OSHA Q&A: steel erection work with unprotected surface edge
Question: At what distance from an unprotected side or edge does a worker, performing steel erection activities under 29 CFR 1926 Subpart R with a fall hazard greater than 15 feet, be required to have fall protection?
Response: The fall protection standards for steel erection activities are set out in Sections 1926.760 of 29 CFR 1926 Subpart R (Steel Erection). Section 1926.760(a) states:
(1) Except as provided by paragraph (a)(3) of this section, each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet (4.6 m) above a lower level shall be protected from fall hazards by guardrail systems, safety net systems, personal fall arrest systems, positioning device systems or fall restraint systems.
By its terms, 1926.760(a)(1) requires all employees performing a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level be protected by one of the enumerated fall protection methods, unless an explicit exception applies. There is no "safe" distance from an unprotected side or edge that would render fall protection unnecessary."1
Section 1926.760(a)(3) permits alternative fall protection requirements for connectors and workers in controlled decking zones (CDZ). More specifically, the alternative requirements for employees engaged in leading edge work in a CDZ are set out in Section 1926.760(c), which states:
(1) Each employee working at the leading edge in a CDZ shall be protected from fall hazards of more than two stories or 30 feet (9.1 m), whichever is less.
In conclusion, all employees performing steel erection activities who are exposed to fall hazards, whether doing leading edge decking work in a CDZ or not, must be protected from such hazards as required by the fall protection standards in 1926.760, regardless of the distance from the edge.
James G. Maddux, Director
Directorate of Construction
1 See the preamble to the fall protection final rule, Safety Standards for Fall Protection in the Construction Industry, 59 FR 40683, available at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=894. [Return to Text]