less than or equal to a 4:12 pitch) are no longer allowed to use slide guards (typically a board placed on edge at the eave of the roof) as the only form of fall protection. Acceptable fall protection for low-sloped roofs includes guardrails, nets and personal fall arrest systems. Other combinations of protection are also acceptable, including a warning line and guardrail or warning line and personal fall arrest system. In some cases, a safety monitor is also an acceptable form of fall protection according to OSHA. Work on steep, sloped roofs must be protected by guardrails with toe boards, safety nets or personal fall arrest systems. Slide guards are not acceptable. If such fall protection is infeasible or creates a greater hazard, a fall protection plan can be used. The plan must be written by a quali fied person, be site-specific, up-to-date and document why the use of conventional fall protection is infeasible or creates a greater hazard.

These new standards apply only to employees engaged in residential construction work, defined as a home being built with traditional wood frame construction materials and methods. The limited use of structural steel in a predominantly wood framed home would still qualify as residential construction. Use of sheet metal studs or the use of masonry brick in exterior walls would also fall under residential construction. (Residential construction work on scaffolds, ladders and aerial lifts is covered by other OSHA standards. Nursing homes, hotels and similar facilities are not considered residential construction.)

Previous OSHA regulations

Previous compliance regulations were originally issued by OSHA in 1995. (A plain language version was later issued in 1999.) These regulations were intended only as a temporary policy after concerns were voiced about the feasibility of fall protection in residential building construction.

The instruction permitted employers engaged in certain residential construction activities to use specified alternative procedures instead of conventional fall protection. These alternative procedures could be used without showing why conventional fall protection was not feasible or why it presented a greater hazard if used.

For example, the old instruction said that employers performing roofing work did not have to use active fall protection systems such as harness/ lanyard/ lifeline or self-retracting devices, guardrails or nets in many situations. Instead they had the option of using slide guards or other alternative measures. The alternative forms of fall protection could typically be used when the pitch of the roof was 8:12 or less and the ground to eave height was 25 feet or less.

According to a December 2010 news release issued by OSHA, the National Association of Home Builders recommended rescinding the 1995 directive, as did OSHA’s labor-management Advisory Committee for Construction Safety and Health, the AFL-CIO and the Occupational Safety and Health State Plan Association, which represents the 27 states and territories that run their own occupational safety and health programs.

Falling injury rates

Once new OSHA regulations take effect June 16, any employer who is not providing acceptable forms of fall protection for affected workers will be cited, unless they can demonstrate why conventional fall protection was not feasible or why it presented a greater hazard if used. Of course employers have always had a responsibility to protect their employees from work-related hazards, but improved guidelines from OSHA will help to lead the construction industry and all industries in a safer direction. This will result in better work environments and reduce the amount of fall-related injuries and fatalities suffered on the job.

Note: Capital Safety, one of the leading manufacturers of fall protection, contributed to the content of this article.

SIDEBAR: Highlights of the new OSHA compliance instruction

• Fall protection is needed anytime a fall of 6 feet or more is possible, including roof work.
• A 25-foot eave-to-ground height threshold rule no longer applies.
• Slide guards are no longer acceptable forms of fall protection, regardless of the roof pitch or height of roof eave.
• Written site-specific fall protection plans can be used as a form of fall protection if conventional fall protection is shown to be infeasible or if it presents a greater hazard.
• The interim OSHA instruction STD 03-00- 001, which provided some flexibility for fall protection, is cancelled.
• The effective date for the new guidance instruction is June 16, 2011.