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The Occupational Safety and Health Administration on Dec. 22 withdrew the Plain Language Revision of OSHA Instruction STD 3.1, Interim Fall Protection Compliance Guidelines for Residential Construction. First issued in 1995, the directive was a source of confusion among home builders over what fall protection methods and systems should be used to comply with OSHA’s fall protection standards.
The confusion stems from the variety of sources of fall protection compliance information that builders and trade contractors need to find, read, understand and then follow. To understand what they need to do to protect workers, builders have to read OSHA’s fall protection regulation, then read the interim fall protection guidelines and then find the 25 or more letters of interpretation of what is required.
Because falls continue to be the leading cause of costly accidents, injuries and even fatalities in the home building industry, NAHB is actively engaged in seeking solutions to address this very real and serious problem. Concerned that the interim guidelines were making the work environment less safe for employees on the home building site, NAHB in April 2008 asked OSHA to withdraw them and instead follow the fall protection regulations in OSHA standard 29 CFR 1926 Subpart M, which allows residential construction employers some flexibility in providing fall protection systems.
This important enforcement policy change will require employers to take additional steps to ensure worker safety when working six feet or more above a lower level. The new Compliance Guidance for Residential Construction will go into effect on June 16, 2011.
Among the significant changes resulting from the withdrawal of OSHA STD 03-00-001:
Roofing contractors must use guardrails, personal fall arrest systems (harnesses and lanyards) or safety nets on all roofs with slopes exceeding 4-in-12 when working six feet or more above a lower level.
All other trade contractors must use guardrails or personal fall arrest systems (harnesses and lanyards) or safety nets when the height from one elevation to another is greater than six feet. However, employers who can demonstrate that these fall protection systems are not feasible or create a greater hazard can use a plan outlining alternative fall protection measures that must be followed.
The fall protection plan must be in writing and site-specific. However, a written plan developed for repeated use for a particular model or style of home will be considered site-specific.
The use of fall protection plans is limited to “residential construction” in which the structure will be used as a home and constructed with traditional wood frame materials and methods (although the limited use of structural steel in a predominantly wood-framed home — such as a steel I-beam to help support wood framing — does not disqualify a structure from being considered residential construction).
NAHB expects the OSHA policy change to ultimately make it easier for home builders to understand what's necessary to achieve compliance, to ensure safer worksites and to reduce the occurrence of costly accidents.
If you are attending the International Builders’ Show in Orlando, OSHA staff will be in attendance to discuss the policy change in detail at the NAHB Construction Safety and Health Committee meeting on Tuesday, Jan. 11, from 10:30 a.m.-1:00 p.m. in Room West 312 B, Level III at the Orange County Convention Center.